Item No. 13 - CONSIDERATION OF GENERAL PLAN AMENDMENT NO. 20-01Responses to Comments on Draft Initial
Study/Mitigated Negative Declaration
Walnut Grove Residential Project
SCH No. 2020110322
Prepared for City of West Covina
Planning Division
1444 West Garvey Avenue South, 2nd Floor, Room 208
West Covina, California 91790
Contact: Jo-Anne Burns, Planning Manager
JBurns@westcovina.org
Prepared by Psomas
5 Hutton Centre Drive, Suite 300
Santa Ana, California 92707
Contact: Alia Hokuki
(714) 751-7373
February 2021
ATTACHMENT NO. 12
Table of Contents
WALNUT GROVE RESIDENTIAL PROJECT i
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TABLE OF CONTENTS
Section Page
Introduction and Summary ............................................................................................................. 1‐1
Introduction ............................................................................................................................... 1-1
List of Commenters ............................................................................................................................. 2‐1
Responses to Comments ................................................................................................................... 3‐1
State Agencies ........................................................................................................................... 3-1
Regional/Local Agencies ...................................................................................................... 3-7
Individuals ............................................................................................................................... 3-13
Revisions As Part of The Final IS/MND ........................................................................................ 4‐1
Revisions to the Draft IS/MND .......................................................................................... 4-1
4.1.1 Section 3.0, Project Description ......................................................................... 4-1
4.1.2 Section 4.15, Public Services ................................................................................ 4-3
References ............................................................................................................................................. 5‐1
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INTRODUCTION AND SUMMARY
INTRODUCTION
The purpose of this document is to present public comments and responses to those comments
received on the Draft Initial Study/Mitigated Negative Declaration (Draft IS/MND) for the
Walnut Grove Residential Project (State Clearinghouse Number 2020110322). The City of West
Covina, as the Lead Agency, has evaluated all substantive comments and has prepared written
responses. In accordance with the California Environmental Quality Act (CEQA) Guidelines (Title
14 California Code of Regulations [CCR] Section 15074[b]), the decision-making body of the Lead
Agency must consider the IS/MND and comments received before approving the Project. This
document, which will be provided to the City Council, as the decision-making body, has been
prepared in accordance with CEQA and represents the independent judgment of the
Lead Agency.
The approximate 9.14-acre Project site is in the City of West Covina, in Los Angeles County,
California. The site is located at 1651 East Rowland Avenue, north of East Rowland Avenue and
west of North Azusa Avenue. The Project site is surrounded by single family residential uses to
the north and west. Commercial, retail, restaurant, and office uses are located to the east, and
immediately to the north is a shopping center. To the south and across East Rowland Avenue, is
a large commercial retail shopping center, and beyond that is a single-family residential
neighborhood.
The proposed Walnut Grove Residential Project would involve construction of a 158-unit
attached and detached residential development with a density of 16.7 dwelling units per acre
(du/ac). The existing vacant school uses on the site, including administrative buildings and
surface parking lot, would be demolished to accommodate the proposed Project.
The Project would consist of two different types of residences, including 66 units of detached
single-family in a cluster configuration and 92 attached multi-family units. The proposed
detached single-family units would have a minimum of three floor plan types, with units ranging
in size from 1,471 to 1,798 square feet (sf). The proposed townhomes would have a minimum of
three floor plans, ranging in size from 1,310 to 1,721 sf. Furthermore, the Project would include
2 covered garage parking spaces per dwelling unit (for a total of 316 indoor garage spaces) and
99 uncovered guest surface parking spaces throughout the Project site. A common open space
area would be provided on-site at one central location at the Project site, and private open spaces
would be available for each single-family unit. The common open space area would consist of
0.27 acre of neighborhood park use, which would include bench seating areas and trash
receptacles; picnic areas; children’s tot-lot area; open turf area; connecting walkways; and
mailboxes.
In accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review and comment period beginning on November 19, 2020 and ending on
December 21, 2020. Additionally, the Draft IS/MND was available at the City of West Covina
website. During the public review period, the City received a total of eight comment letters from
State agencies, regional/local agencies, and individuals on the Draft IS/MND. Written responses
Introduction and Summary
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have been prepared to all comments received during the comment period and are included in
Section 3.0 of this document.
The Final IS/MND consists of three documents: (1) the Draft IS/MND; (2) the Technical
Appendices; and (3) the Responses to Comments document. The Responses to Comments
document includes three sections: Section 1.0, provides the introduction; Section 2.0 provides a
list of commenters on the Draft IS/MND; Section 3.0 provides responses to environmental
comments received on the environmental document; and Section 4.0 includes the revisions to
the text of the Draft IS/MND.
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LIST OF COMMENTERS
The following is a list of commenters that submitted written comments on the Draft IS/MND. The
comments included written and e-mail correspondence. The comments are listed
chronologically and numbered. The responses have been prepared to match the bracketing on
the comment letters. Each comment letter is followed by responses to address the comments.
The comment letters and responses are included in Section 3.0 of this document.
No. Commenter Date of
Correspondence
Page
Number
State Agencies
1 Department of Transportation, District 7 (DOT) December 16, 2020 3-3
Local and Regional Agencies
2 Los Angeles County Sanitation Districts (LACSD) December 21, 2020 3-9
Individuals
3 Michael and Patricia Dobszewicz (M&PD) December 18, 2020 3-15
4 Andrew and Elizabeth Guerrero (A&EG) December 18, 2020 3-23
5 Miguel Diaz (MD) December 21, 2020 3-31
6 Fabiola Zelaya Melicher (FZM) December 21, 2020 3-35
7 Mr. and Mrs. Santos (SAN) December 21, 2020 3-51
8 Ward and Phyllis Wenner (W&PW) December 22, 2020 3-57
List of Commenters
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RESPONSES TO COMMENTS
The City’s responses to comments received on the Draft IS/MND are provided below. The
responses are numbered to match the bracketing on the comment letter. Comment letters
received are categorized by State agencies, regional/local agencies, and individuals. Within each
category, the responses are provided chronologically.
STATE AGENCIES
One comment letter was received from the State agencies. The comment letter is listed below:
Department of Transportation, District 7 (DOT)—December 16, 2020
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Letter 1: Department of Transportation, District 7
Comment Letter Dated December 16, 2020
DOT-1 The comment reiterates the Project description. No response is required.
DOT-2 The comment regarding the mission of Caltrans and the use of Vehicle Miles
Traveled (VMT) as the primary metric in identifying transportation impacts is
noted. No. further response is required.
DOT-3 The comment regarding incorporation of the multi-modal and complete streets
transportation elements, which promote alternative modes of transportation is
noted and will be forwarded to the decision makers.
As identified in the IS/MND, the Project would be consistent with adopted policies,
plans, or programs regarding public transit, bike, or pedestrian facilities. As
discussed in the IS/MND, Section 4.8, Greenhouse Gas Emissions and 4.17,
Transportation of the IS/MND, the Project is an infill development and would result
in trip reductions due to the Project site’s proximity to nearby commercial uses
within walking distance of the Project site. As such, the Project would promote
pedestrian activity in an area with complementary uses, which would reduce
reliance on single-passenger vehicles.
Additionally, sidewalks are present on East Rowland Avenue, which would be
retained by the Project and would continue to accommodate pedestrians and
bicyclists. As presented in Project Design Feature (PDF) TRA-2 in Section 3.0,
Project Description and Section 4.17, Transportation of the IS/MND, the on-street
parking along Project frontage (i.e., East Rowland Avenue) would be removed by
implementing red curbing, which would improve visibility and provide additional
on-street space for bicyclists.
In terms of public transportation, the nearest bus routes to the Project site include:
Bus Route 280 (on Azusa Avenue) and Bus Route 488 (along East Rowland Avenue).
Although there have been some changes to transit service due to the COVID-19
pandemic, the Foothill Transit bus lines in the Project area are still operating as
usual. The proximity to and availability of bus lines would encourage use of this
mode of public transportation.
While features such as internal paseos and walkways are included in the Project to
accommodate pedestrians, in light of the commenter’s comments and to
accommodate use of bikes, the text of the IS/MND and the associated exhibit
(Exhibit 3-6, Conceptual Park Enlargement Plan) will be revised to incorporate bike
racks on-site for use by future residents of the Project and their guests. The bike
racks will be provided in two locations adjacent to the mailboxes around the
perimeter of the park. These revisions do not require recirculation of the IS/MND
under CEQA Guidelines Section 15073.5(c)(4). The following addition is hereby
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made to the text of the IS/MND under Section 3.1, Residential Land Use, on page 3-2
of the IS/MND (new text is shown in red italics):
A common open space area would be provided on-site at one central
location at the Project site, and private open spaces would be available for
each single-family unit. The Project would have 100 sf of common open
space per unit (including walking paseos and the neighborhood park use).
The single-family units would have a minimum of 150 sf of private open
space per unit, and the multi-family units would have a minimum of 100 sf
of private open space per unit. The common open space area of the Project
would consist of 0.27 acre of neighborhood park use, hereinafter referred to
as the (“Community Open Space Area”). The Community Open Space Area
would have a private park that is publicly accessible for use. Open space
amenities would include bench seating areas and trash receptacles; picnic
areas; children’s tot-lot area; open turf area; connecting walkways; and
mailboxes. Additionally, to accommodate use of bikes by future residents and
their guests, bike racks will be provided at two locations adjacent to mail boxes
and wood arbor trellis entries, around the perimeter of the proposed park.
The above modification will also be reflected in Exhibit 3-6, Conceptual Park
Enlargement Plan. The exhibit is hereby modified to incorporate the proposed bike
racks. The updated exhibit is included in Section 4.0, Revisions as Part of the Final
IS/MND.
The comment regarding complete streets and pedestrian safety measures as road
diets is noted and will be forwarded to the decision makers. This comment is
beyond the scope of the proposed Project. No further response is required.
The comment regarding Caltrans’ publication of the VMT-focused Transportation
Impact Study Guide (TIGS) is noted and will be forwarded to the decision makers.
No further response is required.
DOT-4 The commenter concurs with the finding that the Project is in a Transit Priority Area
(TPA), and as such, exempt from a VMT analysis. Further, the commenter indicates
that Project’s contribution to the adjacent intersections or the State facility is
nominal, and potential impact to an intersection or State facility is unlikely.
Comment is noted and will be forwarded to the decision makers. No further
response is required.
DOT-5 The comment regarding requirement for a transportation permit from Caltrans for
use of oversized transport vehicles on State highways is noted. The Applicant is
aware of this requirement and will obtain the permit, as appropriate. The comment
adds that the truck trips should be limited to off-peak commute period and that idle
time should not exceed 10 minutes. Comment is noted. No further response is
required.
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REGIONAL/LOCAL AGENCIES
One comment letter was received from the local/regional agencies. The comment letter is listed
below:
Los Angeles County Sanitation Districts (LACSD)—December 21, 2020
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Letter 2: Los Angeles County Sanitation Districts
Comment Letter Dated December 21, 2020
LACSD-1 The comment acknowledges receipt of the Notice of Intent to Adopt a Mitigated
Negative Declaration (NOI) and identifies the jurisdictional boundary where the
Project is located as District 22. The comment is noted, and no further response is
required.
The comment additionally identifies the Project’s wastewater flow, which would
ultimately convey to the District’s Joint Outfall H Unit 8N Trunk Sewer. The
comment indicates that the District’s trunk sewer has a capacity of 7.3 million
gallons per day (mgd) and its peak flow of 2.6 was recorded in 2014. The comment
and the capacity of District’s trunk sewer line is noted. No further response is
required.
LACSD-2 The comment identifies the San Jose Creek Water Reclamation Plant (WRP) as the
facility that would be treating the wastewater generated by the proposed Project.
The comment also notes that the effluent exceeding the capacity of the said plant
are treated at the Joint Water Pollution Control Plant in the City of Carson. The
comment is noted, and no further response is required.
LACSD-3 The comment identifies the Project’s wastewater flow as 35,100 gallons per day.
The comment also provides direction as to where the District’s wastewater
generation factors can be retrieved. The comment is noted, and no further response
is required.
LACSD-4 The comment discusses the Districts’ connection fee that may be required of the
Project. For information pertaining to the fee, the comment references the Districts’
website. Additionally, the comment indicates that for specific information regarding
the connection fee and application produces, the developer should contact the
Districts’ Wastewater Fee Public Counter. The comment is noted, and no further
response is required.
LACSD-5 The comment discusses the correlation between the capacity of the Districts’
wastewater facilities and the Southern California Association of Governments’
(SCAG’s) regional growth forecast. The comment notes that while this letter
provides information regarding the existing capacity and informs that the Project
will be served by the Districts up to the levels that are legally permitted, it is not a
guarantee of wastewater service. The comment is noted, and no further response is
required.
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INDIVIDUALS
A total of six comment letters/emails were received from the individuals and members of the
community. The comment letters/emails are listed below:
Michael and Patricia Dobszewics (M&PD)— December 18, 2020
Andre and Elizabeth Guerrero (A&EG)—December 18, 2020
Miguel Diaz (MD)—December 21, 2020
Fabiola Zelaya Melicher (FZM)—December 21, 2020
Mr. and Mrs. Santos (SAN)—December 21, 2020
Ward and Phyllis Wenner (W&PW)—December 21, 2020
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Letter 3: Michael and Patricia Dobszewicz
Comment Letter Dated December 18, 2020
M&PD-1 The comment identifies the location of the commenters’ home in relation to the
Project and indicates that they have concerns. The comment is noted, and no further
response is required.
Privacy / Solar Panels
M&PD-2 The comment identifies the location of their property in relation to the proposed
Project at their southern property line. The comment states that unlike what they
were told at the community meeting, the proposed Project would be 15 feet from
their property and not 30 feet. In light of this distance, the commenter expresses
concern for lack of privacy.
It should be noted that the site plan presented to the surrounding neighbors at the
community meeting has not changed relative to the setback from the northerly
property line. The setback is larger than what the zoning requires for the adjacent
residential zone. The adjacent property is zoned R-1, which requires a 25-foot front
setback and a 5-foot side and rear setbacks with a maximum building height of
25 feet. For comparison, the second floor would require a 30-foot front setback, a
10-foot side setback, and a 25-foot rear setback. The proposed Project provides a
15-foot side setback, 7.5-foot landscaper buffer, and a 25-foot building height.
M&PD-3 The next concern expressed by the commenter is the usable windows to the north
side of the proposed structures facing their backyard. The comment adds that based
on discussions at the neighborhood meeting, it is anticipated that usable windows
would not be installed such that would invade their backyard privacy. The comment
asserts that the graphics in the IS/MND do not depict the back side of the proposed
structures, so they cannot confirm lack of such windows. The comment is noted and
will be forwarded to the decision makers. However, lack of graphics showing the
back side of the proposed structures, does not imply that the preferred windows
would not be installed. In fact, the windows on the second story units along the
north side of the property have been modified to a height that will make it
impractical for the future residents in those units to have downward visibility into
the existing adjacent properties.
M&PD-4 The comment expresses concern over the type of trees that would be installed
between the proposed Project and their property casting shade on their solar
panels that are installed on the south facing rooftop of their home. In light of growth
potential of these trees, the natural light onto their property would be impacted.
The designated 7.5-foot landscape buffer is intended to be planted with Podocarpus
Gracilior (or similar) and maintained on a regular basis. The purpose of the buffer
is to provide additional privacy. The landscape buffer will not be a maintenance
obligation of the individual unit owner. To keep the landscape buffer uniform, the
plant material will be maintained by the homeowners association for the Project
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and will be kept at a manageable height that will not impact roof-mounted solar
panels.
M&PD-5 The commenter explains the upgrades to their backyard and objects to structures
that would cast shade on their property or their solar panels. Please refer to
Response M&PD-4, above. No further response is required.
Traffic
M&PD-6 The comment shared concerns regarding local congestion resulted by schools in the
area and identifies specific issues in the local circulations system. The commenters
add that the proposed Project will exacerbate the existing congestion. The comment
is noted and will be forwarded to the decision makers.
It should be recognized that the improvements for the intersections on North Azusa
Avenue are not required for this Project. If the desire is to reach Trawek or Covina
High, a right turn from Puente Avenue onto North Azusa Avenue followed by a left
turn on East Rowland Avenue would likely be more efficient than traveling through
the neighborhood to reach East Rowland Avenue directly. Additional concerns
regarding the Azusa intersections are beyond the scope of this Project and can be
addressed to the City, and no further response is warranted.
Additionally, Section 4.17, Transportation, of the IS/MND includes a detailed
analysis of the potential traffic impacts of the proposed Project. While it is
acknowledged that the Project would generate trips and increase traffic, as
identified in Section 4.17, construction traffic is not likely to create any significant
impact due to the size of the proposed Project. Additionally, during Project
operations, the limited number of Project trips (69) traveling through the Azusa
Avenue/Rowland Avenue intersection is unlikely to result in any impacts to the
operation of the intersection. Thus, potential impacts are considered less than
significant, and no mitigation measures are deemed necessary.
M&PD-7 The comment identifies changing the deep drainage passages on North Azusa
Avenue as a mitigating factor, as they will slow down cars while crossing. Your
comment is noted and will be forwarded to the decision makers. The changes
proposed are beyond the scope of this Project and can be addressed to the City. No
further response is warranted.
M&PD-8 The comment regarding congestion due to the schools in the area is noted and will
be forwarded to the decision makers. It should be recognized that school zones are
generally areas of congestion, particularly in the morning peak period where school
drop offs corresponds with the overall peak travel period of all (non-school) traffic.
Congestion issues around schools are common throughout the City, but school
traffic impacts to peak hour commuter travel are generally limited to a relatively
short period in the AM peak hour (school release times generally do not overlap
with the PM peak commute period). As discussed in Section 4.17, Transportation,
of the IS/MND, in the morning, the Project is expected to add approximately 32
vehicles in the area of Rowland Avenue Elementary, with the remaining 48 vehicles
expected to travel on East Rowland Avenue only between Azusa Avenue and the
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Project site. While the introduction of only a few vehicles to an already-congested
situation can worsen conditions, the number of vehicles being added will be a
relatively small percentage of the existing traffic in the area. As indicated in
Response M&PD-6, above, the limited number of vehicle trips generated by the
proposed Project are unlikely to result in any impacts at roadways and intersections
near the site and in the surrounding area. As such, the analysis does not identify any
mitigation measures, as none is required.
Additional Concerns
M&PD-9 The comments expresses concern over a palm tree that is believed to be on the
school property. The commenters request that the tree be removed. It should be
noted that if the tree is outside the Project boundary, the Applicant is not
responsible for removing the tree. However, based on discussions between the
Applicant and the commenters, the Applicant has agreed to remove the said
palm tree.
M&PD-10 The comment is regarding the wall on the south side of the property that the
commenters built. While the commenters previously discussed replacing their wall
with the proposed block wall, they are concerned about the potential impact to their
large plants (shrubs) along their existing wall. It should be noted that the Applicant
is currently working with the commenters on either an extension or replacement of
the wall, and the Applicant is aware of the commenters’ concerns about their plants
along the existing wall.
M&PD-11 The comment regarding potential light spillover onto the commenters’ property is
noted and will be forwarded to the decision makers. The discussion in Section 4.1,
Aesthetics, of the IS/MND acknowledges that the Project would change lighting
levels; however, it indicates that the lighting would be consistent with the ambient
and night-time lighting at the existing residential uses around the site. To further
avoid potential impact and light trespass onto the surrounding uses, the Walnut
Grove Specific Plan includes provisions to address the potential lighting issues. In
compliance with the Specific Plan, fixtures would have devices to aim light
downward with a minimum 70 percent cut off. Additionally, the City’s Municipal
Code regulates exterior lighting to ensure that sensitive land uses are not affected
by lighting associated with new developments. Section 26-519 of the City’s
Municipal Code requires that “all lighting of the building, landscape, parking area,
or similar facilities shall be hooded and directed to reflect away from adjoining
properties”. This is generally accomplished with shielding and directional lighting
methods, and lighting will specifically focus on streets, parking, and pedestrian
areas. Thus, in light of the provisions in place, the potential impacts pertaining to
light spillover would be less than significant.
