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20141202 Late CorrespondenceRECEIVED FROM a.Wn !ilJ?(d01\ ,,~\1:, AND MADE A PART OF THE RECORD ATTHE: COUNCIL MEETING OF 1).. / :i.. / 1+ CFP!CE o~ rn~ O!TY GLERK QAf'll,.A .M§fi~E!AbE. CJrY CLERK Subject: Marymount -City to Resume Processing the Atheltic Field Reconfiguration Project cm TO RESUME PROCESSING THE ATHLETIC FIELD RECONFIGURATION PROJECT On September 9, 2014, the City recelved a letter from Mr. Davis, legal counsel for Marymount ca11romia University, requesting the City resume processing Marymount's application to reconfigure the 2010-Coundl approved Athletic Reid (CUP No. 9 Revision "E"). The processing of the application was placed on hold in February 2014 at the request of the University to allow additional time to respond to questions pertaining to the netting raised at the January 21, 2014 City Council meeting on the Draft MND . The September 9th letter includes new/additional Information regarding the application request, such as requesting to Install permanent netting rather than retractable netting and the offer to Install a mock·up of the proposed netting. Oick here to view the September 9, 2014 letter from Mr. Davis Staff is reviewing the submitted information and developing a tentative processing schedule which will posted on the City's website within the next few weeks. Inqui ries should be directed to Ara Mihranian , Project Planner, at 310-544·5228 or via email at aram@rgv .. com ~ ·-'~ . ..... , 11/24/2.014 1. You already Did! RESOLUTION NO. 201G-14 A RESOLUTION OF THE CfTY COUNCIL OF THE CITY OF RANCHO PALOS VERDES TAKING A UNANIMOUS POSmON IN OPPOSITION TO THE MARYMOUNT INrnATIVE CERTIFIED FOR THE NOVElmER 2. 2010 BALLOT. Whereas, the Marymount Initiative, a voter eponsored lnltiallva pniparad by Marymount College, a private liberal arts college, waa aubmlttsd ID the City Clerk on Tuesday March 2, 2010: Whereas, Iha City recognizes the right of the votera to use the Initiative proce18 when it is used to advance the public health. l8f8ly and welfare: Whlnaa, on June 3, 2010, the City Clerk certified that aufllctant signatures on pellol'8 Md been oblalned to quaHfy the Initiative for a special election: Wheran, the City Council, at a public meeting on June 15, 2010, Ofdered a special election to be held on the Initiative and consolidated the special election with the November 2. 2010 election; Whereas, on June 15, 2010, the City Council received a report on lhe differences between the Marymount lnltlatlve and the City Council-approved plan for the expansion of the M8fYm)Ont campus. That evening. the City Council received additional staff reports, presentations, updates and extensive public comments thereon: Whereas, the City Council held a duly noticed public meeting on June 15, 2010, to cons5derwhether or not to take a-position on the MaiYmount measure in light of the difrerences between the Marymount~sponsored Initiative and the Marymount plan approved by the City Council and the effects of each upon the community; 0) The Initiative wauld return tM Alhletlc Field to ... original location sixty fMt farther to the w.t, rwmovtng th• bufr9r. E) The lnlllallve Ellml...._ CondHlona lmpoMd to Minimize Neptlve Coll9equencn Of the Pro)ect on the Rnldenta. In order to protect the residents of the City, the City Council imposed conditions to mitigate negative impacta of the Marymount expansion plan. Soma of the mitigation measures are modified or eliminated by the lnlliatlve, to the harm of the residents of the City. C!tV to Resume Processing of the Athietl( Field Reconfiguration Proiect 2 5.City's General Plan Policy No. 14 prohibits encroachment on scenic views 4124/2014 5.4.2 The City's General Plan includes the followmg policies: "Urban Environment Element lnstitutiona.I Activity Policy No. 6 -Review the loca.tion and site design of future lnstib.ltional uses very carefully to ensure compatibility with adjacent uses ; Urba n Environment Element Residential Activity Policy No. 14-Prohibit encroachment oo existing scenic views reas onab ly expected by neighboring resid en1s; Uman Environmen t Element Residential Activity Policy No . 15-Enforce height controls to further lessen the possibility fOI' view obstructions ; Urban Environment Element Reaeational ActMly Polley No . 11 -Encourage publ.le use of institutional reaeation raclllties wh ere possible .