M&PD-12 The comment regarding holes on the asphalt on Eileen by the survey company is
noted. It should be recognized that the Applicant will modify the cul-de-sac at the
south of North Eileen Street to improve drainage, but it will remain essentially in its
current configuration. The cul-de-sac will not be removed or incorporated into the
new community. A solid perimeter wall will be installed around the cul-de-sac to
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discourage access and parking for new residents and guests. There will be a gated
access point restricted to emergency vehicles only.
Following completion of the drainage improvements at the North Eileen Street cul-
de-sac, the road will be repaired to resurface damaged areas associated with the
construction effort and the holes identified by the commenters.
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Letter 4: Andre and Elizabeth Guerrero
Comment Letter Dated December 18, 2020
A&EG-1 The comment identifies the location of the commenters’ home in relation to the
Project and indicates that they have concerns. The comment is noted, and no further
response is required.
Privacy / Solar Panels
A&EG-2 The comment identifies the location of their property in relation to the proposed
Project at their southern property line. The comment states that unlike what they
were told at the community meeting, the proposed Project would be 15 feet from
their property and not 30 feet. In light of this distance, the commenter expresses
concern for lack of privacy.
It should be noted that the site plan presented to the surrounding neighbors at the
community meeting has not changed relative to the setback from the northerly
property line. The setback is larger than what the zoning requires for the adjacent
residential zone. The adjacent property is zoned R-1, which requires a 25-foot front
setback and a 5-foot side and rear setbacks with a maximum building height of
25 feet. For comparison, the second floor would require a 30-foot front setback, a
10-foot side setback, and a 25-foot rear setback. The proposed Project provides a
15-foot side setback, 7.5-foot landscape buffer, and a 25-foot building height.
A&EG-3 The next concern expressed by the commenter is the usable windows to the north
side of the proposed structures facing their backyard. The comment adds that based
on discussions at the neighborhood meeting, it is anticipated that usable windows
would not be installed such that would invade their backyard privacy. The comment
asserts that the graphics in the IS/MND do not depict the back side of the proposed
structures, so they cannot confirm lack of such windows. The comment is noted and
will be forwarded to the decision makers. However, lack of graphics showing the
back side of the proposed structures, does not imply that the preferred windows
would not be installed. In fact, the windows on the second story units along the
north side of the property have been modified to a height that will make it
impractical for the future residents in those units to have downward visibility into
the existing adjacent properties.
A&EG-4 The comment expresses concern over the type of trees that would be installed
between the proposed Project and their property casting shade on their solar
panels that are installed on the south facing rooftop of their home. With the growth
of these trees, the natural light onto their property would be impacted.
The designated 7.5-foot tall landscape buffer is intended to be planted with
Podocarpus Gracilior (or similar) and maintained on a regular basis. The purpose
of the buffer is to provide additional privacy. The landscape buffer will not be a
maintenance obligation of the individual unit owner. To keep the landscape buffer
uniform, the plant material will be maintained by the homeowners association for
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the Project and will be kept at a manageable height that will not impact roof-
mounted solar panels.
A&EG-5 The commenters explain the upgrades to their property by installing solar panels
and object to structures that would cast shade on their property or their solar
panels. Please refer to Response A&EG-4, above. No further response is required.
Traffic
A&EG-6 The comment shared concerns regarding local congestion resulted by schools in the
area and identifies specific issues in the local circulations system. The commenters
add that the proposed Project will exacerbate the existing congestion. The comment
is noted and will be forwarded to the decision makers.
It should be recognized that the improvements for the intersections on North Azusa
Avenue are not required for this Project. If the desire is to reach Trawek or Covina
High, a right turn from Puente Avenue onto North Azusa Avenue followed by a left
turn on East Rowland Avenue would likely be more efficient than traveling through
the neighborhood to reach East Rowland Avenue directly. Additional concerns
regarding the Azusa intersections are beyond the scope of this Project and can be
addressed to the City, and no further response is warranted.
Additionally, Section 4.17, Transportation, of the IS/MND includes a detailed
analysis of the potential traffic impacts of the proposed Project. While it is
acknowledged that the Project would generate trips and increase traffic, as
identified in Section 4.17, construction traffic is not likely to create any significant
impact due to the size of the proposed Project. Additionally, during Project
operations, the limited number of Project trips (69) traveling through the Azusa
Avenue/Rowland Avenue intersection is unlikely to result in any impacts to the
operation of the intersection. Thus, potential impacts are considered less than
significant, and no mitigation measures are deemed necessary.
A&EG-7 The comment identifies changing the deep drainage passages on North Azusa
Avenue as a mitigating factor, as they will slow down cars while crossing. Your
comment is noted and will be forwarded to the decision makers. The changes
proposed are beyond the scope of this Project and can be addressed to the City. No
further response is warranted.
A&EG-8 The comment regarding congestion due to the schools in the area is noted and will
be forwarded to the decision makers. It should be recognized that school zones are
generally areas of congestion, particularly in the morning peak period where school
drop offs corresponds with the overall peak travel period of all (non-school) traffic.
Congestion issues around schools are common throughout the City, but school
traffic impacts to peak hour commuter travel are generally limited to a relatively
short period in the AM peak hour (school release times generally do not overlap
with the PM peak commute period). As discussed in Section 4.17, Transportation,
of the IS/MND, in the morning, the Project is expected to add approximately 32
vehicles in the area of Rowland Avenue Elementary, with the remaining 48 vehicles
expected to travel on East Rowland Avenue only between Azusa Avenue and the
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Project site. While the introduction of only a few vehicles to an already-congested
situation can worsen conditions, the number of vehicles being added will be a
relatively small percentage of the existing traffic in the area. As indicated in
Response M&PD-6, above, the limited number of vehicle trips generated by the
proposed Project are unlikely to result in any impacts at roadways and intersections
near the site and in the surrounding area. As such, the analysis does not identify any
mitigation measures, as none is required.
Additional Concerns
A&EG-9 The comment regarding potential light spillover onto the commenters’ property is
noted and will be forwarded to the decision makers. The discussion in Section 4.1,
Aesthetics, of the IS/MND acknowledges that the Project would change lighting
levels; however, it indicates that the lighting would be consistent with the ambient
and night-time lighting at the existing residential uses around the site. To further
avoid potential impact and light trespass onto the surrounding uses, the Walnut
Grove Specific Plan includes provisions to address the potential lighting issues. In
compliance with the Specific Plan, fixtures would have devices to aim light
downward with a minimum 70 percent cut off. Additionally, the City’s Municipal
Code regulates exterior lighting to ensure that sensitive land uses are not affected
by lighting associated with new developments. Section 26-519 of the City’s
Municipal Code requires that “all lighting of the building, landscape, parking area,
or similar facilities shall be hooded and directed to reflect away from adjoining
properties”. This is generally accomplished with shielding and directional lighting
methods, and lighting will specifically focus on streets, parking, and pedestrian
areas. Thus, in light of the provisions in place, the potential impacts pertaining to
light spillover would be less than significant.
A&EG-10 The comment regarding maintain the cul-de-sac is noted. It should be recognized
that the Applicant will modify the cul-de-sac at the south of North Eileen Street to
improve drainage, but it will remain essentially in its current configuration. The cul-
de-sac will not be removed or incorporated into the new community. A solid
perimeter wall will be installed around the cul-de-sac to discourage access and
parking for new residents and guests. There will be a gated access point restricted
to emergency vehicles only.
A&EG-11 The comment regarding holes on the asphalt on Eileen by the survey company is
noted. Following the completion of the drainage improvement at the North Eileen
Street cul-de-sac, as discussed in Response A&EG-10, above, the road will be
repaired to resurface damaged areas associated with the construction effort and the
holes identified by the commenters.
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Letter 5: Miguel Diaz
Comment Letter Dated December 21, 2020
MD-1 The comment identifies the location of the commenter’s home in relation to the
Project and indicates that he has concerns. The comment is noted, and no further
response is required.
Traffic
MD-2 The comment shared concerns regarding local congestion resulted by schools in the
area and identifies specific issues in the local circulations system. The commenters
add that the proposed Project will exacerbate the existing congestion. The comment
is noted and will be forwarded to the decision makers.
It should be recognized that the improvements for the intersections on North Azusa
Avenue are not required for this Project. If the desire is to reach Trawek or Covina
High, a right turn from Puente Avenue onto North Azusa Avenue followed by a left
turn on East Rowland Avenue would likely be more efficient than traveling through
the neighborhood to reach East Rowland Avenue directly. Additional concerns
regarding the Azusa intersections are beyond the scope of this Project and can be
addressed to the City, and no further response is warranted.
Additionally, Section 4.17, Transportation, of the IS/MND includes a detailed
analysis of the potential traffic impacts of the proposed Project. While it is
acknowledged that the Project would generate trips and increase traffic, as
identified in Section 4.17, construction traffic is not likely to create any significant
impact due to the size of the proposed Project. Additionally, during Project
operations, the limited number of Project trips (69) traveling through the Azusa
Avenue/Rowland Avenue intersection is unlikely to result in any impacts to the
operation of the intersection. Thus, potential impacts are considered less than
significant, and no mitigation measures are deemed necessary.
MD-3 The comment identifies changing the deep drainage passages on North Azusa
Avenue as a mitigating factor, as they will slow down cars while crossing. Your
comment is noted and will be forwarded to the decision makers. The changes
proposed are beyond the scope of this Project and can be addressed to the City. No
further response is warranted.
MD-4 The comment regarding congestion due to the schools in the area is noted and will
be forwarded to the decision makers. It should be recognized that school zones are
generally areas of congestion, particularly in the morning peak period where school
drop offs corresponds with the overall peak travel period of all (non-school) traffic.
Congestion issues around schools are common throughout the City, but school
traffic impacts to peak hour commuter travel are generally limited to a relatively
short period in the AM peak hour (school release times generally do not overlap
with the PM peak commute period). As discussed in Section 4.17, Transportation,
of the IS/MND, in the morning, the Project is expected to add approximately 32
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vehicles in the area of Rowland Avenue Elementary, with the remaining 48 vehicles
expected to travel on East Rowland Avenue only between Azusa Avenue and the
Project site. While the introduction of only a few vehicles to an already-congested
situation can worsen conditions, the number of vehicles being added will be a
relatively small percentage of the existing traffic in the area. As indicated in
Response M&PD-6, above, the limited number of vehicle trips generated by the
proposed Project are unlikely to result in any impacts at roadways and intersections
near the site and in the surrounding area. As such, the analysis does not identify any
mitigation measures, as none is required.
Additional Concerns
MD-5 The comment regarding potential light spillover onto the commenters’ property is
noted and will be forwarded to the decision makers. The discussion in Section 4.1,
Aesthetics, of the IS/MND acknowledges that the Project would change lighting
levels; however, it indicates that the lighting would be consistent with the ambient
and night-time lighting at the existing residential uses around the site. To further
avoid potential impact and light trespass onto the surrounding uses, the Walnut
Grove Specific Plan includes provisions to address the potential lighting issues. In
compliance with the Specific Plan, fixtures would have devices to aim light
downward with a minimum 70 percent cut off. Additionally, the City’s Municipal
Code regulates exterior lighting to ensure that sensitive land uses are not affected
by lighting associated with new developments. Section 26-519 of the City’s
Municipal Code requires that “all lighting of the building, landscape, parking area,
or similar facilities shall be hooded and directed to reflect away from adjoining
properties”. This is generally accomplished with shielding and directional lighting
methods, and lighting will specifically focus on streets, parking, and pedestrian
areas. Thus, in light of the provisions in place, the potential impacts pertaining to
light spillover would be less than significant.
MD-6 The comment regarding maintain the cul-de-sac is noted. It should be recognized
that the Applicant will modify the cul-de-sac at the south of North Eileen Street to
improve drainage, but it will remain essentially in its current configuration. The cul-
de-sac will not be removed or incorporated into the new community. A solid
perimeter wall will be installed around the cul-de-sac to discourage access and
parking for new residents and guests. There will be a gated access point restricted
to emergency vehicles only.
MD-7 The comment regarding holes on the asphalt on Eileen by the survey company is
noted. Following the completion of the drainage improvement at the North Eileen
Street cul-de-sac, as discussed in Response MD-6, above, the road will be repaired
to resurface damaged areas associated with the construction effort and the holes
identified by the commenters.
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Letter 6: Fabiola Zelaya Melicher
Comment Letter Dated December 21, 2020
FZM-1 The commenter reiterates the description of the Project and indicates that she has
comments regarding the design and concerns over the concessions requested by
the Project. The comment is noted, and no further response is required.
Section 3.6.1 and 3.6.2 General Plan Use Amendment/Zone Change and Specific Plan
Adoption
FZM-2 The comment regarding the surplus school site and existing zoning is noted and will
be forwarded to the decision makers. However, the IS/MND correctly identifies the
existing designations of the site: General Plan Land Use designation of Civic: Schools
and Zoning designation of Residential Single-Family (R-1). The Project is seeking
approval and adoption of the Walnut Grove Specific Plan and concurrent adoption
of a General Plan Land Use Amendment to allow the “Neighborhood Medium” land
use designation, which permits densities between 9 and 20 dwelling units per acre.
The current R-1 zoning of the site is not consistent with the current General Plan
land use designation, and the General Plan Amendment and accompanying Zone
Change to Specific Plan comprising the Project will eliminate this inconsistency.
It should be noted that the proposed Walnut Grove Specific Plan is established
through the authority granted to the City of West Covina by California Government
Code, Title 7, Division 1, Chapter 3, Article 8, Sections 65450 and 65457 (Specific
Plans). A specific plan is a legislative planning tool and as such serves as the zoning
for the property involved. The Walnut Grove Specific Plan can set the parameters
for the proposed development including distribution, location, extent, and intensity
of land uses. As explained in Section 4.11 of the IS/MND, the Walnut Grove Specific
Plan would be consistent with the General Plan and its relevant goals and objectives,
and the proposed land uses will be consistent with the Zoning as described in the
Specific Plan. The Walnut Grove Specific Plan will be consistent with Section 26-547
of the West Covina Zoning Code, which provides for (S-P) specific plan zones.
4.3 Air Quality
Localized Criteria Pollutants from On-Site Construction
FZM-3 The commenter indicates that the site is over five acres and the LST (Localized
Significance Threshold) method is recommended to projects that are five acres or
less. The commenter is correct that SCAQMD recommends that the LST
methodology should be applied to project sites that are five acres or less. However,
SCAQMD’s “Fact Sheet for Applying CalEEMod to Localized Significance
Thresholds”1 makes clear that the relevant acreage for purposes of applying the LST
1 SCAQMD webpage. Accessed January 14, 2021. http://www.aqmd.gov/docs/default-
source/ceqa/handbook/localized-significance-thresholds/caleemod-
guidance.pdf?sfvrsn=2#:~:text=Fact%20Sheet%20for%20Applying%20CalEEMod%20to%20Localized%20Significa
nce,tables%20based%20on%20site%20acreage%20to%20determine%20the
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methodology is the acreage disturbed by construction activities. The disturbance
area for the Project is calculated to be 4.5 acres based on the equipment anticipated
to be used to develop the site. SCAQMD’s Example 1 is instructive: It describes a 15-
acre development using equipment that could disturb a maximum of 2 acres per
day, so the project should compare CalEEMod reported emissions against the 2-acre
LST lookup tables. Here, because Project-related construction activities would not
exceed the LSTs for 4.5 acres, the Project is not anticipated to result in excessive
exposure of air pollutants to nearby residential uses and no mitigation measures
beyond regulatory requirements are necessary. Regulatory requirements include
dust control measures established under SCAQMD Rule 403 as well as limiting
unnecessary idling of off-road diesel vehicles to five minutes or less, emission
performance compliance options or adoption of Best Available Control Technology
for fleet owners, bans on adding older dirtier (Tier 0, Tier 1, Tier 2) vehicles to large
and medium sized fleets, and labeling and registration of their equipment to the
California Air Resources Board through the DOORS (Diesel Off-road Online Report
System) program for fleets.
The commenter has also requested information on phasing of construction
activities. Section 3.5 Construction Activities of the Project Description of the
IS/MND provides construction information for the Project. All construction staging
would occur within the Project site boundaries. Further construction details are
provided in Section 3.0, Construction Detail, of the IS/MND.
Carbon Monoxide Hotspot
FZM-4 The commenter indicates that Vehicle Miles Traveled (VMT) should be used to
assess Carbon Monoxide (CO) hotspots instead of hourly traffic volumes. As
explained in the IS/MND, potential impacts associated with CO emissions are
appropriately evaluated by analyzing congested intersections, consistent with
California Department of Transportation, Transportation Project‐Level Carbon
Monoxide Protocol, Revised December 1997. The magnitude of hourly traffic
volumes, rates of CO emissions, and level of service at intersections are the primary
factors that affect CO concentrations at intersections. VMT is used to determine
Project-related air pollutant emissions emitted into the region as described and not
for local concentrations of CO. The CO hotspot analysis was evaluated properly and
found to not result in a significant air quality impact because the volume of traffic
was insufficient to result in a CO hotspot, as defined by the State of California and
National Ambient Air Quality Standards.
Regulatory Requirements
FZM-5 The commenter requests additional information on SCAQMD’s Rule 402 and 403.
SCAQMD Rule 403 is 23 pages long, and its incorporation would result in an
excessive level of detail for an IS/MND. A summary of the most common dust
suppression measures is described below.
SCAQMD Rule 403, Fugitive Dust, focuses on controlling fugitive dust and avoiding
nuisance. Compliance with this rule will reduce short-term particulate pollutant
emissions. Contractor compliance with Rule 403 requirements will be mandated in
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the contractor’s specifications. Some of the potential rules may include, but not be
limited to:
Non-toxic soil stabilizers/dust suppressants that create a crust on the
surface to be resistant to wind erosion would be selected and applied
consistent with Rule 403.
Traffic speeds on unpaved roads would be restricted to no more than 15
miles per hour.
One or more devices would be installed at ingress/egress points to remove
dirt from vehicle tires and undercarriage prior to leaving the site.
All materials to be loaded for export would be pre-watered.
All haul trucks would either be covered (with on board tarp) or would
maintain at least six inches of freeboard between the top of the soil and the
edge of the truck bed.
For inactive disturbed surface areas, apply water to at least 80 percent of all
inactive disturbed surface areas on a daily basis when there is evidence of
wind driven fugitive dust or establish a vegetative ground cover within 21
days after active operations have ceased.
The full SCAQMD requirements for Rule 403 can be found at
http://www.aqmd.gov/home/rules-compliance/compliance/rule-403-dust-
control-
information#:~:text=Rule%20403%20requires%20the%20implementation%20o
f%20best%20available,the%20South%20Coast%20AQMD%20by%20submitting
%20specific%20forms.
SCAQMD Rule 402 is reproduced below and can be found at
http://www.aqmd.gov/docs/default-source/rule-book/rule-iv/rule-402.pdf.
“A person shall not discharge from any source whatsoever such quantities of air
contaminants or other material which cause injury, detriment, nuisance, or
annoyance to any considerable number of persons or to the public, or which
endanger the comfort, repose, health or safety of any such persons or the public, or
which cause, or have a natural tendency to cause, injury or damage to business or
property. The provisions of this rule shall not apply to odors emanating from
agricultural operations necessary for the growing of crops or the raising of fowl or
animals.”
Additionally, the commenter requests that information for a contact person be
provided for future complaints regarding air quality, noise, and other concerns.
Comment is noted; Rule 403 requires contact signage for large operations. A large
operation is defined as one with 50 or more acres of disturbed surface area or a
daily earth-moving throughput of 5,000 cubic yards (cy) or more three times in a
year. The Project involves approximately 9,740 cy of import, with 86,150 cy of cut,
and 95,900 cy of fill over the construction duration. The grading duration is one
month, which results in 4,359 cy/day of earth movement on average. Nevertheless,
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the Applicant will provide contract information at a sign that will be posted at the
Project site.
4.10 Hydrology and Water Quality
FZM-6 The comment expresses concern over the Project’s lot coverage of 80 percent in
comparison to the existing school and underlying zoning of single-family
residential. The commenter further asserts that lot coverage should be decreased,
and landscaping increased in light of heat island effect.
It should be recognized that the Walnut Grove Specific Plan is a planning tool that
is established through the authority granted to the City of West Covina by California
Government Code, Title 7, Division 1, Chapter 3, Article 8, Sections 65450 and
65457 (Specific Plans). As such, the Walnut Grove Specific Plan can set the
parameters for the proposed development, including distribution, location, extent,
intensity of land uses, building setbacks, building height, lot coverage, and
landscape requirements. See response to comment FZM-2 above regarding the
Project’s consistency with the General Plan and Zoning Code. The purpose of the
Specific Plan is to establish guidelines and standards specific to that Project, and the
IS/MND accurately disclosed and analyzes the potential environmental impacts
associated with the Project, including the updated zoning designations associated
with the Specific Plan.
Regarding the heat island effect, it is acknowledged that hard, dry surfaces such as
roofs, sidewalks, roads, buildings, and parking lots provide less shade and moisture
than natural landscapes and therefore contribute to higher temperatures. However,
it should also be noted that heat island effect occurs as a result of several factors
(e.g., urban materials properties, urban geometry, human activity, weather and
geology, and more) and not just lack of higher percentage of landscaping (EPA
2021). Additionally, the Project is too small in the context of an urban metropolitan
area that is the main generator of heat island effect. The Project site is currently
developed, and more than half of the site is asphalt and includes structures, and
other development in the area are of similar characteristics. Thus, the Project in and
of itself would not significantly contribute to heat island effect in the area.
4.13 Noise
FZM-7 The commenter requests information on phasing of construction activities. Please
note, Section 3.5, Construction Activities, of the IS/MND provides construction
information for the proposed Project. See response to comment FZM-3 above
regarding construction phasing details.
The commenter also requests incorporation of additional mitigation measures for
Noise. The comment is noted; however, it should be recognized that based on the
detailed analysis in Section 4.13, Noise, of the IS/MND, the Project has implemented
all necessary mitigation measures to reduce Project related construction noise
impacts. The Project will comply with all applicable noise control regulations, and
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additional mitigation measures are not required since the Project will result in less
than significant noise impacts.
4.15 Public Services
FZM-8 The comment states that the IS/MND incorrectly identified the Project being within
the jurisdiction of the West Covina Unified School District (WCUSD), and that the
Project is within the Covina-Valley Unified School District (C-VUSD). The comment
is noted, and the IS/MND will be revised for clarification. These revisions do not
require recirculation of the IS/MND under CEQA Guidelines Section 15073.5(c)(4).
The following revision is hereby made to the text of the IS/MND under iii) Schools,
on pages 4-90 and 4-91 and under Regulatory Requirements on page 4-92 of
Section 4.15, Public Services, of the IS/MND (deleted text is shown in red
strikethrough while new text is shown in red italics):
iii) Schools?
Less than Significant Impact. The proposed Project involves the
development of 158 dwelling units that would be occupied by approximately
529 residents with potential school-aged children requiring school services
from the West Covina Covina‐Valley Unified School District (WCUSD) (C‐
VUSD). The WCUSD C‐VUSD serves 12,500 students2in eight elementary schools,
three middle schools, and four high schools (C‐VUSD 2021). serves over 14,000
students in 15 public elementary and high schools and two charter schools
within the City. Students within the WCUSD may choose to attend any school
within the boundaries (WCUSD 2020). According to student generation rates
for residential land uses within the WCUSD C‐VUSD, the Project may generate
28 elementary school students, 15 middle school students, and 24 high school
students, for a total of 66 students (City of West Covina 2016b).
The Project would pay school development fees to the WCUSD C‐VUSD for the
improvement of school facilities that would be needed to serve the Project’s
demand for school services and facilities (see RR PS-3). As provided under
Section 17620 of the California Education Code and Section 65970 of the
California Government Code, the payment of statutory school development
fees would fully mitigate a project’s impacts on schools. Thus, impacts would
be less than significant, and no mitigation is required.
The Project would pay school development fees to the WCUSD C‐VUSD for the
improvement of school facilities that would be needed to serve the Project’s
demand for school services and facilities (see RR PS-3). As provided under
Section 17620 of the California Education Code and Section 65970 of the
California Government Code, the payment of statutory school development
2 Based on 2013‐2014 student enrollment at C‐VUSD, last available data from California Department of Education
Educational Demographics Unit:
https://dq.cde.ca.gov/dataquest/Enrollment/EthnicEnr.aspx?cChoice=CoEnrEth2&cYear=2013‐
14&TheCounty=19,Los%20Angeles&cLevel=County&cTopic=Enrollment&myTimeFrame=S&cType=ALL&cGender=B
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fees would fully mitigate a project’s impacts on schools. Thus, impacts would
be less than significant, and no mitigation is required.
Regulatory Requirements
RR PS‐3 The Project Applicant shall pay the applicable school development
fee to the West Covina Covina‐Valley Unified School District, in
accordance with Section 17620 of the California Education Code.
References
Covina‐Valley Unified School District (C‐VUSD). 2021 (January 22, last accessed).
Covina‐Valley Unified School District School Directory. Covina, CA: C‐UVSD.
https://www.c‐
vusd.org//site/default.aspx?PageType=2&PageModuleInstanceID=105&ViewID=5
e297a0a‐8ad3‐4901‐bc02‐5599a28a44e5&RenderLoc=0&FlexDataID=0.
The comment asserts that the Project does not provide adequate parkland, and that
the Project should be redesigned to provide additional open space. As indicated in
Section 4.16, Recreation, of the IS/MND document, Project provides an on-site
common open space area at the center of the development that would include a
variety of open space amenities. Additionally, the boundary to the south would
include trees and a parkway along East Rowland Avenue. The Walnut Grove Specific
Plan requires 100 sf of common useable open space per unit (including paseos and
recreational centers) and 150 sf of private open space per unit for single family
units and 100 sf of common useable open space per unit and 100 sf of private open
space per unit for multi-family units. The Project’s demand for parks will be met in
part onsite and in part by payment of park fees for the development of new or
expanded park facilities in the City. This is a standard practice for all new
developments in West Covina and elsewhere. Therefore, in light of provision of
onsite park and open space and payment of park fees, the Project meets its parkland
requirements, and it does not need to be redesigned to provide more open space.
4.17 Transportation
FZM-9 The commenter provides a discussion of VMT and points out that “a Vehicle Miles
Traveled (VMT) analysis is required by State law effective July 1, 2020” and asserts
that the analysis in the IS/MND does not provide evidence to support the conclusion
that the Project is exempt from VMT analysis. Specifically, the commenter asserts
that the Project’s approach of providing surplus guest parking is contrary to the
OPR Guidance for screening out projects from VMT analysis.
The discussion in Section 4.17, Transportation, of the IS/MND accurately describes
SB 743 and states the following:
“State CEQA Guidelines Section 15064.3, subdivision (b) provides the
criteria for analyzing transportation impacts, and a project’s effect on
automobile delay shall not constitute a significant environmental impact.
Generally, vehicle miles traveled is the most appropriate measure of
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transportation impacts. Vehicle miles traveled (VMT) refers to the amount
and distance of automobile travel attributable to a project. According to the
State of California’s Technical Advisory on Evaluating Transportation Impacts
in CEQA, “certain projects (including residential, retail, and office projects,
as well as projects that are a mix of these uses) proposed within ½ mile of
an existing major transit stop or an existing stop along a high quality transit
corridor would have a less than significant impact on VMT” (OPR 2018). The
City of West Covina recently adopted the use of Vehicle Miles Traveled
(VMT) analysis methodology for evaluating potential traffic impacts for
development projects. The Project is located within a Transit Priority Area
(TPA) and is exempt from a full VMT analysis by the City. Although there
have been some changes to transit service due to the COVID-19 pandemic, it
was confirmed that the Foothill Transit bus lines in the Project area are still
operating as usual. Therefore, the TPA exemption is still valid.
The Project is located less than ¼ mile from two major transit stops (Foothill
Transit bus lines 280 and 488) and is therefore in a Transit Priority Area (TPA).
City guidelines, consistent with the OPR Guidance, state that the presumption that
a project located within a TPA will have less-than-significant VMT impacts “might
not be appropriate if the project includes more parking for use by residents,
customers, or employees of the project than required by the City.” (emphasis
added). While the guest parking spaces provided exceed the typical City zoning
requirement, the additional parking is not expected to be used on a daily basis.
Further, the additional guest parking spaces are not expected to generate additional
trips or increase the VMT per capita for the Project. It should be noted that there is
limited parking in the area surrounding the proposed Project site. Neighbors in
those areas have already expressed their concerns about overflow and visitor
parking on their streets. In response to this concern, the Applicant modified the site
plan to include a solid wall, without gate or access, around the perimeter of the cul-
de-sac on North Eileen Street to prevent/discourage the future Project residents or
their guests from using the adjacent neighborhood for parking and external access
to their units. In light of this condition and to address the existing neighbors’
concerns, the Applicant provided additional guest parking spaces. Additionally, the
Applicant will add a provision in the governing documents for the Homeowners’
Association that will apply within the Project that will require residents to utilize
their garages for parking, reserving street parking and guest parking spaces for
guests only. Owner vehicles in the guest spaces would be subject to violation. This
will ensure that residents do not own more than two vehicles and will promote the
use of public transit and ensure the guest parking spaces do not result in an increase
in VMT.
Per City guidelines and direction, providing additional guest parking spaces is not
grounds for dismissing the TPA screening exemption for the proposed Project.
Therefore, the IS/MND will not require recirculation due to this point. The comment
incorrectly cites CEQA Guidelines Section 15088.5, which provides the
requirements for recirculation of an Environmental Impact Report (EIR), not an
MND. The criteria for recirculation of an MND are provided in CEQA Guidelines
Section 15073.5, and none of those criteria is triggered here.
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Preliminary Design and Layout Concerns
FZM-10 The comments pertaining to design and layout of the Project and its components
are noted and will be forwarded to the decision makers. Upon submittal of the
Project application and plans, the Applicant received comments from the City and
addressed them prior to resubmittal. At this time, the design and layout of the
Project are in accordance with the provisions of the Walnut Grove Specific Plan and
in addition to the City requirements. As such no modifications to the design and
layout of the Project are required nor anticipated. Most of these comments relate to
the commenter’s opinions on design features the Project, not its environmental
impacts. The purpose of the IS/MND is to evaluate the physical environmental
effects of a project, not to defend or criticize the project itself. Regarding noise
attenuation, see Response FZM-7, above. The comment cites several provisions of
the City’s Zoning Code, which do not apply to the Project since it will be governed
by the Walnut Grove Specific Plan, as explained above in Response FZM-2.
Concessions Requested
FZM-11 The commenter incorrectly asserts that the Project Applicant has requested a
number of concessions for the Project and in return has not offered any community
benefits. The commenter incorrectly cites the state Density Bonus Law (Cal. Gov.
Code 69515-69518), which is not relevant to the Project. The Applicant has not
applied for Project benefits or concessions under the provisions of the Density
Bonus Law. As explained above in Response FZM-2, the Walnut Grove Specific Plan
is a planning tool that is established through the authority granted to the City of
West Covina by California Government Code, Title 7, Division 1, Chapter 3, Article
8, Sections 65450 and 65457 (Specific Plans). As such, the Walnut Grove Specific
Plan can set the parameters for the proposed development, including distribution,
location, extent, intensity of land uses, building setbacks, building height, lot
coverage, and landscape requirements. The purpose of the Specific Plan is to
establish guidelines and standards specific to that Project. These are not considered
“concessions” and none has been requested by the Applicant. Thus, what is listed by
the commenter is not a list of concessions but rather provisions of the Specific Plan
to implement the proposed development. These provisions would achieve the
vision of the Project and are consistent with the provisions of the Government Code
governing Specific Plans cited above. Accordingly, the Project is not required to
provide community benefits.
FZM-12 The comment regarding lack of affordable units to justify the concession and that
the Project should include affordable units is noted and will be forwarded to the
decision makers. As discussed in Response FZM-13, above, the Applicant has not
requested any concessions, nor is the Project required to provide a certain number
of affordable housing units as mitigation.
FZM-13 The commenter requests additional community outreach and being notified of
future meetings. The comment is noted and will be forwarded to the decision
makers. However, it should be recognized that the Project has met all applicable
noticing requirements in accordance with CEQA and the West Covina Municipal
Code. The surrounding property owners within 300 feet of the Project limits were
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notified of the 30-day public review of the IS/MND, and a notice was also published
in the San Gabriel Valley Tribune and the City’s website regarding the availability of
the IS/MND for review. Therefore, City met the requirements to encourage public
participation.
Additionally, the Applicant organized a community meeting with the surrounding
property owners on August 15, 2020. Thus, in light of the noticing discussed above,
the community meeting in August, and regular discussions with the surrounding
residents, the Applicant is not required to organize additional community meetings.
FZM-14 The comment regarding availability of a full set of plans on the City’s website for
public to review is noted and will be forwarded to the decision makers.
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Letter 7: Mr. and Mrs. Santos
Comment Letter Dated December 21, 2020
SAN-1 The comment discusses the location of the commenters’ home and expresses their
opinion that the Project would result in many negative impacts that would affect
the quality of life and living conditions. The comment is noted and will be forwarded
to the decision makers. It should be noted that the IS/MND document included
detailed analyses of all topical issues supported by substantial evidence and
justifications and provided mitigation measures for potential significant impacts
that were identified to reduce them to less than significant levels. Additionally,
please note that the “quality of life” is not a required CEQA topic, and as such no
further response is required.
SAN-2 The commenter asserts that the Project will result in increased population. The
comment is acknowledged, and as identified in Section 4.14, Population and
Housing, and elsewhere in the IS/MND document, the 158 proposed dwelling units
would generate approximately 529 residents. However, this is a minimal increase
equating to 0.5 percent of the existing City population. Additionally, it should be
recognized that this increase is within the anticipated growth projection for the
City. Therefore, the Project would not result in direct unplanned population growth
that was not previously anticipated.
SAN-3 The comment expresses concern for parking and new traffic in the area. The
comment is noted and will be forwarded to the decision makers. As indicated in
Section 3.2, Project Access/Parking, of the IS/MND, in accordance with the
provisions of the Walnut Grove Specific Plan, the proposed Project is required to
provide a total of 316 parking spaces for residents and 79 spaces for guests. The
Project would meet and exceed this requirement by providing 20 surplus guest
parking spaces. The commenter’s opinion regarding most homes having at least
three cars is noted; however, the Project is not required to provide parking in excess
of requirements or based on hypothetical scenarios.
Regarding new traffic in the area, we concur that the Project would generate new
traffic; however, the increase in traffic is not quantified based the number of cars in
each household but rather based on the type of development that is proposed, in
this case single- and multi-family residential. Thus, traffic trips commensurate with
the type of residential development. The single-family detached units would
generate 9.44 daily trips per day, and the multi-family units would generate 5.44
daily trips per unit. These generation rates have been derived from the Institute of
Transportation Engineers’ (ITE’s) Trip Generation Manual, 10th Edition, as
discussed in Section 4.17, Transportation, of the IS/MND. Using these rates, the
proposed Project’s daily trip generation is calculated.
SAN-4 The comment regarding traffic incidents on East Roland Avenue is noted and will
be forwarded to the decisions makers. However, the comment does not provide any
evidence to support the statement regarding these traffic incidents, and the Project
traffic increasing these incidents is the opinion of the commenter.
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Additionally, as discussed in detail in Section 4.17, Transportation, of the IS/MND,
the limited number of vehicle trips generated by the proposed Project would not
cause significant impacts at roadways and intersections near the site and in the
surrounding area. As part of the Project, it is anticipated that the median on East
Rowland Avenue would be reconstructed to provide full access at the west
driveway of the Project, as the existing median opening is slightly east of the
proposed west driveway location. The median reconstruction would also include a
left-turn cutout to allow left turns directly into the Project site. The implementation
of the said planned improvements in compliance with City standards would not
result in impacts from hazards due to a geometric design feature. Thus, Project
traffic would not interfere with access, circulation, or activities at the surrounding
land uses.
SAN-5 The comment suggests analysis of aesthetics, utilities, population and housing,
transportation, air quality, and energy. We believe the commenter is referring to
the checklist on page 4-1 of the IS/MND. The boxes that are checked in this three-
column checklist represent the topics with potential impact that require mitigation
measures. The checklist does not mean that the topics with boxes not checked do
not include analysis. In accordance with CEQA requirements for preparation of an
IS/MND, all topics require full analyses. Please refer to Sections 4.1, Aesthetics; 4.3,
Air Quality; 4.6, Energy; 4.14, Population and Housing; 4.17, Transportation; and
4.19, Utilities and Service Systems, of the IS/MND for detailed discussion and
analysis of the identified topics. No further response is required.
SAN-6 The comment regarding the checklist question (a) in Section 4.1, Aesthetics, of the
IS/MND is not clear. We understand the commenter does not agree with the
conclusion and asks for additional research. However, the comment does not
elaborate on the particular aspect of the discussion that the commenter disagrees
with. The analysis under this checklist question has been fully discussed and
analyzed in the context of the “Our Natural Community” Element of the City’s
General Plan and the existing and future conditions of the area, which is a fully built
and urban portion of the City. Thus, the discussion is a full qualitative analysis of
the checklist question in accordance with the CEQA guidance. No further response
is required.
SAN-7 The comment objects to the description of View 1 in Section 4.1, Aesthetics, of the
IS/MND. It should be noted that this and other views depicted in the section are just
snapshots of where the photographer was standing, and they are not
representations of what is experienced or seen walking, driving, or living in the
area. This comment expresses the opinion of the commenter, and no further
response is required.
SAN-8 The comment regarding the Project being a breach of Policy 19 (correction, the
referenced policy is 1.9 and not 19) of “Our Natural Community” Element of the
General Plan is an opinion of the commenter, and no further response is required.
However, it should be noted that Section 4.1, Aesthetics of the IS/MND included
analysis of views of the Los Angeles National Forest and San Gabriel Mountains from
public areas surrounding the Project site. The analysis identified that no
obstruction of natural areas would occur with implementation of the Project.
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SAN-9 The commenter’s appreciation for the improvements in the City is noted and will
be forwarded to the decision makers. The comment also repeats the potential
impact pertaining to parking and traffic. Please refer to Responses SAN-3 and
SAN-4, above. No further response is required.
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Letter 8: Ward and Phyllis Wenner
Comment Letter Dated December 21, 2020
W&PW-1 This comment email was sent by Teresa Cozad on behalf of Ward and Phyllis
Wenner. The comment provides the location of the commenters’ residence and
identifies the issues of concern to Wenners.
The first concern is a drainage ditch that has caused runoff and flooding at Pioneer
and Leaf and flooding of sidewalk later at East Rowland Avenue during heavy rains.
The comment also asks if the development has addressed this issue. The comment
is noted and will be forwarded to the decision makers. The channel that extends
across the northwest and western boundary of the site currently accepts offsite
drainage from the commercial center north of the Project. With implementation of
the proposed Project, the current flows from offsite will be intercepted at the
northern cul-de-sac (North Eileen Street) and re-routed through the Project site
through an underground drainage system.
However, it should be recognized that the drainage ditch is part of the existing
condition and is not relevant to the development of the proposed Project. The
Project has not created the condition and as such, the Project Applicant is not
responsible for addressing the issue. Resolving the drainage ditch issue is outside
the scope of the Project.
Regarding the second concern for availability of park and green areas within the
Project site, as indicated in Section 4.16, Recreation, of the IS/MND document,
Project provides an on-site common open space area at the center of the
development that would include a variety of open space amenities. Additionally, the
boundary to the south would include trees and a parkway along East Rowland
Avenue. The Walnut Grove Specific Plan requires 100 sf of common useable open
space per unit (including paseos and recreational centers) and 150 sf of private
open space per unit for single family units and 100 sf of common useable open space
per unit and 100 sf of private open space per unit for multi-family units. The
Project’s demand for parks will be partially met onsite and by payment of park fees
for the development of new or expanded park facilities in the City. This is a standard
practice for all new developments in West Covina and elsewhere. Regarding
provision of a pet area, the comment is noted and will be forwarded to the decision
makers. While the Project is required to provide open space and pay for park fees,
it is not required to provide for a pet area within the development.
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REVISIONS AS PART OF THE FINAL IS/MND
Revisions have been made to the Draft IS/MND based on input received during the public review
period and while preparing the responses to comments on the Draft IS/MND. The revisions
requested do not reflect a substantial change to the Project description, nor would any of the
changes result in a new impact or intensification of an impact already identified in the Draft
IS/MND. The changes are not in response to comments that raise significant environmental
issues. Additions to the Draft IS/MND are shown in red italicized text and deletions are shown in
red strikethrough text.