• 5.4 .3 The conditions placed on the use of the netting, including the limitation on hours of use and the retractable nature of the netting , support the General Plan policies cited in the previous finding . 5.4.4 The proposed athletic field net and tennis court fencing are not contrary to the General Plan . This finding can be made. C :ty iO Resurne Processing of thti AthlPt1c Field Reconfornration ProJett 6 6. "The site is of adequate size to accommodate an athletic field .. provided that it is moved further to the east, with two tennis courts on either side, because a field so configured, would not result in safety impacts." li24/2 2.1.9 The athletic field and tennis courts are set into the grade thus reducing their visibility from neighboring properties and from the public roadway. Although the retaining walls for these facilities exceed the height limits established by the Development Code , the additional Grading Permit findings can be made , as discussed below, to warrant approval of the facilities. 2.1.10 The City Council finds that the site is of adequate size to accommodate an athletic field in addition to the other components of the project, provided that it is moved further to the east, with two tennis courts on either side, because a field so configured, would not result in safety impacts on Palos Verdes Drive East. 1229056.4 C1tv to Re'.ume Procec;smg of the Ath1et1 Resolution No. 2010-42 Page 6 of 31 7.CUP Condition 7 requires compliance with the approved ''D-2'' Athletic Field Plan 6) The project development shall conform to the specific standards contained in these Conditions of Approval or , if not addressed herein, shall conform to the appropriate devetopment and operational standards of the Rancho Palos Ven:tes Municipal Code \RPVMC1. 7) The project. inciuding stte layout, the building and appurtenances, and signage throughout the site , must be constructed and maintained in substantial compliance with the plans reviewed and approved by the City Council , on March 31 , 2010 and May 4, 2010 (Athletic Field Altemative 0-2}, and stamped APPROVED by the City with the effective date of the Notice of Decision . Prior to any submittal to Building and Safety. the applicant shall submit to the Community Development Director a complete set of the revised plans (such as , but not limited to , architectural , grading, landscaping, and lighting plans) that reftect the Council's final decision. ,..AA'T lAL. ~Ile P\.Al" S£JrrLE> 1•.eo·-c• ~ .......... ,~.._....:..,.. .. *' !A/20 ~COlLEGE f.\CUTIES EXPANS IOfl PRO.ECT 1 & ll.\CHEl.O.Ol'AAl$OEGA!f-.W ·a~-•o '-'-'·· i =--Athletic Field Altematlve ID. D·2 Detai led Site ,._ , EtillllllH Cirv [O Resun1e Processing of the A.thlt~[ic l=!efd f~cconffgdr.at~o ··: Proje~:.t g 8.Marymount defaulted on their Approved Athletic Field entitlement and it is gone now Don Davis said "notwithstanding the expiration of Phase 1, the applicant has the ability to construct an athletic field if the currently requested CUP amendment is approved by the City Council." On May 7, 2013 City Attorney Carol Lynch Rejected Marymount's arguments that their application of October 12, 2012, provides the ability to construct an athletic field despite project-imposed (Condition 60a) time limits. (Lapsed September 30, 2013!) It is important to note that on September 30, 2013, Phase 1 of the Marymount Facilities Expansion project approved by the City Council in June 2010 expired. Phase 1 included, among other things, the construction of a new athletic field. The current application to reconfigure the 2010 approved athletic field was submitted to the City in October 2012, prior to the expiration of Phase 1. Thus, notwithstanding the expiration of Phase 1, the applicant has the ability to construct an athletic field if the currently requested CUP amendment is approved by the City Council. · .l..-41 2~/.20.i.4 C'.tv to Resurne Proct::s·-:infl of the A.thietlC Fieid •.:teconfigurat;o11 Pro!ect 9.Testimony to City Council regarding Errant Balls in his yard April 17, 2012 refutes Application • Staff is also well aware of testimony given on April 17, 2012 by neighbor Mike DeNardo, (to Council member Jim Knight), that his real life experience with the adjacent Castle Field use by Marymount students resulted in "enough soccer and lacrosse balls that could fill this Room": JUST SAY NO! [] • This direct evidence contradicts the anecdotal review conducted in rhe IS MND (Errant Balls ) that seeks to demonstrate otherwise - • Just take a look at the trees and Nets protecting Mike 's home (righ t ) from the invas ion of all those room-filling errant balls - 1!