REVISIONS TO THE DRAFT IS/MND
4.1.1 SECTION 3.0, PROJECT DESCRIPTION
While features such as internal paseos and walkways are included in the Project to accommodate
pedestrians, in light of the commenter’s comments and to accommodate use of bikes, the text of
the IS/MND and the associated exhibit (Exhibit 3-6, Conceptual Park Enlargement Plan) will be
revised to incorporate bike racks on-site for use by future residents of the Project and their
guests. The bike racks will be provided in two location adjacent to the mailboxes around the
perimeter of the park. These revisions do not require recirculation of the IS/MND under CEQA
Guidelines Section 15073.5(c)(4). The following addition is hereby made to the text of the
IS/MND under Section 3.1, Residential Land Use, on page 3-2 of the IS/MND (new text is shown
in red italics):
A common open space area would be provided on-site at one central location at
the Project site, and private open spaces would be available for each single-family
unit. The Project would have 100 sf of common open space per unit (including
walking paseos and the neighborhood park use). The single-family units would
have a minimum of 150 sf of private open space per unit, and the multi-family
units would have a minimum of 100 sf of private open space per unit. The common
open space area of the Project would consist of 0.27 acre of neighborhood park
use, hereinafter referred to as the (“Community Open Space Area”). The
Community Open Space Area would have a private park that is publicly accessible
for use. Open space amenities would include bench seating areas and trash
receptacles; picnic areas; children’s tot-lot area; open turf area; connecting
walkways; and mailboxes. Additionally, to accommodate use of bikes by future
residents and their guests, bike racks will be provided at two locations adjacent to
mail boxes and wood arbor trellis entries, around the perimeter of the proposed
park.
The above modification will also be reflected in Exhibit 3-6, Conceptual Park Enlargement Plan.
The exhibit is hereby modified to incorporate the proposed bike racks. The updated exhibit is
included in the following page.
Map not to scale(02/02/2021 MMD) R:\Projects\LEW\3LEW001200\Graphics\MND\ex_ConceptualParkEnlargmentPlan.pdfD:\Projects\LewisOp\3LEW001200\GRAPHICS\MND\ex_ConceptualParkEnlargementPlan.aiWalnut Grove Residential ProjectConceptual Park Enlargement Plan Exhibit 3-6Source: Lewis Group Of Companies, April 2020
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4.1.2 SECTION 4.15, PUBLIC SERVICES
In response to comments on the Draft IS/MND, there are a number of revisions pertaining to the
applicable school district. These revisions are included under the appropriate sections below.
The comment is addressed, and the following revision is hereby made to the text under iii)
Schools, on pages 4-90 and 4-91 and under Regulatory Requirements on page 4-92 of
Section 4.15, Public Services, of the IS/MND (deleted text is shown in red strikethrough while
new text is shown in red italics):
iii) Schools?
Less than Significant Impact. The proposed Project involves the development of
158 dwelling units that would be occupied by approximately 529 residents with
potential school-aged children requiring school services from the West Covina
Covina‐Valley Unified School District (WCUSD) (C‐VUSD). The WCUSD C‐VUSD
serves 12,500 students3in eight elementary schools, three middle schools, and four
high schools (C‐VUSD 2021). serves over 14,000 students in 15 public elementary
and high schools and two charter schools within the City. Students within the
WCUSD may choose to attend any school within the boundaries (WCUSD 2020).
According to student generation rates for residential land uses within the WCUSD
C‐VUSD, the Project may generate 28 elementary school students, 15 middle
school students, and 24 high school students, for a total of 66 students (City of
West Covina 2016b).
The Project would pay school development fees to the WCUSD C‐VUSD for the
improvement of school facilities that would be needed to serve the Project’s
demand for school services and facilities (see RR PS-3). As provided under Section
17620 of the California Education Code and Section 65970 of the California
Government Code, the payment of statutory school development fees would fully
mitigate a project’s impacts on schools. Thus, impacts would be less than
significant, and no mitigation is required.
The Project would pay school development fees to the WCUSD C‐VUSD for the
improvement of school facilities that would be needed to serve the Project’s
demand for school services and facilities (see RR PS-3). As provided under Section
17620 of the California Education Code and Section 65970 of the California
Government Code, the payment of statutory school development fees would fully
mitigate a project’s impacts on schools. Thus, impacts would be less than
significant, and no mitigation is required.
3 Based on 2013‐2014 student enrollment at C‐VUSD, last available data from California Department of Education
Educational Demographics Unit:
https://dq.cde.ca.gov/dataquest/Enrollment/EthnicEnr.aspx?cChoice=CoEnrEth2&cYear=2013‐
14&TheCounty=19,Los%20Angeles&cLevel=County&cTopic=Enrollment&myTimeFrame=S&cType=ALL&cGender=B
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Regulatory Requirements
RR PS‐3 The Project Applicant shall pay the applicable school development
fee to the West Covina Covina‐Valley Unified School District, in
accordance with Section 17620 of the California Education Code.
References
Covina‐Valley Unified School District (C‐VUSD). 2021 (January 22, last accessed).
Covina‐Valley Unified School District School Directory. Covina, CA: C‐UVSD.
https://www.c‐
vusd.org//site/default.aspx?PageType=2&PageModuleInstanceID=105&ViewID=5
e297a0a‐8ad3‐4901‐bc02‐5599a28a44e5&RenderLoc=0&FlexDataID=0.
WALNUT GROVE RESIDENTIAL PROJECT 5-1
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REFERENCES
Covina-Valley Unified School District (C-VUSD). 2021 (January 22, last accessed). Covina-Valley
Unified School District School Directory. Covina, CA: C-UVSD. https://www.c-
vusd.org//site/default.aspx?PageType=2&PageModuleInstanceID=105&ViewID=5e297
a0a-8ad3-4901-bc02-5599a28a44e5&RenderLoc=0&FlexDataID=0.
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Mark and Susan Paredes
Comment Letter Dated December 20, 2020
M&SP-1 The comment regarding reissuing the letters from August 2020 is noted and will be
forwarded to the decision makers. The commenter expresses their living
environment and indicates that their neighbors also have concerns, and they all
hope to resolve the issues. Comment is noted, no further response is required.
M&SP-2 The commenter notes that she talked to Mr. Adam Collier on August 6, 2020
regarding a series of concerns. The first comment identifies concerns for the cul-de-
sac and states that the whole circle belongs to the neighborhood. The comment is
noted and will be forwarded to the decision makers.
It should be recognized that the Applicant will modify the cul-de-sac at the south of
North Eileen Street to improve drainage, but it will remain essentially in its current
configuration. The cul-de-sac will not be removed or incorporated into the new
community. A solid perimeter wall will be installed around the cul-de-sac to
discourage access and parking for new residents and guests. A solid perimeter wall
will be installed around the cul-de-sac to discourage access and parking for new
residents and guests. There will be a gated access point restricted to emergency
vehicles only.
M&SP-3 The comment regarding the drainage system to be redone is noted and will be
forwarded to the decision makers. The channel that extends across the northwest
and western boundary of the site currently accepts offsite drainage from the
commercial center north of the Project. With implementation of the proposed
Project, the current flows from offsite will be intercepted at the northern cul-de-sac
(North Eileen Street) and re-routed through the Project site through an
underground drainage system. Following completion of the drainage
improvements at the North Eileen Street cul-de-sac, the road will be repaired to
resurface damaged areas associated with the construction effort.
M&SP-4 The comment regarding the windows facing existing homes and retaining the
privacy of neighbors is noted and will be forwarded to the decision makers. The
windows on the second story units along the north side of the property have been
modified to a height that will make it impractical for the future residents in those
units to have downward visibility into the existing adjacent properties. As such the
privacy of existing homes are respected and protected.
Regarding the landscaping, the designated 7.5-foot tall landscape buffer is intended
to be planted with Podocarpus Gracilior (or similar) and maintained on a regular
basis. The purpose of the buffer is to provide additional privacy. The landscape
buffer will not be a maintenance obligation of the individual unit owner. To keep
the landscape buffer uniform, the plant material will be maintained by the
homeowners association for the Project and will be kept at a manageable height
that will not impact roof-mounted solar panels for the homes that have solar panels.
M&SP-5 The comment regarding replacing the old fence with a new wall is noted and will be
forwarded to the decision makers. The comment indicates that the Applicant will
build a wall so a dead space would not result between the old fence and the new
block wall. The Applicant is currently working with some homeowners on replacing
10
the existing fence/wall, where appropriate. In some cases, the existing wall of the
homeowner will remain in place. In other cases, the existing fence/wall will be
replaced or modified. Every effort will be made to avoid or minimize a double wall
condition; however, it will require cooperation from the adjacent owners.
M&SP-6 The comment describes the types of units and parking that will be developed as part
of the Project, and that the townhouses will be for-sale units. Just to supplement the
description, the Project would involve construction of a 158-unit attached and
detached residential development, which would consist of two different types of
residences, including 66 units of detached single-family in a cluster configuration
and 92 attached multi-family units. the Project would include 2 covered garage
parking spaces per dwelling unit (for a total of 316 indoor garage spaces) and 99
uncovered guest surface parking spaces throughout the Project site.
M&SP-7 The comment regarding the location of the three-story homes within the
development is noted. As the commenter indicates the three-story attached units
will be located along the eastern portion of the site. Regarding windows
overlooking the existing homes, please refer to Response M&SP-4, above.
M&SP-8 The comment regarding increased traffic associated with the 158 units is noted.
Section 4.17, Transportation, of the IS/MND includes a detailed analysis of the
potential traffic impacts of the proposed Project. While it is acknowledged that the
Project would generate trips and increase traffic, construction traffic is not likely to
create any significant impact due to the size of the proposed Project. Additionally,
during Project operations, as indicated in Section 4.17, the proposed Project’s daily
trip generation of 1,124 trips per day, with approximately 82 AM peak hour trips
and 106 PM peak hour trips is unlikely to result in any impacts at roadways and
intersections near the site and in the surrounding area. The number of vehicles
being added will be a relatively small percentage of the existing traffic in the area.
As such, the analysis does not identify any mitigation measures, as none is required.
M&SP-9 The comment regarding the Project being processed through the City of West
Covina and staying in touch with update is noted and will be forwarded to the
decision makers. No further response is required.
M&SP-10 The commenter expresses the importance of the cul-de-sac to them and the
community. The comment is noted. Please refer to Response M&SP-2, above, for
more detail on the cul-de-sac.
M&SP-11 The comment expresses concern regarding the proposed wall and inquires about
the height of the wall and distance from the existing homes. The comment further
asks about a potential dead space that could result and issues associated with
critters and the maintenance of such space. Please also refer to Response M&SP-5,
above for additional discussion.
M&SP-12 The commenter questions the water runoff from neighboring commercial
properties that ultimately empties out onto Rowland Avenue. Please refer to
Response M&SP-3, above, regarding this issue.
The comment regarding maintenance of the gutters is noted and will be forwarded
to the decision makers. This comment is beyond the scope of the proposed Project.
No further response is required. However, it should be noted that the existing runoff
from the neighboring commercial property to the north of the proposed Project
11
currently drains into a catch basin, which ultimately outlets above ground into a
channel and swale along the north and west edge of the Project site. The proposed
Project will intercept the runoff at the North Eileen Street cul-de-sac and transfer
the flow through the site where it will be managed through the storm drain system.
M&SP-13 The commenter questions the types of units proposed. The comment is noted.
Information regarding the units and their numbers is detailed in Section 3.0, Project
Description, of the IS/MND. For a summary of number and type of units proposed,
please refer to Response M&SP-6, above.
M&SP-14 The comment expresses concern regarding potential invasion of the privacy of
existing homes. Comment is noted and will be forwarded to the decision makers.
For a discussion of this issue, please refer to Response M&SP-4, above.
M&SP-15 The comment regarding less units and the issues of parking and traffic associated
with the proposed 158-unit development is noted and will be forwarded to the
decision makers. The commenter makes an assumption that each unit will have two
adults with each adult owning a car. Based on this assumption, the commenter
erroneously states that there will be a total of 632 cars, while based on the stated
assumption there will be a total of 316 cars. However, it should be recognized that
the increase in traffic is not quantified based the number of cars in each household
but rather based on the type of development that is proposed, in this case single-
and multi-family residential. Thus, traffic trips commensurate with the type of
residential development. The single-family detached units would generate 9.44
daily trips per day, and the multi-family units would generate 5.44 daily trips per
unit. These generation rates have been derived from the Institute of Transportation
Engineers’ (ITE’s) Trip Generation Manual, 10th Edition, as discussed in Section 4.17,
Transportation, of the IS/MND. Using these rates, the proposed Project’s daily trip
generation is calculated. For a discussion of Project related traffic, please refer to
Response M&SP-8, above.
Regarding parking, the Project would include 2 covered garage parking spaces per
dwelling unit (for a total of 316 indoor garage spaces) and 99 uncovered guest
surface parking spaces throughout the Project site. As indicated in Section 3.2,
Project Access/Parking, of the IS/MND, in accordance with the provisions of the
Walnut Grove Specific Plan, while the proposed Project is required to provide a total
of 316 parking spaces for residents and 79 spaces for guests, the Project would
exceed this requirement by providing 20 surplus guest parking spaces. No
underground parking is proposed.
M&SP-16 The comment expresses the benefits of less units, so the future residents will have
more “space” in their homes. The comment is noted, but it is speculative, as it makes
assumptions about the future resident’s interests and preferences. The commenter
also hopes that the future residents will have school age children who would enroll
in the schools in the area to keep them open. The comment is noted. No further
response is required.
M&SP-17 The commenter asks for consideration for their needs and wants and indicates that
they do not want to be taken advantage of. The comment is noted and will be
forwarded to the decision makers. No further response is required.
12
M&SP-18 The comment regarding the cul-de-sac being the clearest spot on Eileen Avenue to
enjoy the nature is noted and will be forwarded to the decision makers. Please refer
to Response M&SP-10, regarding the cul-de-sac. No further response is required.
M&SP-19 The comment addresses Mr. Collier and indicates that the commenter passed out
the Project Fact Sheets. The comment is noted, and no further response is required.
M&SP-20 The comment regarding the Fact Sheet as related to KMART is noted and will be
forwarded to the decision makers. No further response is required.
M&SP-21 The comment regarding the word “proposed” is noted. It should be recognized that
use of the word “proposed” during the planning phase of a project is customary and
standard. Until a project is approved, it is referred to as the “proposed” project, and
its components (e.g., units, parking, wall, etc.) are also referred to as “proposed
units”, “proposed parking”, “proposed wall”, etc.
M&SP-22 Regarding the use of the word “proposed”, please refer to Response M&SP-22,
above. The discussion regarding the block wall has been between the Applicant and
the neighbors. The wall will be reviewed and approved by the City of West Covina.
The cost for permitting and construction of the wall will be borne by the Applicant.
M&SP-23 The comment regarding fumigation of existing structures and use of pest control
upon completion of the units is noted and will be forwarded to the decision makers.
Pest management will be included as part of the demolition of the existing school
structures.
M&SP-24 The comment inquires about the height of the wall as it relates to privacy. The
perimeter wall will generally range from 6 to 8 feet in height. There may be some
exceptions in cases where the existing wall of the adjacent property owner will
remain. In an effort to further enhance privacy, a 7.5-foot perimeter landscape
buffer adjacent to the wall will be established as part of the proposed project. A
hedgerow of closely spaced shrubs will be planted to form an additional privacy
barrier. The landscape buffer will be maintained by the homeowners association
for the proposed Project to ensure regular care and uniformity.
M&SP-25 The commenter indicates that she provided information about the Project to the
neighbors as much as she could remember and emphasizes the importance of their
concerns. The commenter further states that they have not been treated right in the
past. The comment is noted and will be forwarded to the decision makers. No
further response is required.
13
LKF1
1
2
3
14
3
(cont.)
4
5
6
7
8
15
8
(cont.)
8
9
10
11
12
16
12
(cont.)
13
14
15
17
16
17
18
18
Lydia K. Frey
Comment Letter Dated February 19, 2021
The general comment regarding the commenter’s concerns about the proposed Walnut Grove
Residential Project is noted and will be forwarded to the decision makers. It should be noted that
in accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review beginning on November 19, 2020 and ending on December 21, 2020.
During that time, the Draft IS/MND was available at the City of West Covina website. In light of
this, it should be acknowledged that this comment letter was submitted approximately two
months past the end of the review period. Nevertheless, the following responses are prepared to
address the comments.
Environmental
LKF1-1 The comment states that the Leighton and Associates, Inc. Phase I and Limited Phase
II ESA detected lead, arsenic, and organochloride pesticides and that the study
recommended further studies even though the levels were identified as below the
EPA thresholds for residential uses. The comment is noted and will be forwarded to
the decision makers. However, as indicated in the comment, the Leighton study
recommends that during site development, upon encountering the types of finds
stated in the quote from the study, further investigation and analysis may be
necessary. The study does not require further investigation at this time.
Section 4.9, Hazards and Hazardous Materials, of the IS/MND, was prepared based on
the findings of the Leighton Phase I/II ESA in addition to the Limited Asbestos
Inspection Report and Lead‐Based Paint/Ceramic Tile Inspection Report, prepared by
Executive Environmental and provided adequate level of detail pursuant to CEQA and
CEQA Guidelines. The analysis in Section 4.9 indicated that,
The Phase I ESA did not identify the presence of previous or current
hazardous materials or wastes on the site. No underground or aboveground
storage tanks were observed, and no stains, corrosion, drains, sumps, pits, or
wells are present on the site. The existing school uses are not occupied.
Miscellaneous trash, consisting of abandoned school and office supplies and
equipment, was observed in the classroom buildings, the administration
building, and the cafeteria. Minor amounts of trash were observed on the
exterior of the Project site. According to the Phase I ESA, this debris is not
considered a recognized environmental condition (REC) associated with the
Project site. Commercial and residential uses near the site do not represent a
significant environmental concern due to their distances or case status. No
evidence of RECs (either historical or controlled) was found on the site, and
no additional assessment was recommended. The Project site is not listed as
a facility that handled hazardous materials or generated hazardous wastes.
Additionally, as indicated in the comment,
According to the Limited Phase II ESA, the Project site did not detect
concentrations of arsenic, lead, or organochlorine pesticides (OCPs) in excess
of the U.S. Environmental Protection Agency (USEPA) Residential Regional
Screening Levels (RSLs) or Department of Toxic Substance Control Screening
Levels (DTSC-SLs).
19
The analysis identified that due to the age of the structures, asbestos-containing
materials (ACM) and lead based paint (LBP) were anticipated to be present. However,
the studies concluded that demolition, removal, and disposal of ACM and LBP would
comply with existing regulatory requirements, including the Federal and State
Occupational Safety and Health Regulations (OSHA and CalOSHA); SCAQMD
Regulation X, Subpart M − National Emission Standards For Asbestos and Rule 1403
– Asbestos Emissions (see RR HAZ-2); and California Code of Regulations Title 8,
Section 1532.1 – Lead and Section 1529 – Asbestos. With compliance with these
regulations, which are reflected in RR HAZ-1 through RR HAZ-3, the impacts would
be less than significant.
LKF1-2 The comment pertaining to hydrology states that by replacing five acres of penetrable
land with impenetrable materials, there will be significant impacts, as runoff from the
site will have more contaminants. The comment also says that “with the cars parked
in the 355+ spaces provided, contaminants will be directly into the water swale and
into the catch basins . . .” The comment is not clear and does not identify where the
355+ spaces are provided. The proposed Project will include a total of 99 surface
guest parking spaces in addition to 316 spaces in garages.
Section 4.10, Hydrology and Water Quality, of the IS/MND provided a detailed
analysis of potential water quality impacts during construction and operation of the
Project and concluded that impacts would be less than significant with compliance
with regulations. During operations, the analysis indicates that the Project would
generate sediment, trash and debris, oil and grease, bacterial indicators, nutrients,
and pesticides that would come from landscaped areas, drive aisles, parking areas,
and outdoor residential activities. However, the Project Applicant would be required
to prepare and implement a standard urban stormwater mitigation plan (SUSMP)
(reflected in RR HYD-2), which would include low impact development, structural
and non-structural BMPs and source control BMPs. Compliance with RR HYD-1 and
RR HYD-2 would reduce the risk of water degradation from soil erosion and other
pollutants, and potential violations of water quality standards would be minimized
through required BMPs. Consequently, the Project would not violate water quality
standards or waste discharge requirements.
LKF1-3 The comment expresses concerns for the nesting birds and identifies nests on existing
trees (photographs provided in Appendix III, Nesting Birds). The comment is noted
and will be forwarded to the decision makers. Section 4.4, Biological Resources, of the
IS/MND provides a detailed discussion of potential impacts pertaining to nesting
birds, as related to Threshold (d). Based on the analysis, in light of the presence of
trees and vegetation on the site, there is potential for birds protected by the Federal
Migratory Bird Treaty Act (MBTA) and Sections 3503, 3503.5, and 3513 of the
California Fish and Game Code to nest at the site. Bird species protected under the
provisions of the MBTA are identified by the List of Migratory Birds (50 Code of
Federal Regulations [CFR] Section 10.13, as amended). In order to protect the birds,
if demolition and site clearing activities occur during the nesting season, a mitigation
measure (MM BIO-1) is recommended to avoid impacts to nesting birds and their
fledglings. Per MM BIO-1, a pre-construction survey will occur to find out if nests are
present. The provisions of MM BIO-1 require that the start of demolition and site
preparation would occur outside of the bird nesting and breeding season; if nests are
within 200 feet of the impact area, a temporary buffer will be erected; and
construction activities will be postponed until juveniles have fledged from the nest.
Additionally, a biologist will serve as a construction monitor during those periods
20
when disturbance activities will occur near active nest areas to ensure that no
inadvertent impacts on these nests will occur.
It should also be noted that upon completion of construction and landscaping
activities on the site, newly planted trees and landscaping would provide nesting
habitat for migratory birds. In light of the above provisions in place, impacts would
be less than significant.
LKF1-4 The comment states that removal of trees would be an environmental impact and
further identifies the importance of trees and grass in terms of carbon dioxide
absorption. The comment is noted and will be forwarded to the decision makers.
Section 4.4, Biological Resources (Threshold e), of the IS/MND identifies removal of
the said trees in order to accommodate development of the Project. Per the
discussion, a permit will be required to remove trees, as oak trees are native to
California and are considered heritage trees. Therefore, the Project would be subject
to Chapter 26, Article VI, Division 9, Preservation, Protection, and Removal of Trees,
of the West Covina Municipal Code. This requirement is reflected in RR BIO-1.
Additionally, the carbon dioxide emissions for the Project were quantified and were
found to be under the SCAQMD-recommended threshold of 3,000 MTCO2e/year, as
stated in Section 4.XX, Greenhouse Gas Emissions, of the IS/MND. Also, the Project
would plant over 200 trees and provide ample landscaping, which would sequester
carbon dioxide.
LKF1-5 The commenter states that the study on the City’s website indicates that “the
equipment may only temporarily have an impact on the air quality of local residents”.
Please note, Section 4.3, Air Quality, of the IS/MND provides a detailed analysis of
construction and operations air quality for the proposed Project. Project emissions
were estimated using the California Emissions Estimator Model (CalEEMod) version
2016.3.2 computer program. CalEEMod is designed to model construction and
operational emissions for land development projects. Based on the quantified
analysis, none of the criteria pollutants for the estimated maximum daily emissions
during construction of the Project exceeded the South Coast Air Quality Management
District’s (SCAQMD’s) daily regional emission thresholds. As shown in Table 4-5 on
page 4-19 of the Air Quality section, all criteria pollutants are below the SCAQMD’s
respective thresholds. Therefore, no significant impacts would result.
Public Utilities & Electric
LKF1-6 The commenter states that there is no study published with the list of commenters,
including Southern California Edison (SCE). The comment pertaining to the potential
rolling blackout in peak heat season is noted and will be forwarded to the decision
makers.
Please note, the Responses to Comments on the Draft Initial Study/Mitigated Negative
Declaration, Walnut Grove Residential Project, dated February 2021 has been
available on the City’s website. Section 2.0 of the document includes a table that lists
the commenters. The City received a total of eight comments, one comment from
Caltrans District 7; one comment from Los Angeles County Sanitation Districts; and
six comment letters from individuals. No letter was received from SCE, even though
an electronic copy of the IS/MND and a Notice of Intent (NOI) were sent, and they
were received by the SCE. Thus, SCE has been made aware of the Project.
21
Traffic Study Flaws
LKF1-7 The comment inquires if Caltrans was notified of this Project. Caltrans is aware of the
Project and provided comments, indicating that the Project is unlikely to have a
notable impact to their facilities. The Project is expected to generate 1,124 trips per
day, not the 12,000 noted in the comment. The proposed resident parking (i.e., 2
spaces per unit) and 99 parking spaces for the guests are consistent with City
standards as well as the Walnut Grove Specific Plan. Existing traffic volumes were
taken from 2017 and a growth rate was applied to estimate 2020 volumes, as detailed
in the report. Traffic volumes have decreased significantly during the ongoing COVID-
19 pandemic, so volumes collected now would not accurately represent non-
pandemic conditions.
LKF1-8 The comment expresses concern about the number of units and “only one” entrance
and exit on Rowland Avenue as well as potential accidents. The comment is noted and
will be forwarded to the decision makers. Trip generation is not based on number of
occupants, but instead is based on number of units. The Project will have two
driveways on East Rowland Avenue, both of which will serve entering and exiting
traffic. Approximately 40 total inbound Project trips are expected to be added to the
East Rowland Avenue/Azusa Avenue intersection in the peak hour for all approaches
combined, which may have a nominal effect on operations. However, the northbound
left turn operates as a protected only movement (left turns are only allowed on green
arrow, not during southbound through traffic), so there should not be any conflicts
between northbound left turn vehicles and southbound right turn vehicles unless a
driver is running a red light. If red light running is an issue at the intersection, law
enforcement can be notified, and enforcement can be increased at the intersection.
Additionally, it should be recognized that not all units in the proposed development
will be three stories. The Project would include construction of a 158-unit attached
and detached residential development, which would consist of two different types of
residences, including 66 units of detached single-family in a cluster configuration and
92 attached multi-family units. Only the 92 multi-family residential units will be 3
stories, and the single-family units will be 2 stories.
This comment also expressed concern for potential pedestrian accident. The
comment is noted and will be forwarded to the decision makers. If students from the
Project site decide to walk to school, they will be able to cross the major roadways
(Lark Ellen or Azusa Avenue) to reach their school at a signalized intersection. While
additional pedestrians can generally increase the risk of pedestrian-involved crashes,
having the opportunity to cross at a signalized intersection is generally considered
one of the safest options for pedestrians. It is the responsibility of the pedestrians to
be aware of their surroundings and cross when indicated, and it is the responsibility
of drivers to yield to pedestrians. If the intersection has a high incidence of drivers
running red lights or not yielding to pedestrians, law enforcement presence can be
increased to help improve driver behavior.
LKF1-9 The comment states that Caltrans recommends traffic calming measures. The
comment is noted; however, Caltrans comments do not specifically recommend
traffic calming measures; instead, they recommend incorporation of multi-modal and
complete streets elements. The Project will include on-site pedestrian and bicycle
facilities and on-street parking will be prohibited along the frontage of the Project,
providing additional area for cyclists. The comments state support for traffic calming
22
features, but none is required by the City at this time. However, if speeding is an
existing issue, the City can evaluate various approaches to reducing speeds including
increased enforcement and/or construction of a road diet (reducing travel lanes to
one per direction).
At most, there are expected to be 61 vehicles exiting the property during the AM peak
hour (fewer in the PM peak hour), and they will be able to do so from either property
access point. The west access will allow left turns directly on to Rowland Avenue. If
drivers do choose to make a U-turn at Homerest, the outside through lane will allow
other drivers to continue west. Of the 61 exiting vehicles, approximately 60 percent
(36 vehicles) are expected to travel towards Azusa Avenue.
LKF1-10 Assuming this comment is concerning cut-through traffic through the residential
areas between East Rowland Avenue and Puente, the concern is noted and will be
forwarded to the decision makers. This issue is beyond the scope of this Project. The
commenter can discuss speed calming measures with the City, and the City may
evaluate other options to reduce cut-through traffic.
LKF1-11 It should also be noted that the increase in traffic is not quantified based the number
of cars in each household but rather based on the type of development that is
proposed, in this case single- and multi-family residential. Thus, traffic trips
commensurate with the type of residential development. The single-family detached
units would generate 9.44 daily trips per day, and the multi-family units would
generate 5.44 daily trips per unit. These generation rates have been derived from the
Institute of Transportation Engineers’ (ITE’s) Trip Generation Manual, 10th Edition, as
discussed in Section 4.17, Transportation, of the IS/MND. Using these rates, the
proposed Project’s daily trip generation is 1,124 trips per day, with approximately 82
AM peak hour trips and 106 PM peak hour trips. In light of this, please note, the
Project will not add a total of 12,100 trips per day as indicated in the comment.
Pedestrian facilities will be provided on site and will tie into the existing sidewalks
along East Rowland Avenue. If school children do move into the area and end up
walking to their perspective schools, they will be able to do so by crossing one
signalized intersection. Further, if students walk to school (accompanied by parents
or alone), that may reduce the total number of trips generated by the site.
Preliminary Hydrology Report Response: Water Run‐Off Problems
LKF1-12 The comment regarding the findings of drainage and storm runoff is noted and will
be forwarded to the decision makers. Please refer to Response LKF-2, above,
regarding replacement of “penetrable land” with “impenetrable materials,”
contributing to runoff.
The comment regarding runoff (photos in Appendix I) and the existing management
of runoff being ineffective is noted and will be forwarded to the decision makers. The
channel that extends across the northwest and western boundary of the site currently
accepts offsite drainage from the commercial center north of the Project. With
implementation of the proposed Project, the current flows from offsite will be
intercepted at the northern cul-de-sac (North Eileen Street) and re-routed through
the Project site through an underground drainage system. Following completion of
the drainage improvements at the North Eileen Street cul-de-sac, the road will be
repaired to resurface damaged areas associated with the construction effort.
23
Further, the comment repeats that the replacement of “penetrable land” with
“impenetrable materials,” will exacerbates the flooding condition. Please refer to
Response LKF-2, above for additional discussion. It should also be noted that the
current flooding condition referenced by the commenter and shown on photos in
Appendix I is a condition that exists regardless of the proposed Project, and the
Applicant bears no responsibility for addressing it.
Too Many Units
LKF1-13 The comment regarding market research flaws is noted and will be forwarded to
the decision makers. As noted above in Response LKF-9, not all units in the
proposed development will be three stories. The Project would include
construction of a 158-unit attached and detached residential development, which
would consist of two different types of residences, including 66 units of detached
single-family in a cluster configuration and 92 attached multi-family units. Only the
92 multi-family residential units will be 3 stories, and the single-family units will be
2 stories. Additionally, it should be recognized that the three-story multi-family
units will be located on the eastern portion of the site, along the existing commercial
uses and/or surface parking lot, while the two-story single-family units will be
located on the western portion and adjacent to existing residential uses.
LKF1-14 The comment regarding crime and impact on West Covina Police Department
(WCPD) is noted and will be forwarded to the decision makers. The comment
regarding the City experiencing an increase in homeless population near the Project
leading to property theft crimes is the opinion of the commenter and speculative at
best. Additionally, there is no nexus between development of the proposed Project
and increase in crimes by the homeless population. The conclusion is drawn based
on personal opinion and speculation. No backup documentation, with the exception
of the Economic Roundtable reporting, and no substantial evidence is provided. No
further response is required.
LKF1-15 The comment regarding impact on local schools by the future residents of the
proposed Project is noted and will be forwarded to the decision makers. The
analysis in the IS/MND acknowledges that the 529 future residents of the
development will potentially have school aged children requiring school services
from the Covina-Valley Unified School District (C-VUSD). The C-VUSD serves 12,500
students1in eight elementary schools, three middle schools, and four high schools.
According to student generation rates for residential land uses within the C-VUSD,
the Project may generate 28 elementary school students, 15 middle school students,
and 24 high school students, for a total of 66 students.
The Project would pay school development fees to the C-VUSD for the improvement
of school facilities that would be needed to serve the Project’s demand for school
services and facilities. This requirement is reflected in RR PS-3 in Section 4.15,
Public Services, of the IS/MND. As provided under Section 17620 of the California
Education Code and Section 65970 of the California Government Code, the payment
1 Based on 2013-2014 student enrollment at C-VUSD, last available data from California Department of Education
Educational Demographics Unit:
https://dq.cde.ca.gov/dataquest/Enrollment/EthnicEnr.aspx?cChoice=CoEnrEth2&cYear=2013-
14&TheCounty=19,Los%20Angeles&cLevel=County&cTopic=Enrollment&myTimeFrame=S&cType=ALL&cGender=
B
24
of statutory school development fees would fully mitigate a project’s impacts on
schools. Thus, the impacts would be less than significant.
LKF1-16 The commenter questions the number of proposed units and assumes the Project
is a three-story development. Please refer to Response LKF-11, above, for a
discussion of the proposed components of the Project.
The comment regarding the City of West Covina being in a dire financial situation is
noted and will be forwarded to the decision makers. This is not CEQA issues, and no
further response is required.
Three Story Structures’ Proximity to Residents
LKF1-17 The comment states that the Project with the proposed height and close proximity is
an imposition on the existing residential units, and that such a project should be
located near non-residential uses. The comment implies that the proposed Project is
a high-rise development. The comment is noted and will be forwarded to the decision
makers.
The proposed Project includes construction of a 158-unit attached and detached
residential development, which would consist of two different types of residences,
including 66 units of detached single-family in a cluster configuration and 92 attached
multi-family units. Only the 92 multi-family residential units will be 3 stories, and the
single-family units will be 2 stories. A maximum height of three stories is not
considered a high-rise development. According to California Building Code (CBC),
a high‐rise building is defined in Chapter 2 as “Every building of any type of
construction or occupancy having floors used for human occupancy located more
than 75 feet above the lowest floor level having building access . . . ” Typically, a 5-
story building could be considered a “high-rise” building. Thus, the proposed Project
with a maximum height of approximately 40 feet (40’-4”) is not considered a high-
rise.
The proposed Project provides adequate setback along the northern property line,
which interfaces the existing residential units. In fact, the proposed setback is larger
than what the zoning requires for the adjacent residential zone. Additionally, the
features in place would create buffers between the existing and proposed homes,
which would provide and maintain privacy, soften the interface, and promote
compatibility.
Regarding backyard pool privacy, it should be noted that the windows on the second
story units along the north side of the property have been modified to a height that
will make it impractical for the future residents in those units to have downward
visibility into the existing adjacent properties. Further, the designated 7.5-foot
landscape buffer is intended to be planted with Podocarpus Gracilior (or similar) and
maintained on a regular basis. The purpose of the buffer is to provide additional
privacy. The landscape buffer will not be a maintenance obligation of the individual
unit owner. To keep the landscape buffer uniform, the plant material will be
maintained by the homeowners association for the Project.
Regarding views, the discussion in Section 4.1, Aesthetics, of the IS/MND provides a
detailed analysis of potential visual impacts of the proposed Project. While the
proposed Project would alter the existing visual character of the Project site from a
school use to a residential development and would change views from the
25
surrounding public vantage point2 (i.e., East Rowland Avenue), this change would not
be considered a degradation of the Project site or its surroundings. The new
development would replace older structures and increase visual interest and
character of the site with quality design and landscaping. The Project would be
required to comply with Section 26-547, Specific Plan (S-P) zone, which has
requirements for design elements, such as orientation of buildings and uses, building
bulk and scale, building height and setback, parking, traffic generation, noise and
landscaping (RR AES-1). Therefore, this would ensure that the design of the Project
uses would be compatible with the surrounding uses and the General Plan
requirements. Additionally, as indicated above, the proposed units adjacent to
existing residential uses will be two-story single family units and not three stories.
Transparency
LKF1-18 The commenter is hoping for transparency and that there is no relation between the
Planning Commissioner Nickolas Lewis and the Applicant. The commenter also asks
for a statement ensuring transparently. The comment is noted and will be forwarded
to the decision makers. No further response is required.
2 Please note, the updated Appendix G of the State CEQA Guidelines (Aesthetics section, Threshold c), considers “public”
and not “private” views of the site. The threshold defines public views as, “those that are experienced from publicly
accessible vantage point).
26
LKF2
Amendments
I. Rather than 128 three-story units, I want to submit that, instead, something
benefiting the community is preferable to me, Lydia K. Frey, an E Rowland Ave
resident.
II. Aquatics Center -- In Southern California, particularly in this area, many homes
have pools. For people who don’t, they know their children will either visit a
grandparent or a friend with a pool, and it is a safety concern, as well as a
socialization concern and developmental concern, to provide their children with
aquatic safety lessons. I suggest a community recreation center with a pool.
A. I own a small business providing aquatic safety lessons; a project like this
would actually be my competition. However, given my experience and
expertise, there is a real need that is not being met for sufficient aquatic
safety lessons.
B. Tearing down a school and, rather than stacking 128 three-story units,
increasing West Covina’s risk for infrastructure problems, crime problems
to residents, West Covina’s carbon footprint and effectively offsetting a
significant portion of its current mitigation, replacing it with something
similar to the La Verne Aquatics center, with a small park, will be of major
benefit to the City and the Community.
If this land has already been sold and the Lewis Group is unwilling to sell it back, the
Lewis Group can commodify this, similar to other sports parks and soccer centers, and
charge a fee for use and/or rentals, whilst providing lifeguards on duty.
I would rather see something benefitting my community.
Thank you, Joanne. Please confirm that these will be in the Packet, added to my statements.
Thank you.
Regards,
Lydia
Lydia K. Frey
February 24, 2021
27
Lydia K. Frey
Comment Letter Dated February 24, 2021
LKF2-1 The commenter provides suggestions and ideas for the development of the site that
would replace the proposed development concept. The comment erroneously makes
references to the proposed Project as a “three-story” development. As indicated in the
responses to the previous letter by the commenter, not all units in the proposed
development will be three stories. The Project would include construction of a 158-
unit attached and detached residential development, which would consist of two
different types of residences, including 66 units of detached single-family in a cluster
configuration and 92 attached multi-family units. Only the 92 multi-family residential
units will be three stories, and the single-family units will be two stories. The three-
story multi-family units will be located on the eastern portion of the site, along the
existing commercial uses and/or surface parking lot, while the two-story single-
family units will be located on the western portion and adjacent to existing residential
uses.
The commenter’s suggestion regarding an “Aquatics Center” in lieu of the proposed
development is the opinion of the commenter. No further response is required.
28
VC1
1
2
3
4
5
29
Vicki Claudius
Comment Letter Dated February XX, 2021
The general comment regarding the commenter’s concerns about the proposed Walnut Grove
Residential Project is noted and will be forwarded to the decision makers. It should be noted that
in accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review beginning on November 19, 2020 and ending on December 21, 2020.
During that time, the Draft IS/MND was available at the City of West Covina website. In light of
this, it should be acknowledged that this comment letter was submitted to the City of West
Covina approximately two months past the end of the review period. Nevertheless, the following
responses are prepared to address the comments.
VC1-1 The commenter expressed reservations about the proposed Walnut Grove
Residential Project living three houses from the site, and that the proposed
development will negatively affect the existing neighborhood and the peace and quiet
that the they have enjoyed. The comment is noted and will be forwarded to the
decision makers. No further response is required.
VC1-2 The comment regarding the type and number of units proposed is noted and will be
forwarded to the decision makers. The commenter states that she has not seen the
combination of single-family and condo/townhouses being built within an
established residential neighborhood. The Project would include construction of a
158-unit attached and detached residential development, which would consist of two
different types of residences, including 66 units of detached single-family in a cluster
configuration and 92 attached multi-family units. Only the 92 multi-family residential
units will be 3 stories, and the single-family units will be 2 stories. Additionally, it
should be noted that in consideration of the existing uses, the three-story multi-family
units will be located on the easter portion of the site, along the existing commercial
uses and/or surface parking lot, while the two-story single-family units will be
located on the western portion and adjacent to existing residential uses.
Additionally, the proposed Project provides adequate setback along the northern
property line, which interfaces the existing residential units. In fact, the proposed
setback is larger than what the zoning requires for the adjacent residential zone.