/ 24. 2014 ..:lty to Resume: Processing of the Athletic Field Reconf1£1.uration Pro1ect _Q 10.Mitigation Measures AES-5 and TR-9 are not replaced (as CEQA requires) with equivalent or more stringent measures in th~--~:~ised Field As:ation . .;:"·~·,~ 'n • lilloltyml;)Ont c~a.g* Fit,1ttl~ &p~n•ion PJot-tl .............-. En .. ·ira11memallmp.c1 A•JWl1 ~ il&-__ ----------- Wil'9ii'U\~,. 4 -... _,..... -.. ........ ---~ .. .._. .. ~, J •11t.ta. O.U. RenWI' .. ~ hr.M •M ~> lk .;'Oi l> 1ty to Re~ume.: Proce--:.c,1ng of the Athlet1 F1elct Reconfiguration Pro1ect " -... .....tlllf~ --~ ltft.otutlo111*'.l01~ Emfo;rt • j;"; W..l')'ITI OU llLCol}eg• F•cllhlcS E1.p•11sl o 11 Pro~f Env1r o 11mel\lal ltnoo1(.'.r R&pa l1 ....... Vt..i ... lttllUld~~ ---......... 1'.11.lv ~' MtlpU~ Mor11tt111ac-.i Anpor1:1rtff'locram "I 11. BONUS! has Marymount August 26, 2010 without ANY Athletic Field Athletics • since ~~ ~ Men's Soccer Schedule --Thl..ol'1.A'"f,.l.6&:tl fll'lbrt-fllGdk'~r-t~ MOl".Al..lol.Dil ~lll~Uf'M"ffS•t'r l'r: Sc'" .~~ ~SQUl/~~it,mer114 s.t~llrl\ (J ~nCkttp(hmlf,,..,CdleiJt ~~ S.pl l.4iJ~ @ W1ilwri lf'~\Oolll \J~t~ 5~~-l&u. ft\J1~rOU1'1.Mef"S«V luH Sept Jttl ~...,.'foll(WO>.l!JA......-ii('f TNin. S.p~ lln! ~~"'~ 5',ir:t~pl.J6th t.l..-,.1u"'-"'"il !wl Oct l/1{! f!t £mD,.,..~ ~W'~. AZ ~r.Ocl-lt.'VI It ~I S.f.11 a. Uti...er\o'f\i 7hl.in.On l.tth ~lftv.\)fGfG1.F-.-.~1f!tSl.)l(A} s.t Ocl l3nJ ~~t~~(.Qol~J.I -""""' (l~t ~teUnN ~lol.Jl(O'I. t:r1Ckt ~ ~U'llwr-..tro1.trnt11Ui --l-00~ ?:00.om 7 OOpm 5.31111"11 Jt-.:lptr> '""'"' .;.;30:~ '"""" 7:00pni !:OO~m ll.OOMn ""'""' '""pm lOOpt'\ 100~11'r 2014-2015 MEN'S SOCCER SCHEDULE .. ,.., llMSlERlii COU.K.t: \CAi..f': \/~~..,.,.­ ~\ -.. ~ c:.i.uF(RM !l 4TI: ~---= ~SlATE ~~~ ~ ~" -.iTMIU. .,., ~-­-""""' "" """""' -"""" '2..l ""'"""' ,_._, L l -2 ""'""'" _ _.... """"'" -"'""' -.:;iJ ... -- W•-O """""" -"""' w .. ~ ...... ~ ......... "'"" ~~ ~~il-. \.1a1 irn.:r:-. ,;l ._ """' ..,,., CAL PAC been playing NAIA to the Present day "'14'015 WOMEN'S SOCCER SCHEDULE -...,, - ."Jt~a~ ~SQ.·~~ """"""" .... ~~~~ ,=- OIOl.A~.":Jil#.1 ~'""'°"';.,~Mil.'!); U~llf'~f ··~ fttt ~.:.£Q-()loiflollon0 (:' ll··~~._..all.MC)~n' ~·) ~~~1.::...:.s , I ~ llllOll.t:lb'.lu.LG~, o~~~ """" - --=-~ ....., -- w ?• -- u• ---~ ""' ---~ "'.!.--- ~:.~ w>• ~­--·=- ~~~ 'ilCALF ) '1.IF i """"" ACOO ~ .......,., ;( CAtPAC GAIETOSE ""5C>Ell.LEO ""' L1-2 :.-- ~ 11/24/2014 .... o Resume Procec;~1ng of the Athlet1 Fi~ld P.econf1gurC,t1on Pro1e 1.2 Marymount Athletic Field Expansion Project Initial Study-Mitigated Negative Declaration fragments between the L.A. airport and Palos Verdes, the airport is the largest remaining site where the species is found. Per recent communications with Richard Arnold (El Segundo Blue Butterfly lO(a)l(a) Permitted Biologist), neither ashy-leafed nor California buckwheat provide suitable habitat for the butterfly. Given the lack of suitable host plants within the project site, this species is considered to have a low potential to occur. Monarch butterflies may use the eucalyptus trees onsite for perching; however, given the low number of trees, sparse canopy cover, and location on an unprotected hill, the trees do not provide the protected wooded habitat required of overwintering/roosting sites. Coastal One occurrence (CNDDB Occurrence 338) is tracked approximately 2.5 miles southeast of the project site; however, the roost site was lost when trees were removed circa 1985. TI1e potential for monarchs to breed onsite is low, given that the species is dependent on milkweed plants (Asclepias spp.), upon which they lay their eggs. No milkweed species were observed onsite during the site reconnaissance survey. Given the lack of suitable roosting/ overwintering habitat and a lack of host plants within the project site, this species is considered to have a low potential to occur. Native birds protected by the FGC and MBTA are expected to nest within non-native and native vegetafion onsite. The proposed project would include removal of non-native and native vegetation including a small grove of eucalyptus trees at the southeast comer of the athletic field. Potential direct impacts (loss of inctividuals) could occur to birds nesting onsite if the disturbance/ clearance of nesting habitat occurs during the