Additionally, the features in place would create buffers between the existing and
proposed homes, which would provide and maintain privacy, soften the interface, and
promote compatibility. In light of the above design consideration, no incompatibility
impacts would be anticipated.
The comment regarding the developers boosting their profits is noted and forwarded
to the decision makers. This comment expresses the opinion of the commenter. No
further response is required.
VC1-3 The commenter is concerned about few entrances/exits for the Project in light of the
number of people and cars, and all cars “coming onto Rowland Avenue” will
exacerbate traffic. The comment is noted and forwarded to the decision makers. The
proposed Walnut Grove Residential development is designed per the requirements
as stated in the Walnut Grove Specific Plan and in compliance with City regulations.
In designing the entries/exists for the Project, the number of units and the future
residents were considered. Thus, in light of safety requirements, the number of
entries/exists are appropriate for the proposed development.
30
In terms of traffic, Section 4.17, Transportation, of the IS/MND includes a detailed
analysis of the potential traffic impacts of the proposed Project. While it is
acknowledged that the Project would generate trips and increase traffic, construction
traffic is not likely to create any significant impact due to the size of the proposed
Project. Additionally, during Project operations, the limited number of Project trips is
unlikely to result in any impacts at roadways and intersections near the site and in
the surrounding area. The number of vehicles being added will be a relatively small
percentage of the existing traffic in the area. As such, the analysis does not identify
any mitigation measures, as none is required.
VC1-4 The comments states that the proposed Project will result in a large number of people
in the area. The comment is noted and will be forwarded to the decision makers.
Section 4.14, Population and Housing, of the IS/MND provides an analysis of the
future population associated with the development. The Walnut Grove Project would
directly generate approximately 529 residents. This would increase the City’s
resident population of 105,999 persons by 0.5 percent to 106,528 residents. It would
also increase the City’s housing stock of 32,919 (Department of Finance 2020) by 0.48
percent to 33,077 units. However, these increases would be within anticipated
growth for the City as projected by Southern California Association of Governments
(SCAG) at 116,700 residents, 35,000 households, and 34,300 jobs by 2040 (SCAG).
Therefore, the increase in population in the area is not such that would negatively
impact the surrounding area.
VC1-5 The comment regarding the increase in runoff as a result of the proposed
development is noted and will be forwarded to the decision makers. The Project
includes drainage improvements. The channel that extends across the northwest and
western boundary of the site currently accepts offsite drainage from the commercial
center north of the Project. With implementation of the proposed Project, the current
flows from offsite will be intercepted at the northern cul-de-sac (North Eileen Street)
and re-routed through the Project site through an underground drainage system.
Following completion of the drainage improvements at the North Eileen Street cul-
de-sac, the road will be repaired to resurface damaged areas associated with the
construction effort. It should be noted that the current flooding condition referenced
by the commenter is a condition that exists regardless of the proposed Project.
The comment regarding reducing the number of structures is noted and will be
forwarded to the decision makers. The comment regarding the Project being a
separate village within an existing neighborhood is the opinion of the commenter. No
further response is required.
The comment regarding runoff is noted and will be forwarded to the decision makers.
The channel that extends across the northwest and western boundary of the site
currently accepts offsite drainage from the commercial center north of the Project.
With implementation of the proposed Project, the current flows from offsite will be
intercepted at the northern cul-de-sac (North Eileen Street) and re-routed through
the Project site through an underground drainage system. Following completion of
the drainage improvements at the North Eileen Street cul-de-sac, the road will be
repaired to resurface damaged areas associated with the construction effort. It should
be noted that the current flooding condition referenced by the commenter is a
condition that exists regardless of the proposed Project.
31
VC2
1
2
3
32
4
5
6
7
8
9
33
9
(cont.)
10
11
12
34
12
(cont.)
13
14
15
16
35
17
18
36
Vicki Claudius
Comment Letter Dated February 20, 2021
The general comment regarding the commenter’s concerns about the proposed Walnut Grove
Residential Project is noted and will be forwarded to the decision makers. It should be noted that
in accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review beginning on November 19, 2020 and ending on December 21, 2020.
During that time, the Draft IS/MND was available at the City of West Covina website. In light of
this, it should be acknowledged that this comment letter was submitted approximately two
months past the end of the review period. Nevertheless, the following responses are prepared to
address the comments.
Environmental
VC2-1 The comment states that the Leighton and Associates, Inc. Phase I and Limited Phase
II ESA detected lead, arsenic, and organochloride pesticides and that the study
recommended further studies even though the levels were identified as below the
EPA thresholds for residential uses. The comment is noted and will be forwarded to
the decision makers. However, as indicated in the comment, the Leighton study
recommends that during site development, upon encountering the types of finds
stated in the quote from the study, further investigation and analysis may be
necessary. The study does not require further investigation at this time.
Section 4.9, Hazards and Hazardous Materials, of the IS/MND, was prepared based on
the findings of the Leighton Phase I/II ESA in addition to the Limited Asbestos
Inspection Report and Lead‐Based Paint/Ceramic Tile Inspection Report, prepared by
Executive Environmental and provided adequate level of detail pursuant to CEQA and
CEQA Guidelines. The analysis in Section 4.9 indicated that,
The Phase I ESA did not identify the presence of previous or current
hazardous materials or wastes on the site. No underground or aboveground
storage tanks were observed, and no stains, corrosion, drains, sumps, pits, or
wells are present on the site. The existing school uses are not occupied.
Miscellaneous trash, consisting of abandoned school and office supplies and
equipment, was observed in the classroom buildings, the administration
building, and the cafeteria. Minor amounts of trash were observed on the
exterior of the Project site. According to the Phase I ESA, this debris is not
considered a recognized environmental condition (REC) associated with the
Project site. Commercial and residential uses near the site do not represent a
significant environmental concern due to their distances or case status. No
evidence of RECs (either historical or controlled) was found on the site, and
no additional assessment was recommended. The Project site is not listed as
a facility that handled hazardous materials or generated hazardous wastes.
Additionally, as indicated in the comment,
According to the Limited Phase II ESA, the Project site did not detect
concentrations of arsenic, lead, or organochlorine pesticides (OCPs) in excess
of the U.S. Environmental Protection Agency (USEPA) Residential Regional
Screening Levels (RSLs) or Department of Toxic Substance Control Screening
Levels (DTSC-SLs).
37
The analysis identified that due to the age of the structures, asbestos-containing
materials (ACM) and lead based paint (LBP) were anticipated to be present. However,
the studies concluded that demolition, removal, and disposal of ACM and LBP would
comply with existing regulatory requirements, including the Federal and State
Occupational Safety and Health Regulations (OSHA and CalOSHA); SCAQMD
Regulation X, Subpart M − National Emission Standards For Asbestos and Rule 1403
– Asbestos Emissions (see RR HAZ-2); and California Code of Regulations Title 8,
Section 1532.1 – Lead and Section 1529 – Asbestos. With compliance with these
regulations, which are reflected in RR HAZ-1 through RR HAZ-3, the impacts would
be less than significant.
VC2-2 The comment pertaining to hydrology states that by replacing five acres of penetrable
land with impenetrable materials, there will be significant impacts, as runoff from the
site will have more contaminants. The comment also says that “with the cars parked
in the 355+ spaces provided, contaminants will be directly into the water swale and
into the catch basins . . .” The comment is not clear and does not identify where the
355+ spaces are provided. The proposed Project will include a total of 99 surface
guest parking spaces in addition to 316 spaces in garages.
Section 4.10, Hydrology and Water Quality, of the IS/MND provided a detailed
analysis of potential water quality impacts during construction and operation of the
Project and concluded that impacts would be less than significant with compliance
with regulations. During operations, the analysis indicates that the Project would
generate sediment, trash and debris, oil and grease, bacterial indicators, nutrients,
and pesticides that would come from landscaped areas, drive aisles, parking areas,
and outdoor residential activities. However, the Project Applicant would be required
to prepare and implement a standard urban stormwater mitigation plan (SUSMP)
(reflected in RR HYD-2), which would include low impact development, structural
and non-structural BMPs and source control BMPs. Compliance with RR HYD-1 and
RR HYD-2 would reduce the risk of water degradation from soil erosion and other
pollutants, and potential violations of water quality standards would be minimized
through required BMPs. Consequently, the Project would not violate water quality
standards or waste discharge requirements.
VC2-3 The comment expresses concerns for the nesting birds and identifies nests on existing
trees (photographs provided in Appendix III, Nesting Birds). The comment is noted
and will be forwarded to the decision makers. Section 4.4, Biological Resources, of the
IS/MND provides a detailed discussion of potential impacts pertaining to nesting
birds, as related to Threshold (d). Based on the analysis, in light of the presence of
trees and vegetation on the site, there is potential for birds protected by the Federal
Migratory Bird Treaty Act (MBTA) and Sections 3503, 3503.5, and 3513 of the
California Fish and Game Code to nest at the site. Bird species protected under the
provisions of the MBTA are identified by the List of Migratory Birds (50 Code of
Federal Regulations [CFR] Section 10.13, as amended). In order to protect the birds,
if demolition and site clearing activities occur during the nesting season, a mitigation
measure (MM BIO-1) is recommended to avoid impacts to nesting birds and their
fledglings. Per MM BIO-1, a pre-construction survey will occur to find out if nests are
present. The provisions of MM BIO-1 require that the start of demolition and site
preparation would occur outside of the bird nesting and breeding season; if nests are
within 200 feet of the impact area, a temporary buffer will be erected; and
construction activities will be postponed until juveniles have fledged from the nest.
Additionally, a biologist will serve as a construction monitor during those periods
38
when disturbance activities will occur near active nest areas to ensure that no
inadvertent impacts on these nests will occur.
It should also be noted that upon completion of construction and landscaping
activities on the site, newly planted trees and landscaping would provide nesting
habitat for migratory birds. In light of the above provisions in place, impacts would
be less than significant.
VC2-4 The comment states that removal of trees would be an environmental impact and
further identifies the importance of trees and grass in terms of carbon dioxide
absorption. The comment is noted and will be forwarded to the decision makers.
Section 4.4, Biological Resources (Threshold e), of the IS/MND identifies removal of
the said trees in order to accommodate development of the Project. Per the
discussion, a permit will be required to remove trees, as oak trees are native to
California and are considered heritage trees. Therefore, the Project would be subject
to Chapter 26, Article VI, Division 9, Preservation, Protection, and Removal of Trees,
of the West Covina Municipal Code. This requirement is reflected in RR BIO-1.
Additionally, the carbon dioxide emissions for the Project were quantified and were
found to be under the SCAQMD-recommended threshold of 3,000 MTCO2e/year, as
stated in Section 4.XX, Greenhouse Gas Emissions, of the IS/MND. Also, the Project
would plant over 200 trees and provide ample landscaping, which would sequester
carbon dioxide.
VC2-5 The commenter states that the study on the City’s website indicates that “the
equipment may only temporarily have an impact on the air quality of local residents”.
Please note, Section 4.3, Air Quality, of the IS/MND provides a detailed analysis of
construction and operations air quality for the proposed Project. Project emissions
were estimated using the California Emissions Estimator Model (CalEEMod) version
2016.3.2 computer program. CalEEMod is designed to model construction and
operational emissions for land development projects. Based on the quantified
analysis, none of the criteria pollutants for the estimated maximum daily emissions
during construction of the Project exceeded the South Coast Air Quality Management
District’s (SCAQMD’s) daily regional emission thresholds. As shown in Table 4-5 on
page 4-19 of the Air Quality section, all criteria pollutants are below the SCAQMD’s
respective thresholds. Therefore, no significant impacts would result.
Public Utilities & Electric
VC2-6 The commenter states that there is no study published with the list of commenters,
including Southern California Edison (SCE). The comment pertaining to the potential
rolling blackout in peak heat season is noted and will be forwarded to the decision
makers.
Please note, the Responses to Comments on the Draft Initial Study/Mitigated Negative
Declaration, Walnut Grove Residential Project, dated February 2021 has been
available on the City’s website. Section 2.0 of the document includes a table that lists
the commenters. The City received a total of eight comments, one comment from
Caltrans District 7; one comment from Los Angeles County Sanitation Districts; and
six comment letters from individuals. No letter was received from SCE, even though
an electronic copy of the IS/MND and a Notice of Intent (NOI) were sent, and they
were received by the SCE. Thus, SCE has been made aware of the Project.
39
Traffic Study Flaws
VC2-7 The comment inquires if Caltrans was notified of this Project. Caltrans is aware of the
Project and provided comments, indicating that the Project is unlikely to have a
notable impact to their facilities. The Project is expected to generate 1,124 trips per
day, not the 12,000 noted in the comment. The proposed resident parking (i.e., 2
spaces per unit) is and 99 parking spaces for the guests are consistent with City
standards as well as the Walnut Grove Specific Plan. Existing traffic volumes were
taken from 2017 and a growth rate was applied to estimate 2020 volumes, as detailed
in the report. Traffic volumes have decreased significantly during the ongoing COVID-
19 pandemic, so volumes collected now would not accurately represent non-
pandemic conditions.
VC2-8 The comment expresses concern about the number of units and “only one” entrance
and exit on Rowland Avenue as well as potential accidents. The comment is noted and
will be forwarded to the decision makers. Trip generation is not based on number of
occupants, but instead is based on number of units. The Project will have two
driveways on East Rowland Avenue, both of which will serve entering and exiting
traffic. Approximately 40 total inbound Project trips are expected to be added to the
East Rowland Avenue/Azusa Avenue intersection in the peak hour for all approaches
combined, which may have a nominal effect on operations. However, the northbound
left turn operates as a protected only movement (left turns are only allowed on green
arrow, not during southbound through traffic), so there should not be any conflicts
between northbound left turn vehicles and southbound right turn vehicles unless a
driver is running a red light. If red light running is an issue at the intersection, law
enforcement can be notified, and enforcement can be increased at the intersection.
Additionally, it should be recognized that not all units in the proposed development
will be three stories. The Project would include construction of a 158-unit attached
and detached residential development, which would consist of two different types of
residences, including 66 units of detached single-family in a cluster configuration and
92 attached multi-family units. Only the 92 multi-family residential units will be 3
stories, and the single-family units will be 2 stories.
This comment also expressed concern for potential pedestrian accident. The
comment is noted and will be forwarded to the decision makers. If students from the
Project site decide to walk to school, they will be able to cross the major roadways
(Lark Ellen or Azusa Avenue) to reach their school at a signalized intersection. While
additional pedestrians can generally increase the risk of pedestrian-involved crashes,
having the opportunity to cross at a signalized intersection is generally considered
one of the safest options for pedestrians. It is the responsibility of the pedestrians to
be aware of their surroundings and cross when indicated, and it is the responsibility
of drivers to yield to pedestrians. If the intersection has a high incidence of drivers
running red lights or not yielding to pedestrians, law enforcement presence can be
increased to help improve driver behavior.
VC2-9 The comment states that Caltrans recommends traffic calming measures. The
comment is noted; however, Caltrans comments do not specifically recommend
traffic calming measures; instead, they recommend incorporation of multi-modal and
complete streets elements. The Project will include on-site pedestrian and bicycle
facilities and on-street parking will be prohibited along the frontage of the Project,
providing additional area for cyclists. The comments state support for traffic calming
40
features, but none is required by the City at this time. However, if speeding is an
existing issue, the City can evaluate various approaches to reducing speeds including
increased enforcement and/or construction of a road diet (reducing travel lanes to
one per direction).
At most, there are expected to be 61 vehicles exiting the property during the AM peak
hour (fewer in the PM peak hour), and they will be able to do so from either property
access point. The west access will allow left turns directly on to Rowland Avenue. If
drivers do choose to make a U-turn at Homerest, the outside through lane will allow
other drivers to continue west. Of the 61 exiting vehicles, approximately 60 percent
(36 vehicles) are expected to travel towards Azusa Avenue.
VC2-10 Assuming this comment is concerning cut-through traffic through the residential
areas between East Rowland Avenue and Puente, the concern is noted and will be
forwarded to the decision makers. This issue is beyond the scope of this Project. The
commenter can discuss speed calming measures with the City, and the City may
evaluate other options to reduce cut-through traffic.
VC2-11 It should also be noted that the increase in traffic is not quantified based the number
of cars in each household but rather based on the type of development that is
proposed, in this case single- and multi-family residential. Thus, traffic trips
commensurate with the type of residential development. The single-family detached
units would generate 9.44 daily trips per day, and the multi-family units would
generate 5.44 daily trips per unit. These generation rates have been derived from the
Institute of Transportation Engineers’ (ITE’s) Trip Generation Manual, 10th Edition, as
discussed in Section 4.17, Transportation, of the IS/MND. Using these rates, the
proposed Project’s daily trip generation is 1,124 trips per day, with approximately 82
AM peak hour trips and 106 PM peak hour trips. In light of this, please note, the
Project will not add a total of 12,100 trips per day as indicated in the comment.
Pedestrian facilities will be provided on site and will tie into the existing sidewalks
along East Rowland Avenue. If school children do move into the area and end up
walking to their perspective schools, they will be able to do so by crossing one
signalized intersection. Further, if students walk to school (accompanied by parents
or alone), that may reduce the total number of trips generated by the site.
Preliminary Hydrology Report Response: Water Run‐Off Problems
VC2-12 The comment regarding the findings of drainage and storm runoff is noted and will
be forwarded to the decision makers. Please refer to Response LKF-2, above,
regarding replacement of “penetrable land” with “impenetrable materials,”
contributing to runoff.
The comment regarding runoff (photos in Appendix I) and the existing management
of runoff being ineffective is noted and will be forwarded to the decision makers. The
channel that extends across the northwest and western boundary of the site currently
accepts offsite drainage from the commercial center north of the Project. With
implementation of the proposed Project, the current flows from offsite will be
intercepted at the northern cul-de-sac (North Eileen Street) and re-routed through
the Project site through an underground drainage system. Following completion of
the drainage improvements at the North Eileen Street cul-de-sac, the road will be
repaired to resurface damaged areas associated with the construction effort.
41
Further, the comment repeats that the replacement of “penetrable land” with
“impenetrable materials,” will exacerbates the flooding condition. Please refer to
Response LKF-2, above for additional discussion. It should also be noted that the
current flooding condition referenced by the commenter and shown on photos in
Appendix I is a condition that exists regardless of the proposed Project, and the
Applicant bears no responsibility for addressing it.
Too Many Units
VC2-13 The comment regarding market research flaws is noted and will be forwarded to the
decision makers. As noted above in Response LKF-9, not all units in the proposed
development will be three stories. The Project would include construction of a 158-
unit attached and detached residential development, which would consist of two
different types of residences, including 66 units of detached single-family in a cluster
configuration and 92 attached multi-family units. Only the 92 multi-family residential
units will be 3 stories, and the single-family units will be 2 stories. Additionally, it
should be recognized that the three-story multi-family units will be located on the
easter portion of the site, along the existing commercial uses and/or surface parking
lot, while the two-story single-family units will be located on the western portion and
adjacent to existing residential uses.
VC2-14 The comment regarding crime and impact on West Covina Police Department
(WCPD) is noted and will be forwarded to the decision makers. The comment
regarding the City experiencing an increase in homeless population near the Project
leading to property theft crimes is the opinion of the commenter and speculative at
best. Additionally, there is no nexus between development of the proposed Project
and increase in crimes by the homeless population. The conclusion is drawn based on
personal opinion and speculation. No backup documentation, with the exception of
the Economic Roundtable reporting, and no substantial evidence is provided. No
further response is required.
VC2-15 The comment regarding impact on local schools by the future residents of the
proposed Project is noted and will be forwarded to the decision makers. The analysis
in the IS/MND acknowledges that the 529 future residents of the development will
potentially have school aged children requiring school services from the Covina-
Valley Unified School District (C-VUSD). The C-VUSD serves 12,500 students3in eight
elementary schools, three middle schools, and four high schools. According to student
generation rates for residential land uses within the C-VUSD, the Project may
generate 28 elementary school students, 15 middle school students, and 24 high
school students, for a total of 66 students.
The Project would pay school development fees to the C-VUSD for the improvement
of school facilities that would be needed to serve the Project’s demand for school
services and facilities. This requirement is reflected in RR PS-3 in Section 4.15, Public
Services, of the IS/MND. As provided under Section 17620 of the California Education
Code and Section 65970 of the California Government Code, the payment of statutory
3 Based on 2013-2014 student enrollment at C-VUSD, last available data from California Department of Education
Educational Demographics Unit:
https://dq.cde.ca.gov/dataquest/Enrollment/EthnicEnr.aspx?cChoice=CoEnrEth2&cYear=2013-
14&TheCounty=19,Los%20Angeles&cLevel=County&cTopic=Enrollment&myTimeFrame=S&cType=ALL&cGender=
B
42
school development fees would fully mitigate a project’s impacts on schools. Thus, the
impacts would be less than significant.
VC2-16 The commenter questions the number of proposed units and assumes the Project is
a three-story development. Please refer to Response LKF-11, above, for a discussion
of the proposed components of the Project.
The comment regarding the City of West Covina being in a dire financial situation is
noted and will be forwarded to the decision makers. This is not CEQA issues, and no
further response is required.
Three Story Structures’ Proximity to Residents
VC2-17 The comment states that the Project with the proposed height and close proximity is
an imposition on the existing residential units, and that such a project should be
located near non-residential uses. The comment implies that the proposed Project is
a high-rise development. The comment is noted and will be forwarded to the decision
makers.
The proposed Project includes construction of a 158-unit attached and detached
residential development, which would consist of two different types of residences,
including 66 units of detached single-family in a cluster configuration and 92 attached
multi-family units. Only the 92 multi-family residential units will be 3 stories, and the
single-family units will be 2 stories. A maximum height of three stories is not
considered a high-rise development. According to California Building Code (CBC),
a high‐rise building is defined in Chapter 2 as “Every building of any type of
construction or occupancy having floors used for human occupancy located more
than 75 feet above the lowest floor level having building access . . . ” Typically, a 5-
story building could be considered a “high-rise” building. Thus, the proposed Project
with a maximum height of approximately 40 feet (40’-4”) is not considered a high-
rise.
The proposed Project provides adequate setback along the northern property line,
which interfaces the existing residential units. In fact, the proposed setback is larger
than what the zoning requires for the adjacent residential zone. Additionally, the
features in place would create buffers between the existing and proposed homes,
which would provide and maintain privacy, soften the interface, and promote
compatibility.
Regarding backyard pool privacy, it should be noted that the windows on the second
story units along the north side of the property have been modified to a height that
will make it impractical for the future residents in those units to have downward
visibility into the existing adjacent properties. Further, the designated 7.5-foot
landscape buffer is intended to be planted with Podocarpus Gracilior (or similar) and
maintained on a regular basis. The purpose of the buffer is to provide additional
privacy. The landscape buffer will not be a maintenance obligation of the individual
unit owner. To keep the landscape buffer uniform, the plant material will be
maintained by the homeowners association for the Project.
Regarding views, the discussion in Section 4.1, Aesthetics, of the IS/MND provides a
detailed analysis of potential visual impacts of the proposed Project. While the
proposed Project would alter the existing visual character of the Project site from a
school use to a residential development and would change views from the
43
surrounding public vantage point4 (i.e., East Rowland Avenue), this change would not
be considered a degradation of the Project site or its surroundings. The new
development would replace older structures and increase visual interest and
character of the site with quality design and landscaping. The Project would be
required to comply with Section 26-547, Specific Plan (S-P) zone, which has
requirements for design elements, such as orientation of buildings and uses, building
bulk and scale, building height and setback, parking, traffic generation, noise and
landscaping (RR AES-1). Therefore, this would ensure that the design of the Project
uses would be compatible with the surrounding uses and the General Plan
requirements. Additionally, as indicated above, the proposed units adjacent to
existing residential uses will be two-story single family units and not three stories.
Transparency
VC2-18 The commenter is hoping for transparency and that there is no relation between the
Planning Commissioner Nickolas Lewis and the Applicant. The commenter also asks
for a statement ensuring transparently. The comment is noted and will be forwarded
to the decision makers. No further response is required.
4 Please note, the updated Appendix G of the State CEQA Guidelines (Aesthetics section, Threshold c), considers “public”
and not “private” views of the site. The threshold defines public views as, “those that are experienced from publicly
accessible vantage point).
CBCM
CBCM-1
CBCM-2
CBCM-2
(cont.)
CBCM-2
(cont.)
CBCM-2
(cont.)
CBCM-2
(cont.)
CBCM-3
CBCM-3
(cont.)
CBCM-4
CBCM-4
(cont.)
CBCM-5
CBCM-6
CBCM-6
(cont.)
CBCM-7
CBCM-8
CBCM-8
(cont.)
CBCM-8
(cont.)
CBCM-9
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Chatten-Brown, Carstens & Minteer LLP
(Community Coalition Against Walnut Grove Project)
Comment Letter Dated March 23, 2021
Walnut Grove Residential Project
The general comment regarding the commenter’s concerns about the proposed Walnut Grove
Residential Project is noted and will be forwarded to the decision makers. It should be noted that
in accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review beginning on November 19, 2020 and ending on December 21, 2020.
During that time, the Draft IS/MND was available at the City of West Covina website. In light of
this, it should be acknowledged that this comment letter was submitted three months past the
end of the review period. Nevertheless, the following responses are prepared to address the
comments.
CBCM-1 The comment letter is submitted on behalf of Community Coalition Against Walnut
Grove Project. The comment briefly reiterates the Project description and adds that
the Project is inconsistent with the General Plan and Zoning. The comment is noted,
and it is acknowledged that as it stands the proposed land uses are not consistent
with the current land use designations. As such and as indicated in the IS/MND on
page 3-5 in Section 3.0, Project Description, a General Plan Amendment and Zone
Change are required and are part of the Project.
The Project site has an existing General Plan Land Use designation of Civic:
Schools. Approval of the Project and adoption of the Walnut Grove Specific
Plan requires a concurrent adoption of a General Plan Land Use Amendment
to the “Neighborhood Medium” land use designation, which allows densities
between 9 and 20 dwelling units.
Additionally, the discussion of Zone Change and Specific Plan Adoption (Section 3.6.2)
on the same page indicates that,
The Project site is currently zoned as Residential Single-Family (R-1). The R-
1 zoning of the site is not consistent with its General Plan land use designation
and requires a Zone Change to Specific Plan. Upon adoption by ordinance of
the Walnut Grove Specific Plan, it would constitute as the zoning for the
Project site, and therefore, the Project would be consistent with the
Zoning Code.
The comment regarding a tree removal permit for removal of significant trees is also
noted and is acknowledged in the IS/MND on page 3-6 in Section 3.0, Project
Description, and on page 4-29 in Section 4.4, Biological Resources. The discussion
indicates,
2 | P a g e
The significant trees onsite consist of trees 12 inches or greater in diameter,
including: one mulberry tree (Morus Spp.), two maple trees (Acer Spp.), one
carrotwood tree (Cupaniopsis Anacardioides), two bottle brush trees
(Callistemon Viminalis), one (sick) California ash tree (Fraxinus Dipetala), one
jacaranda tree (Jacaranda Mimosifolia), and 4 dead trees. These trees would
be removed as part of the Project. The removal of these trees would require a
permit to remove trees, as oak trees are native to California and are
considered heritage trees. Therefore, the Project would be subject to Chapter
26, Article VI, Division 9, Preservation, Protection, and Removal of Trees, of
the West Covina Municipal Code.
As discussed in the IS/MND, the removed trees and vegetation would be replaced by
a variety of trees, vines, shrubs, and groundcover.
The comment also states that the City’s environmental review does not satisfy the
California Environmental Quality Act (CEQA), and the underlying land transfer
violates the Surplus Lands Act. The comment is noted and will be forwarded to the
decision makers. The comment does not identify how the City’s review does not
satisfy CEQA, and as such no further response is required. Regarding the land transfer
and alleged violations of the Surplus Lands Act, it should be noted this is not a CEQA
issue, and as such no further response is required.
I. The Project is Inconsistent with the City of West Covina’s General Plan
CBCM -2 The comment cites various case law to assert that a City’s land use decision must be
consistent with the General Plan, and that a project is inconsistent with a General Plan
if it conflicts with a policy that is “fundamental, mandatory, and clear”. The comment
is noted and will be forwarded to the decision makers. Regarding the current
designations and the proposed General Plan Amendment and Zone Change, please
refer to Response CBCM-1, above.
The comment claims that the Project is inconsistent with various General Plan Goals
and Policies. The commenter is incorrect. Each of the alleged inconsistencies are
addressed in the table below.
General Plan Consistency Analysis
General Plan Goals/Policy/Actions Consistency Analysis
Goal – Our Natural Community
Air-P1.1 Promote alternative
transportation modes like
walking, biking, and transit that
reduce emissions related to
vehicular travel.
The proposed Project would not conflict with adopted
policies, plans, or programs regarding public transit,
bike, or pedestrian facilities. As discussed in the
IS/MND, Section 4.8, Greenhouse Gas Emissions and
4.17, Transportation of the IS/MND, the Project is an
infill development and would result in trip reductions
due to the Project site’s proximity to nearby
commercial uses within walking distance of the Project
site. As such, the Project would promote pedestrian
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General Plan Consistency Analysis
General Plan Goals/Policy/Actions Consistency Analysis
activity in an area with complementary uses, which
would reduce reliance on single-passenger vehicles.
Additionally, sidewalks are present on East Rowland
Avenue, which would be retained by the Project and
would continue to accommodate pedestrians and
bicyclists. Also, the Project will include bike racks on-
site for use by future residents of the Project and their
guests. The bike racks will be provided in two locations
adjacent to the mailboxes and wood arbor trellis
entries, around the perimeter of the park.
Regarding providing more parking than required,
please refer to Response CBCM-4, below.
Thus, based on the above, the Project would not
conflict with this policy.
Policy 1.3
A1.3
Minimize the adverse impacts of
growth and development on air
quality and climate.
As discussed in detail and supported by modeling and
quantified analysis in Section 4.3, Air Quality and
Section 4.8, Greenhouse Gas Emissions, of the MND, the
Project would not result in significant air quality and
greenhouse gas emissions impacts. Besides compliance
with regulatory requirements, no mitigation measures
were required for either topic, as none exceeded the
significance thresholds.
Regarding providing more parking than required,
please refer to Response CBCM-4, below.
Thus, the Project would not conflict with this policy.
Water
A 1.4
P 1.4
A 1.5
Where appropriate, new
development shall minimize
impervious area, minimize runoff
and pollution, and incorporate
best management practices.
Where appropriate, new
development shall minimize
impervious area, minimize runoff
and pollution, and incorporate
best management practices
Develop Standards to increase
pervious surfaces recharge
groundwater basin, where
appropriate.
Project implementation would result in an increase in
impervious surfaces, as accurately disclosed in the
IS/MND. A private storm drain system within the main
drive aisles would convey the site’s stormwater runoff
to an underground detention system in the guest
parking lot adjacent to East Rowland Avenue.
Stormwater would infiltrate, be detained, and meter
the runoff onto East Rowland Avenue to match
historical drainage patterns and volumes at the Project
site. In addition, stormwater from North Eileen Avenue
would be intercepted and re-routed through the onsite
storm drain system. This would allow for
abandonment of the existing storm drain swale and
easement along the westerly boundary of the site, and
improved drainage for the area. These encroachments
would occur in compliance with City regulations. The
proposed changes would not substantially increase the
rate or amount of surface runoff in a manner, which
would result in flooding on- or offsite.
Thus, the Project would not conflict with this policy.
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General Plan Consistency Analysis
General Plan Goals/Policy/Actions Consistency Analysis
Our Well Planned Community
P 3.1
A 3.1
Preserve existing housing stock
Incorporate standards in the
development code to preserve the
existing form and character of
stable residential areas and
prevent encroachment of
incompatible land uses and
intensity.
Please refer to Response CBCM-6, below, regarding
discussion of the Walnut Grove Specific Plan as the
zoning for the proposed Project. The Project would be
required to comply with Section 26-547, Specific Plan
(S-P) zone, which includes guidelines and standard
requirements for design elements, such as orientation
of buildings and uses, building bulk and scale, building
height and setback, parking, and landscaping.
Therefore, this would ensure that the design of the
Project uses would be compatible with the
surrounding uses and the General Plan requirements.
Thus, the Project would not conflict with this policy.
Our Accessible Community
Transit
P 4.3
Establish protection of human life
and health as the highest
transportation system priorities
and seek to improve safety
through the design and
maintenance of streets, sidewalks,
intersections and crosswalks.
This policy applies to circulation systems throughout
the entire City, and the relevant elements of the Project
would not conflict with this policy. Safety has been the
central element in the design and planning of the
proposed Project, and it should be noted that the City
requirements have been integrated into the design. As
stated in Section 4.17, Transportation, of the IS/MND,
the on-site driveway, drive aisles, and cul-de-sacs
would comply with City roadway standards for
adequate sight distance (RR TRA-1). Also, to provide
the two access points from East Rowland Avenue to the
Project site, site visibility would be impaired if cars
were to be parked along East Rowland Avenue.
However, to address this issue, much of the curb on the
north side of East Rowland Avenue along the Project
frontage would be painted red to prohibit parking and
to provide sufficient site distance (PDF TRA-2). This
would provide site visibility for vehicles and other
roadway users and reduce potential hazards from
dangerous intersections. Therefore, with
implementation of the said planned improvements,
impacts from hazards due to a geometric design
feature would be less than significant.
Thus, the Project would not conflict with this policy.
P 4.4 Allocate street space equitably
among all modes.
This policy applies to circulation systems throughout
the entire City, and the relevant elements of the Project
would not conflict with this policy. The Project is
improving or constructing new public streets.
Policy 4.8 Implement “green” streetscape
elements for purposes of
beautification, carbon reduction
and stormwater runoff
management.
The conceptual landscape plan would include a
hierarchy of plant materials including trees, vines,
shrubs, and groundcover along the front yards of each
unit, throughout the Project site, and in open space
areas. Additionally, a 7’-6” wide HOA-maintained
5 | P a g e
General Plan Consistency Analysis
General Plan Goals/Policy/Actions Consistency Analysis
landscape area would be along the northern and
western perimeter of the site. The boundary to the
south would include trees and a parkway along East
Rowland Avenue. Also, the centrally-located park
would include landscape berms and open turf. The
comment speculates, with no evidence, that trees will
be removed as they mature and that the Project will
generate “heat island effects.”
The Responses to Comments on the Draft IS/MND
acknowledged that hard, dry surfaces such as roofs,
sidewalks, roads, buildings, and parking lots provide
less shade and moisture than natural landscapes and
therefore contribute to higher temperatures. However,
it should also be noted that heat island effect occurs as
a result of several factors (e.g., urban materials
properties, urban geometry, human activity, weather
and geology, and more) and not just lack of higher
percentage of landscaping (EPA 2021). Additionally,
the Project is too small in the context of an urban
metropolitan area that is the main generator of heat
island effect. The Project site is currently developed,
and more than half of the site is asphalt and includes
structures, and other development in the area are of
similar characteristics. Thus, the Project in and of itself
would not significantly contribute to heat island effect
in the area.
Thus, with these elements in place, the Project would
not conflict with this policy.
Our Active Community
Walk or
Bike to
Parks—
Policy 8.4
Small and frequent open spaces
should be dispersed throughout
the neighborhood.
The Project would have 100 sf of common open space
per unit (including walking and the neighborhood park
use). The single-family units would have a minimum of
150 sf of private open space per unit, and the multi-
family units would have a minimum of 100 sf of private
open space per unit. The common open space area of
the Project would consist of 0.27 acre of neighborhood
park use that would be publicly accessible for use.
Open space amenities would include bench seating
areas; picnic areas; children’s tot-lot area; open turf
area; connecting walkways; and mailboxes.
Thus, in light of the above, the Project would not
conflict with this policy.
Walk or
Bike to
Parks—
Action 8.4
Develop new neighborhood parks,
pocket parks, and community
gardens as feasible and
appropriate to meet citizen needs
and require them in new
development.
Please see discussion, above. Additionally, as stated in
RR PS-2, in Section 4.15, Public Services, of the MND, the
Project Applicant would be responsible for paying park
facilities impact fees for the development of new or
expanded park facilities in the City.
6 | P a g e
General Plan Consistency Analysis
General Plan Goals/Policy/Actions Consistency Analysis
Thus, in light of the above, the Project would not
conflict with this policy.
Housing Element
Goal 2 Provide a variety of housing types
to accommodate all economic
segments.
The proposed Project includes multi-family attached
and single-family detached units that will include a
range of price points. The project is consistent with
Policy 2.4, “Provide high quality housing for current
and future residents at all income levels to achieve a
‘balanced’ community.” There is no requirement that
each individual housing project in the City provide
units at less than market rates.
Goal 4 Promote equal housing
opportunity for all residents.
This goal applies to the entire City, and the relevant
elements of the Project would not conflict with this
goal. The Project contributes to a mix of housing types
and sizes available in the City and therefore promotes
the goal of equal housing opportunity. There is no
requirement that each individual housing project in the
City provide units at less than market rates.
II. The Project Requires an EIR
CBCM -3 The comment’s CEQA background description is noted. The comment asserts that the
MND for the proposed Project fails to adequately analyze the Project’s impacts
pertaining to vehicle miles traveled (VMT) and land use. Therefore, the comment
asserts, an EIR is required.
The City of West Covina appropriately determined that an MND is the appropriate
CEQA document for the proposed Project. The MND appropriately and adequately
provided accurate evaluations of potential environmental impacts associated with
the Project’s construction and operation. To address the potential impacts, the MND
proposed feasible mitigation measures to reduce the impacts to less than significant
levels. Additionally, the detailed analysis contained in the MND disclosed that the
Project would not result in significant impacts that could not be reduced to less than
significant levels and would remain significant and unavoidable for which an
Environmental Impact Report (EIR), and not an MND, would be required. In light of
this determination, an MND prepared in accordance with Article 6, Negative
Declaration Process (Section 15070 to 15071) of the State CEQA Guidelines was
deemed to be the appropriate CEQA document for the proposed Project.
The responses pertaining to VMT and land use are provided, below.
A. The Mitigated Negative Declaration Fails to Analyze the Project’s Vehicle Miles
Traveled, as Required
CBCM -4 The commenter provides a discussion of the Senate Bill (SB) 743 and points out that
a VMT analysis is required by State law effective July 1, 2020. The comment correctly
7 | P a g e
notes that the City adopted VMT as its metric for evaluating transportation impacts
under CEQA. The comment asserts that the MND failed to evaluate the Project’s
impacts related to VMT. It further asserts that the Transit Priority Area (TPA)
presumption does not apply to the Project and without a full VMT analysis the Project
cannot be adopted.
The discussion in Section 4.17, Transportation, of the IS/MND accurately describes
SB 743 and states the following:
State CEQA Guidelines Section 15064.3, subdivision (b) provides the criteria
for analyzing transportation impacts, and a project’s effect on automobile
delay shall not constitute a significant environmental impact. Generally,
vehicle miles traveled is the most appropriate measure of transportation
impacts. Vehicle miles traveled (VMT) refers to the amount and distance of
automobile travel attributable to a project. According to the State of
California’s Technical Advisory on Evaluating Transportation Impacts in CEQA,
“certain projects (including residential, retail, and office projects, as well as
projects that are a mix of these uses) proposed within ½ mile of an existing
major transit stop or an existing stop along a high quality transit corridor
would have a less than significant impact on VMT” (OPR 2018). The City of
West Covina recently adopted the use of Vehicle Miles Traveled (VMT)
analysis methodology for evaluating potential traffic impacts for development
projects. The Project is located within a Transit Priority Area (TPA) and is
exempt from a full VMT analysis by the City. Although there have been some
changes to transit service due to the COVID-19 pandemic, it was confirmed
that the Foothill Transit bus lines in the Project area are still operating as
usual. Therefore, the TPA exemption is still valid.
The Project is located less than ¼ mile from two major transit stops (Foothill Transit
bus lines 280 and 488) and is therefore in a Transit Priority Area (TPA).
City guidelines, consistent with the OPR Guidance, state that the presumption that a
project located within a TPA will have less-than-significant VMT impacts “would not
apply… if project-specific information indicates that the project will still generate
significant level of VMT” and states that “the presumption might not be appropriate”
in four cases OPR provided as examples (emphasis added). In this case, there is no
project-specific information indicating that the Project will still generate a significant
level of VMT, and the TPA presumption is appropriate. Each of OPR’s examples is
addressed below:
• Has a Floor Area Ratio (FAR) of less than 0.75: Not applicable to 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): The Project’s provision of
additional guest parking is appropriate, as explained in detail below.