breeding/ nesting season. In addition, indirect impacts such as construction noise, dust, and other human disturbances may deter breeding/nesting behaviors if construction occurs during the breeding/nesting season. A 30-foot high retractable net would be installed along the north, west, and south sides of the field. The athletic field would be below grade and the netting would extend 13 to 22 feet above the grade of the slope surrounding the athletic field and would be erected when there is a possibility of errant balls or objects leaving the field during use. When not erected, the netting would be enclosed in storage containers. When fully extended, the netting would have holes approximately 1.5 square inches in size and would. be of a moderately heavy gauge so that it is visible when erected. The field would not have _exterior lighting so nets would be used exclusively during daylight hours. Given that the netting would be visible to wildlife, would be used intermittently only during daylight hours and would be completely contained when not in use, the netting is not expected to entangle wildlife. Based on the discussion above, the project would have a potentially significant impact on nesting birds. Mitigation Measure BI0-2 from the previously Certified FEIR requires that a pre- construction nesting bird survey be conducted prior to the onset of construction activities (including vegetation removal) onsite. Although the project is not expected to impact special status species, BI0-1 from the previously Certified FEIR requires that a general preconstruction survey must be conducted and must focus on sensitive species with potential to occur onsite, specifically butterflies. The proposed project's potential impact related to special status species would be incrementally greater than those of the approved project studied in the Certified FEIR, due to the slightly larger area of disturbance and removal of non-native trees, and would be potentially significant. However, like the approved project, impacts would be less than significant with implementation of Mitigation Measure BI0-1 from the Certified EIR and Mitigation Measw·e BI0-2 from the Certified FEIR as modified below. City of Rancho Palos Verdes 55 Marymount Athletic Field Expansion Project Comments and Concerns with the Revised Draft Initial Study-Mitigated Negative Declaration (IS/MND) EXECUTIVE SUMMARY Based on RPV's Letter to President Michael Brophy of March 8, 2013, initiation of any EIR Review Process is inappropriate based upon 1.) Marymount's continued failure to comply with required information submittals as listed, and 2.) the lapse of Phase I components post September 30, 2013, described in Condition No. 60a, "those uncompleted items become null and void and cannot be completed as part of the following phase. (August 2, 2011 City Council Staff Report) 1. There is no Field to modify. There is no Master Plan remaining. Start over, a single element of an overall plan cannot be broken into bite-sized pieces for isolated environmental review (Orinda, et sec.). 2. Marymount President Brophy, in an exchange with Councilman Doug Stern on the evening of March 30, 2010, acknowledged that the modified (approved) field is actually safer than the one Marymount proposed and would accept if it came to a denial of any field. llPage PARTIAL 511C PLAN SC.ALE• 1"•60'-0' Source: Rasmussen & Associates, September 28, 2009. I i t I ) \ \ \ I \ MARYMOUNT COLLEGE FACILITIES EXPANSION PROJECT BACHELOR OF ARTS DEGREE PROGRAM• EIR APPENDIX D ~ Athletic Field Alternatlve No. D·2 Detailed Site Plan CDN•ULTINQ Exhlblt21 21Page March 30, 2010 City Council Hearing Councilman Doug Stern asks Marymount President Michael Brophy, which Field is safer? (Video Log times in parentheses) Councilman Stem: (03:36:37) "Now let me try again. Does Marymount have a view as to whether the original (field) location -the one that sites the athletic field closest to PV Drive East -is safer than the modified plans which would move it an additional 60' -the one we saw most recently?" Dr. Brophy: "In the second plan there is no need for netting." (03:37:11) Councilman Stem: (03:37:25) "Would you have a view if we said we move it 60' away from PV Drive East and require netting have a view as that is a safer outcome than you have proposed in your original plan? (03:37:42) Dr. Brophy: I think that you would find after 2 hours (of PC hearing time) you get to the place where that would need to happen, if an appeal would be denied, the answer is yes." (03:37:55) And that is what was approved in Resolutions 2010-41 & 2010-421 • On May 7, 201 3 the City Council was asked to approve and initiate a Professional Services Agreement without disclosure that Marymount had failed to provide the required grading information associated with the Master Plan Phasing: 11 The College's January 25, 2013 submittal raised a concern with the proposed grading as it relates to the Campus Master Plan as a whole." Specially, the proposal to export 17,625 cubic yards of earth, which, according to the approved grading plan was to be 31Page repurposed on-site for the Campus Master Plan, raised the question as to how this revision affects the overall project." , and any justification or basic rationale for importing/exporting grading materials contrary to Condition 67 has not been provided by the 15/MND, contrary to CEQA. • The Professional Services Agreement (PSA) with Rincon Consultants, is premised upon Marymount College's Application for a Revised Athletic Field Dated October 29, 2012 as prepared by Joel Rojas, Director of Community Development and approved by RPV City Manager Carolyn Lehr in the May 7, 201 3 Staff Report. • On page 2-42, thereof, the Service Agreement states that "Marymount seeks the following three revisions to its current Conditional Use Permit .. " • FACT: Marymount actually sought four Revisions, not three! 41Page Rancho Palos Verdes City Council Meeting May7, 2013 Th is is a significant change MAJqMQUNT COLLEGE CA15PUS MASTER PL.AN PROPOSED REV1819NS TO TttE PLANS FOR THE ATHLETIC FIELD AND A REQUEST FOR EXIENBIONS OF THE APPROVAL PERIODS FOR THE REMAINING APPROVED FACILITIES ALONG WITH OTHER MINOR MODIFICATIONS JO THE llARYMOUNJ CUP (Propoud Rev191on "F" lo CUP No. t) You cannot Un-ring this Bell! IDlmlllllillllD MwymounlCcllege II _king lour-1 lo Ila IU18ftl C'"1dilionll UM Permit No 9 rcuP") •PPfCMld by .,.. Cly In 2UTD .. Rrmlon "E"" ID Ille CUP. Fllll, Mlrymounl Is P-'"11 lo remoYI lhll lour lsnnll COUlll opproved lot Ille wetlam por1lon ol lhe -In Ofder lo -rge lhe ploying .... """" rnulti-iMJrpooe ·--r-Flold"l onc1 to -. ""' 1U11aco '"""'"" o1 ""' -F1oJc1 rram "'"""' -to oynthollc turf. second. Mlryn10lllll ls ~ 1n --l lo CUP ~ o1 Applavll No 138 lo -up lo 11n1 ovon1t (indUOlng 1J!W1U811on ........-) wilh omplifiod IO<ll1d on lhe -Flokl under llt onnull Speoill lJle Ponnll TNnl, Morymount 1a ~ 11111 "'" amo Plf1odo or lho opproYlls 1o -iah-1JClstingllcililieland_lhe_llJll'fO'l9d __ Conditloo ol App<ovll No. 80 bo revised lllhough lhe actual overlll C0111truction time period l'orlle c:onotrucllon-wil 1111111in II lhlfly·llx(36)-Flnllly, Mllymount Is niquntlng I millon lo l1o WMllng ol Condition ol Approvol No 711 to fllOl9 acantoly -lho llrnilotion on ltnJClurel tor prlmlry occtlP"lley In lhl - <leologlc Selbld< AIM • Specifically, (the missing revision requested is) "Marymount is requesting that the time periods of the approvals to demolish certain existing facilities and construct the new approved facilities under Condition of Approval 60 (a) be revised .. as Phase One B .. (that) includes demolition of existing buildings, further grading .. and .. the .. athletic field. that shall be completed no later than September 30, 2020." Rancho Palos Verdes City Council Meeting _______ ... .,... • .....,...,..... Ma 7 2013 _ .... _ ... ________ y ' ._ ..... ,.... ......................... -.... ,,. --~~--.. ~~ ................... ..... ·-:-.:=:=:.= .. --·· This is a Significant Change .......... _ ............. ..... . ,.,.,_ ....... ~_... .... ~..---............. .............. ._ ... ,... ..... _.. __ _____ ltft:J_.........., .. ~---- "~ "-D9 11w-~, "-CIN IL.._ __ ., __ ..... ~ .. B..!IUCU~ .. -..... ~ .... --..... --. New proposed Phase One A and Phase One B ........ _ o -~ .. .. •• IO .. IO "° ... ... ... ... • Phase One B extends two years beyond the 8 year end date approved in 2010. The Library completion date (new Phase Two) is shifted by 1 3 years and Athletic Building completion date (new Phase Three) is moved by 1 8 years to (respectively) Sf Page September 30, 2025 and 2030. A Mitigated Negative Declaration (MND) is inappropriate as it fails to address the overall project environmental impacts. • A subsequent Application, submitted January 25, 2013 by Marymount College, removed this re-Phasing request. A later letter from Don Davis to RPV Staff dated February 27, 2013 (on pages 3 & 4) acknowledged that the College fully intends to proceed with (Phase 2 and 3) entitlements "regardless of any actions taken or not taken by the City Council on or before September 30, 2013, with respect to any remaining Phase 1 grading." • As referenced in a recent Court Decision, Katzoff v. California Department of Forestry, Filed 1/28/2010, in Orinda Assn v. Board of Supervisors (1986) 182 Cal.App.3d 1145 (Orinda), at pp. 1145, 11 71 .); "A public agency is not permitted to subdivide a single project into smaller individual subprojects in order to avoid the responsibility of considering the environmental impact of the project as a whole". The requirements of CEQA "cannot be avoided by chopping up proposed projects into bite-sized pieces which, individually considered, might be found to have no significant effect on the environment or to be only ministerial." (Ibid.) (Continues) "If demolition could be segregated from other development activities and made non-reviewable, the requirements of CEQA would be voided altogether ... " (Id) 6IPage • "Several points in Orinda are significant here. First, Orinda states the well-established principle that a project cannot be divided into smaller parts that individually will not have a significant effect on the environment. Second, this rule is applicable even if one of the smaller parts might require only ministerial, rather than discretionary, approval. Third, where conditions are imposed on a project, those conditions-and the policies behind CEQA-cannot be avoided by applying for another approval apart from the larger project. (Orinda, supra, 182 Cal.App.3d at pp 11 71-11 72.)" • City Staff has been well-informed of the consequences of Marymount's failure to complete all remaining Phase 1 entitlement components by the extended deadline of September 30, 2013, at which time such uncompleted entitlements, including grading, became "null and void" as shown in Staff's May 7, 2013 Recommendation. 71P age Staff Recommendation • deny the Phase 1 extension request, thereby voiding all the construction related planning entitlements for Phase 1 of the Facilities Expansion Project with the exception of the permanent Parking Lot Expansion Project, which is a vested construction project that is currently underway, and documenting the City Council's decision on August 2, 2011, which clarified the operational conditions that remain in effect. • The extension in the above Presentation was granted, but Marymount failed to meet that extended deadline (and) thereby the related planning entitlements of Phase 1, with the exception of the permanent Parking Lot Expansion Project, were voided per Condition 60a. • Although the initial 15/MND Draft was released October 31, 2013, and later revised in November, no public notification has been made acknowledging this lapse of those entitlements, which represents a Significant change in the 2010 EIR that disqualifies use of a MND in for any EIR review of the proposed Revised Athletic Field project. • This is significant oversight because, per CEQA 1 5162(a) and 1 5162(a)(2), a subsequent declaration that a Mitigated Negative Declaration (MND) be adopted, is in direct conflict with those established CEQA provisions that prohibit use of a MND under such radically changed conditions. • For example, "When an earlier adopted mitigation measure has been deleted (ref. Mitigation Measure TR-9 /TR-9A), the deference provided to governing bodies with respect to land use planning decisions must be tempered by the presumption that the governing body adopted the mitigation measure in the first place only after due investigation and consideration. We therefore hold that a governing body must state a legitimate reason for deleting an earlier adopted mitigation measure, and must support that statement of reason with substantial BJ Page evidence." (Ibid., italics added; see also Mani Brothers Real Estate Group v. City of Los Angeles (2007) 153 Cal.App.4th 1385, 1388-1389, 1403." • As with the above determination, Mitigation Measure TR-9 was in fact adopted only after due investigation and consideration. ........ ......... c.tllllll ~· ....... ............. Miion ~ofl:OllllllmCI FBl•llllllllldflr ............ ........... AINetk ........ .., ,._,,., ..... AllNNIMN Allllillr: F1lllt __.. ...... ....... ......... COlllplMol fllr .... o.11 ......... Fllld1 ...... l9qllQmenls and shal be to the lallsfacllon of the Pulllc Worb lli9cb'. Since hi Paloe Vtflles DriWl Emtll'llb Verdes Dri'le S014t1 ~ II ~ by Che plOpclMd Projecl for 'C~ wilh propoMd Project QOlldllons,' • ~ shnc:onlriW!on ~~~· TR·9 Prior lo lslUln:e of My Y8il TR+AF Prior ID lssl8lC8 of any Pllorlo ~ Vllibllon th8I Gredilg Pl!wl, the Project Pin ahal .Pli19 Ot bvici119 peimt. Ille Project ilRllllCllolalrf ~ the requiad be rMied 1o Incl.do 'M04Jghl ron Plmll ~ be 18'1\ted to h:lude Gidtgor Dlrectlr lenciig is ahow1 fllndrQ aloog Pa Verdes Drive wnK"1I Iron lencing lllong the Building PEimt on plans Eal II ~ l>.O leel In ~adgeoflheillhllltlglleldll ~t ;nd 80 pett:erC open to lght ~ e.o 1eo1 1n height en<1 and •• llrrcJol*Y rehcbible netllng 80 pen:enl open to lght and all' so along the llOl1llem, ICUlhern and tllll DITft blllt n dlclen~ MAim llidea of· the liNetic leld Ill oontailld, lo the l5IElrlaclcll of the appolimllaly 30.0 l9el In heigh~ Cormudty DIMlopment OnctJr. end dlain ilk fencing Ill 29.0 fNt In The UM of a landlClpe eaeen helg1I around tbl perimeW of lhe arwnd nl ;idjacent lo Ille \llOOght --.n lerir.il coOOI and 10.0 feet ron l8nce a1ong the perimot1f of Iha ii heiglll sound Ille perimeler of the Atiric Field ""81 be lmll8ll lo a 8Mllm lllMfa courts IO lhat enWtl b.ls In IUlliclendy conllined, lo Iha maxinun height 0142 lndles. ~ of the Communly llewlopment DlrD!r. The ~ net std only be exllw1ded cUlng adivila ~ llllld bait Ill the All*'& Fleld, albjec:t ID lhe hblicN 11111 lo<lh in ~ u..... .... AES-Ii. The 15 • This determination is memorialized by the Findings and Facts in Support of Findings in Resolution No. 2010-41, Exhibit A, pages 6 7 and 68. • The further required statements of Site adequacy by size and shape can be found in Resolution No. 2010-42 on pages 6' & 7 in Sections 2.1.9, 2.1. l 0 and 2.1.11. 9IPage • Specifically, Section 2.1.10 states with reference to the approved field, that "The City Council finds that the site is of adequate size to accommodate an athletic field in addition to the other components of the project, provided (emphasis added) that it is moved further to the east, with two tennis courts on either side, because a field so configured, would not result in safety impacts on Palos Verdes Drive East. • Condition No. 1 75 provides that there be no use of "small balls" on this playing field, including golf, lacrosse and baseballs, among others. The IS/MND provides no justification that supports modification of this Condition. • Staff is also well aware of testimony given on April 17, 2012 by neighbor Mike DeNardo, (to Council member Jim Knight), that his real life experience with the adjacent Castle Field use by Marymount students resulted in "enough soccer and lacrosse balls that could fill this Room". 10 I Page • This direct evidence contradicts the anecdotal review conducted in the IS/MND (Errant Balls) that seeks to demonstrate otherwise. • Just take a look at the trees and Nets protecting Mike's home (right) from the invasion of all those room-filling errant balls. • Here is a photograph of the Nets behind that goal area; 111Page • The basis for adopting a Mitigated Negative Declaration (bottom of page 1 7) fails to meet the standards established by CEQA 15162. The Resolution No 2010-41 (EIR, Appendix A, pages 69, 70 & 71) determined that the Level of Significance for Short Term Construction Noise was "Significant and (caused an) Unavoidable Impact, thus requiring (Exhibit B, page 1) a Statement of Overriding Considerations (SOC). • Bottom Line is that you cannot logically approve use of a MND when it has been demonstrated there can be no Mitigation of the resulting impacts (Short term Construction Noise) that cannot be reduced by Mitigation to a less than a Significant level, as is the case here. Makes no sense! • That 201 0 required SOC also set forth a benefit (as Item E) of that approved athletic field location, stating that "The Final Project increases the landscaped setback along Palos Verdes Drive East, thus enhancing the appearance of the campus from the public right-of-way." This benefit would be voided and lost by the design of the Proposed Revised Athletic Field Project location, a fact not disclosed anywhere in the IS/MND. • The Short Term excessive Construction Noise (exceeds 70dbA) contemplated by the EIR, as shown in the Table 5.5-9, was confined to Phase I only, limited in duration for three months. The 201 0 approved project compressed all of the demolition and basic grading for all buildings, parking lots and athletic field to be incurred concurrently during the specified 12 I Page (Condition 60a) limited 3 month time span. Post September 30, 2013, with the lapse and voiding of these uncompleted Phase I entitlements that Marymount has indicated are now shifted to the future in a re-phased new Master Plan, those future unavoidable impacts also represent a significant change that cannot be fully mitigated which further disqualifies adoption of a MND for this Revised Athletic Field Project. 