8 | P a g e
• Is inconsistent with the applicable Sustainable Communities Strategy
(as determined by the lead agency, with input from the Metropolitan
Organization): This example is only applicable to projects of
statewide, regional, or areawide significance so is inapplicable to the
Project.
• Replaces affordable residential units with a smaller number of
moderate- or high-income residential units: The Project provides new
housing and does not replace affordable residential units, so this
example is not applicable. The comment is incorrect that the TPA
presumption is contingent on the provision of supportive or senior
housing.
Specifically, regarding the Project’s provision of additional parking, as explained in
the Responses to Comments on the Draft IS/MND, the additional parking provided for
the Project is appropriate and does not conflict with the City’s determination that the
TPA presumption applies. While the guest parking spaces provided exceed the typical
City zoning requirement, the additional parking is not expected to be used on a daily
basis. Further, the additional guest parking spaces are not expected to generate
additional trips or increase the VMT per capita for the Project. There is limited
parking in the area surrounding the proposed Project site. Neighbors in those areas
have already expressed their concerns about overflow and visitor parking on their
streets. In response to this concern, the Applicant modified the site plan to include a
solid wall, without gate or access, around the perimeter of the cul-de-sac on North
Eileen Street to prevent/discourage the future Project residents or their guests from
using the adjacent neighborhood for parking and external access to their units. In
light of this condition and to address the existing neighbors’ concerns, the Applicant
provided additional guest parking spaces. Additionally, the Applicant will add a
provision in the governing documents for the Homeowners’ Association that will
require residents to utilize their garages for parking, reserving street parking and
guest parking spaces for guests only. Owner vehicles in the guest spaces would be
subject to violation. This will ensure that residents do not own more than two vehicles
and will promote the use of public transit and ensure the guest parking spaces do not
result in an increase in VMT. Therefore, consistent with OPR Guidance, providing
additional guest parking spaces in this case does not disqualify the Project from the
TPA exemption.
Finally, note that the California Department of Transportation (Caltrans) reviewed
the Project and stated that the Project “is in a Transit Priority Area (TPA) and is
therefore exempt from a full VMT analysis.”
Thus, in light of the above discussion, the Project is located within a TPA, as
determined by the City, and an exemption from VMT analysis is appropriate.
B. Land Use Impacts
CBCM-5 The comment’s citations to case law regarding CEQA’s requirement to analyze land
use consistency are noted. The comment alleges that the MND for the Project does not
9 | P a g e
analyze the Project’s inconsistencies with the General Plan goals and. Please refer to
the table in Response CBCM-2, above, for responses to the specific inconsistencies
alleged by the commenter.
The comment further alleges that the Project is an example of “spot-zoning,” citing
Citizens of Goleta Valley v. Board of Supervisors (1990) 52 Cal.3d 553, 572-3 (“Citizens
of Goleta Valley”). The commenter loosely uses the term “spot zoning” without any
definition and without any explanation of how the Project would constitute “spot
zoning.” Citizens of Goleta Valley did not involve spot zoning. “Spot zoning” generally
refers to the creation of land use “islands,” where a small area is zoned differently
than the surrounding area and is illegal when the zoning “improperly limits” the use
of the island. Wilkins v. City of San Bernardino (1946) 29 Cal.2d 332, 341. However,
spot zoning describes a physical set of circumstances, and in and of itself is not illegal.
“Spot zoning may or may not be impermissible, depending on the circumstances. The
rezoning ordinance may be justified, however, if a substantial public need exists, and
this is so even if the private owner of the tract will also benefit.” Foothill Communities
Coalition v. County of Orange et al., (2014) 222 Cal. App. 4th 1302. There is no basis
for the commenter’s allegation.
The Project involves the adoption of a Specific Plan, which establishes zoning
requirements for a specific area within the larger City of West Covina General Plan
area. See Cal. Gov. Code §§65450-65457. The very purpose of a Specific Plan is to
establish zoning that is specific to an area within a larger planning area. Under the
commenter’s logic, all Specific Plans in California would be impermissible spot
zoning.
Lastly, the comment incorrectly states that the IS/MND failed to adequately support
its claim that the Project’s construction emissions would remain below applicable
South Coast Air Quality Management District (SCAQMD) thresholds and to provide
enforceable mitigation for these claims. The Responses to Comments on the Draft
IS/MND already responded to the earlier comments referenced in the comment. The
IS/MND provides a construction emissions analysis of the Project’s regional and
localized construction emissions in comparison with the applicable SCAQMD mass
daily thresholds (Table 4-5 of the Draft IS/MND) and the SCAQMD localized
significance thresholds (Table 4-7 of the Draft IS/MND), respectively. The Draft
IS/MND states that “the SCAQMD recommends that projects be evaluated in terms of
the quantitative thresholds established to assess both the regional and localized
impacts of project-related air pollutant emissions”. (Draft IS/MND at pp. 4-12 and 4-
13). Table 4-1, SCAQMD Air Quality Significance Thresholds, provides the mass daily
thresholds for volatile organic compounds (VOC), nitrogen oxides (NOx), carbon
monoxide (CO), respirable particulate matter 10 microns or less in diameters (PM10),
fine particulate matter 2.5 microns or less in diameter (PM2.5), and sulfur oxides
(SOx). Under threshold 4.3(b) of the Draft IS/MND, it states that Project emissions
were estimated using the California Emissions Estimator Model (CalEEMod) version
2016.3.2 computer program. The CalEEMod input for construction emissions was
based on the Project’s construction assumptions (as detailed in Section 3.5,
Construction Activities of the Draft IS/MND) and default assumptions derived from
CalEEMod. As stated in the Draft IS/MND, the outputs for CalEEMod quantification
10 | P a g e
outputs for construction emissions are included in Appendix A, Air Quality and
Greenhouse Gas Emissions Modeling, of the Draft IS/MND. As detailed in Appendix A
and Section 4.3, Air Quality, the entirety of construction activities for the Project were
quantified. Table 4-5, Estimated Maximum Daily Construction Emissions, presents
the estimated maximum daily emissions during construction of the proposed Project
and compares the estimated emissions with the SCAQMD’s daily regional emission
thresholds. As shown in Table 4-5, all criteria pollutants are below the SCAQMD’s
respective thresholds (page 4-18 of the IS/MND), included here from the Draft
IS/MND for ease of reference. In light of this findings no mitigation measures are
required.
TABLE ERROR! NO TEXT OF SPECIFIED STYLE IN DOCUMENT.-1
ESTIMATED MAXIMUM DAILY CONSTRUCTION EMISSIONS
Year
Emissions (lbs/day)
VOC NOx CO SOx PM10 PM2.5
2021 15 67 37 <1 7 4
Maximum Emissions 15 67 37 <1 7 4
SCAQMD Thresholds (Table 4-1) 75 100 550 150 150 55
Exceeds SCAQMD Thresholds? No No No No No No
lbs/day: pounds per day; VOC: volatile organic compound; NOx: nitrogen oxides; CO: carbon monoxide; SOx: sulfur oxides; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in
diameter; SCAQMD: South Coast Air Quality Management District.
Source: SCAQMD 2019 (thresholds); see Appendix A, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod model outputs.
Additionally, as detailed under Threshold 4.3(c) of the Draft IS/MND, localized
criteria pollutants from on-site construction were also quantified and compared to
the applicable SCAQMD localized significance thresholds. On page 4-22 of the Draft
IS/MND, Table 4-7, Localized Significance Threshold Construction Emissions, shows
the maximum daily on-site emissions for construction activities compared with the
SCAQMD localized significance thresholds. As shown in Table 4-7, the localized
emissions from the Project would be below the applicable thresholds, and no
significant impacts would result to sensitive receptors. No mitigation is required.
TABLE ERROR! NO TEXT OF SPECIFIED STYLE IN DOCUMENT.-2
LOCALIZED SIGNIFICANCE THRESHOLD CONSTRUCTION EMISSIONS
Emissions and Thresholds
Emissions (lbs/day)
NOx CO PM10 PM2.5
Project maximum daily on-site emissions 56 34 6 4
SCAQMD Localized Significance Thresholda 173 1,684 13 8
Exceed threshold? No No No No
lbs/day: pounds per day; NOx: nitrogen oxides; CO: carbon monoxide; PM10: respirable particulate matter 10 microns or less in diameter; PM2.5: fine particulate matter 2.5 microns or less in diameter.
a Data is for SCAQMD Source Receptor Area 11, South San Gabriel Valley, 25-meter distance, 4.5 acres.
Source: SCAQMD 2009 (thresholds); see Appendix A, Air Quality and Greenhouse Gas Emissions Modeling Data, for CalEEMod
outputs.
11 | P a g e
Furthermore, the Project addressed cumulatively considerable net increases of
criteria pollutants for which the Project region is nonattainment under an applicable
federal or state ambient air quality standards. As detailed on page 4-19 of the Draft
IS/MND, because the Project’s construction emissions are below the SCAQMD’s
regional and local significance thresholds, local construction emissions would not be
cumulatively considerable, and the impact would be less than significant. As such, no
mitigation measures are required. Because the Project’s estimated construction
emissions are below the SCAQMD’s applicable construction emissions thresholds, no
mitigation measures are required. Therefore, temporary construction emissions
were adequately analyzed within the Draft IS/MND.
III. The City Cannot Make the Required Findings for Issuing a Precise Plan Permit or a
Tentative Tract Map
A. Precise Plan Findings
CBCM-6 The comment asserts that the permit for the Precise Plan may not be adopted unless
the Project complies with a list of conditions. It further states that the City cannot
support several of the findings, including consistency with the General Plan goals and
policies, compliance with all adopted development standards, provision of
landscaping barriers (per Fabiola Zelaya Melicher’s letter), and parking in front of the
development. According to the commenter, granting the permit would allegedly
interfere with neighbors’ enjoyment and encroach on their privacy. The comment
refers to the neighbors’ comment letters.
The City has determined that the Project is required to obtain a Precise Plan permit,
and as such will evaluate the conditions in light of what is proposed and make an
informed decision based on their findings. It is speculative to assume that the permit
may not be adopted. No further response is required.
Regarding the finding of inconsistency with the General Plan goals and policies, please
refer to Response CBCM-2, above.
Regarding lack of compliance with development standards, it should be noted that
the Walnut Grove Specific Plan is proposed as a planning tool that is established
through the authority granted to the City of West Covina by California Government
Code, Title 7, Division 1, Chapter 3, Article 8, Sections 65450 and 65457 (Specific
Plans). As such, the Walnut Grove Specific Plan can set the parameters for the
proposed development, including distribution, location, extent, intensity of land uses,
building setbacks, building height, lot coverage, and landscape requirements. The
purpose of the Specific Plan is to establish guidelines and standards specific to that
Project to guide the development. These provisions would achieve the vision of the
Project and are consistent with the requirements of the Government Code governing
Specific Plans, cited above. Accordingly, the Project is required to and will comply
with the development standards contained in the Walnut Grove Specific Plan, as the
zoning document for the proposed Project.
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Regarding neighbors’ comments, it is acknowledged that the City received a number
of comments from the surrounding property owners and provided responses to their
comment letters on the Walnut Grove IS/MND. The issues of privacy and landscaping
have been addressed in those responses.
B. Tentative Tract Map Findings
CBCM-7 Similar to the comment on Precise Plan, the commenter asserts that the tentative
tract map may not be issued unless the Project complies with a list of conditions. The
comment makes an assumption that the City will not be able to make the required
findings due to the Project’s alleged inconsistency with General Plan policies and
goals.
The City will evaluate the conditions for a tentative tract map in light of what is
proposed for the Project and will make an informed decision based on their findings.
It is speculative to assume that a tentative tract map may not be issued. No further
response is required.
IV. Covina-Valley Unified School District’s Transfer of the Pioneer School Property May
Violate the Surplus Land Act
CBCM-8 The comment states that the proposed Project would transfer school district land to
a private developer and then to individual homeowners, prior to compliance with the
Surplus Land Act. The comment is noted and will be forwarded to the decision
makers. The commenter then provides a detailed description of the Surplus Land Act
and its requirements.
The comment also asserts that the district has not offered the site for purposes stated
in Government Code Section 54222. Additionally, it states that the district while
claiming that they are conducting an “exchange” has not identified exchange
properties.
First of all, it should be noted that the issue of transfer of the land violating the Surplus
Land Act is not a CEQA issue, and as such no further response is required. Second, the
district is a separate entity and comments pertaining to the actions of the district
allegedly violating the Surplus Land Act cannot be addressed by the City. The City has
received a letter from the Covina – Valley Unified School District addressing this
comment and significantly, the exchange agreement between the District and
Developer was validated by the Superior Court. Quoting from that letter “Specifically,
the District sought and received a judgment from the Los Angeles Superior Court
pursuant to California Code of Civil Procedure section 860 which allows public
agencies to seek an order from the court “validating” specific actions that the public
agency takes pursuant to applicable law. Through this validation action, the District
obtained a “validation judgment” which explicitly finds and declares the Exchange
Agreement with Lewis to be in compliance with all applicable laws, specifically,
including Education Code section 17536.” (see attached letter from Atkinson,
Andelson, Loya, Ruud & Romo, dated April 15, 2021)
13 | P a g e
Conclusion
CBCM-9 The comment regarding incorporating the letter by Fabiola Zelaya Melicher, dated
December 21, 2020, is noted and will be forwarded to the decision makers. The City
prepared detailed responses to the said letter. No further response is required.
ATTACHMENT
Exchange Agreement Between Covina-Valley Unified School District and
Lewis Land Developers, LLC
Letter from Atkinson, Andelson, Loya, Ruud & Romo
April 15, 2021
From: Kristine Frey <freykristine@gmail.com>
Sent: Monday, April 26, 2021 10:38 AM
To: Jo-Anne Burns <JBurns@westcovina.org>
Subject: Re: Pioneer site -- EIR? Council Meeting Date?
CAUTION: This email originated from outside your organization. Exercise caution when opening
attachments or clicking links, especially from unknown senders.
Thank you for this information, Jo-Anne.
I would like to request an EIR, per CEQA, SB 743, New Section 15064.3, and to review that data prior to
approval of the lead agency (West Covina City).
Working with the Traffic Division, I have requested traffic data analysis. On Rowland a few weeks ago,
they put out traffic speed recorders. I also requested a traffic study on Leaf and Rowland. This is data
that qualifies for our review per SB 743, New Section 15064.3. Determining the Significance of
Transportation Impacts, (b) (3) "Qualitative Analysis. If existing models or methods are not available to
estimate the vehicle miles traveled for the particular project being considered, a lead agency may
analyze the project’s vehicle
miles traveled qualitatively. Such a qualitative analysis would evaluate factors such as the availability of
transit, proximity to other destinations, etc. For many projects, a qualitative analysis of construction
traffic may be appropriate."
We should have the opportunity to review the data in an EIR, per CEQA, especially given that the
IS/MND posted said the main culprit on air quality will be by cars on the road having an impact on air
quality. I'm sure it's not just speed they tracked, but a traffic count, as well, giving us an idea of impact
on air quality.
I look forward to your response. Thank you.
Kristinev
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Kristine Frey
Comment Email Dated April 26, 2021
Walnut Grove Residential Project
The general comment regarding the commenter’s concerns about the proposed Walnut Grove
Residential Project is noted and will be forwarded to the decision makers. It should be noted that
in accordance with the State CEQA Guidelines, Section 15073, the Draft IS/MND was circulated
for a 30-day public review beginning on November 19, 2020 and ending on December 21, 2020.
During that time, the Draft IS/MND was available at the City of West Covina website. In light of
this, it should be acknowledged that this comment letter was submitted four months past the
end of the review period. Nevertheless, the following responses are prepared to address the
comments.
The comment primarily asserts that the impacts of the Project pertaining to
transportation and air quality should be analyzed in an Environmental Impact Report
(EIR). To determine the appropriate level of environmental review, the City prepared an
initial study for the Project. The primary function of an initial study is to provide the lead
agency with information to use as the basis for deciding whether to prepare an EIR or a
negative declaration. 14 Cal Code Regs §15063(b)(1). The City then determines, based on
its initial study, that the project may have a significant effect on the environment and that
an EIR is therefore required. If the study shows no substantial evidence that the project
may have a significant effect on the environment, the agency must prepare a proposed
negative declaration, which is then circulated for public review and comment. 14 Cal
Code Regs §§15070(a), 15072–15073
The City of West Covina, based on the initial study, detailed analysis and substantial evidence,
determined that a Mitigated Negative Declaration (MND) is the appropriate CEQA document
for the proposed Project. The MND conducted detailed analysis and adequately provided
accurate evaluations of potential environmental impacts associated with the Project’s
construction and operation. To address the potential impacts, the MND proposed feasible
mitigation measures to reduce the impacts to less than significant levels. Additionally, the
detailed analysis contained in the MND disclosed that the Project would not result in
significant impacts that could not be reduced to less than significant levels and would remain
significant and unavoidable for which an Environmental Impact Report (EIR), and not an
MND, would be required. In light of this determination and based on the initial study and
analysis, an MND was deemed to be the appropriate CEQA document for the proposed Project,
and the MND was prepared in accordance with Article 6, Negative Declaration Process
(Section 15070 to 15071) of the State CEQA Guidelines..
Regarding compliance with SB 743 and Section 15064.3, Section 4.17, Transportation, of
the IS/MND accurately describes SB 743 and states the following:
State CEQA Guidelines Section 15064.3, subdivision (b) provides the criteria
for analyzing transportation impacts, and a project’s effect on automobile
delay shall not constitute a significant environmental impact. Generally,
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vehicle miles traveled is the most appropriate measure of transportation
impacts. Vehicle miles traveled (VMT) refers to the amount and distance of
automobile travel attributable to a project. According to the State of
California’s Technical Advisory on Evaluating Transportation Impacts in CEQA,
“certain projects (including residential, retail, and office projects, as well as
projects that are a mix of these uses) proposed within ½ mile of an existing
major transit stop or an existing stop along a high quality transit corridor
would have a less than significant impact on VMT” (OPR 2018). The City of
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West Covina recently adopted the use of Vehicle Miles Traveled (VMT)
analysis methodology for evaluating potential traffic impacts for development
projects. The Project is located within a Transit Priority Area (TPA) and is
exempt from a full VMT analysis by the City. Although there have been some
changes to transit service due to the COVID-19 pandemic, it was confirmed
that the Foothill Transit bus lines in the Project area are still operating as
usual. Therefore, the TPA exemption is still valid.
The Project is located less than ¼ mile from two major transit stops (Foothill Transit bus
lines 280 and 488) and is therefore in a Transit Priority Area (TPA). Also, please note that the
California Department of Transportation (Caltrans) reviewed the Project and stated that the
Project “is in a Transit Priority Area (TPA) and is therefore exempt from a full VMT analysis.”
Thus, in light this, the Project is located within a TPA, as determined by the City, and an
exemption from VMT analysis is appropriate.
The comment also states that “the main culprit on air quality will be by cars on the road having
an impact on air quality.” Section 4.3, Air Quality of the IS/MND acknowledged that,
Operational emissions associated with the Project are comprised of area,
energy, and mobile source emissions. The principal source of VOC emissions
associated with the Project would result from vehicle trips. . . Mobile source
emissions are based on estimated Project-related trip generation forecasts, as
contained in the Project traffic impact analysis. The Project would generate
1,124 daily trips (Psomas 2020). The peak day operational emissions for VOC,
NOx, CO, SOx, PM10, and PM2.5 daily emissions that would be created from
the Project’s long-term operation have been calculated . . . The data provided
in Table 4-6 shows that none of the analyzed criteria pollutants would exceed
the regional emissions operational thresholds. Therefore, a less than
significant regional air quality impact would occur from operation of the
Project [emphasis added]. No mitigation is required.
Thus, in light of the above, an MND appropriately analyzed the potential impacts pertaining
to air quality, as no significant, unavoidable impacts would result that would require
preparation of an EIR.
The comment regarding data analysis and traffic speed recorders on Rowland Avenue and a
traffic study on Leaf and Rowland Avenue is not relevant to the proposed Walnut Grove
Project, and as such no response is required.
ATTACHMENT NO. 13