13 I Page Table 5.5-9 Summary of Estimated Construction Noise -locMiont Eltimllad o.aipdon Conltrucllon nw.holcP Exceed DINCtion Diltlncel NollelevtP Tiv.hold? Phuel Demotition/Gradlng, Parl<ing Lot North 125 84dBA 70dBA Yes Construction South 250 78dBA 70dBA Yes East 25 98dBA 70dBA Yes West 165 82dBA 70dBA Yes Ph11eU Construction Of Fac:Uty And North 215 . 75dBA 70dBA Yes Student Union Adcitions, New South 450 69dBA 70dBA No l.itgy, Mainfenalce And East 125 80dBA 70dBA Yes Alhletic F aciity West 650 66dBA 70dBA No Phaeelll Auditorilm And Acministntion North 375 70dBA 70dBA Yes Additions, New Residence Hals South 315 72dBA 70dBA Yes andGalery East 190 76dBA 70dBA Yes West 600 66dBA 70dBA No Notes: 1 Clslmlce is an approxination to lhe nenst sensitive land use ~l to an actNe OOOSU\Kfu1 zone. 2 Estimaed COR8truCtion noise leYel is calcUated brt applying a EklBA recluction pet doubling <lstillCe to the noise pdilell identified in ~ ll§. Mora piecisely, the fonnUa Is as fdlor,r,is: dBA2=dBA1 + 10!.ogw (d1fd2)2 where: cllA2 = EstinlBd COnstrudian Noise l.IMll; dBA 1 = Reference noise level al 25 feel (from Tille 5.5§1; d1 = reference cislance ct 25 feel; d2 = Approxinate Receptor Location DBtance 3 Threshold based unon the 70-0BA sllfllrll intederence criteria Excessive noise levels resulting from construction activities generally would occur In the daytime hours only, because Code Section 17.56.020 , Conduct of Construction and Landscaping Activities (Hours of Operation), prohibits construction, grading or landscaping activities, or the operation of hea.vy equipment, except between the , Public R!Mew Draft • October 2007 5.5-18 Noise • During Construction of the Modified Parking Lot in 2013, the entire front side of the Classroom Building was covered with a soundproofing blanket. • Adoption of a MND is non-compliant with CEQA 1 51 62 because the proposed Mitigation Measures TR-4-AF and TR- 7-AF, specify unmet/ineffective Mitigation objectives (793 weekday maximums), consistently exceeded since Fall 2011. 14 I P age History of Reported Marymount Enrollments per the studied approved 2010 CUP : Fall 2010 • Fall 2013 Reporting Period Reporting Ol tegorle$ Ma•lmum Weel\dav (see Notes 1 2 & 3) fndftlon:JJ Non-Tradftlonal 8A$rudeot> Tot•I Pet CUP/EIA inclu ded(?) Studied Fall 2010 755 0 (40) 755 793 Sprlng2011 762 1 (97 ) 763 793 Fall 2011 786 98 (8) 884 793 Sprlng2012 734 106 (93) 840 793 Fall 2012 769 143 0 912 793 Sprlng2013 754 101 0 855 793 S7 Hl\At,t11:it Fall 2013 793 132 (20) 925 793 .__ Note 1 Appendix Don pa11e 3.3-39, Assumptions, st1.1dled a maximum weekday student enrollment of 793 Note 2 Mitigation Measure TR-7 states that parkln1 Impacts studied assume a maximum of 793 weekday students Note 3 Mitigation Mea sure TR-4 speclfles traffic Impacts etssume a ma1dmum of 793 weekday students -oK? Difference YES 38 YES 30 NO ~ NO ' NO . NO NO - .· • Mitigation Measure TR-4-AF does not recognize or mitigate the current Traffic impacts of the 925 weekday students which significantly exceeds the specified maximum limit of 793 shown in Marymount's Fall 2013 Enrollment report. MARYMOUNT CALIFO.RNIA UNIVERSITY September 23, 2013 Dtreclor of Environmental Servtcas City ofltmlc:ho Palos Vardes J094-0 H1wt11omc Blvd. Rmcllo Paloo Venlea CA 9027S-5391 {)./LA-- OFFICE OF THE PRE$10ENT Per out RPV CUP requilmlonts mid Its enrollment cohort pararnetcn, Muymo1111t California Univenity la oubmittin& cerllft<:alion of Fall 2013 cnrolbnent u follows: > 793 SIUdent1 are enrolled in tho Tnidltional Degree Propam. Thon ""' 22 upper dlvialon BA program atud<:nts In Ibis cateipny. > 132 Stu.dents are enrolled In the Non-Tnldldmlll Oe8fCICI Propam in the ovonilJ&. > 783 studlnta ponlclplled in driver 11fe1y tnllnina. Midlael Brophy, Ph.D. PnBiclenl cc: Vice Pnsident for F"tnance lllld Admlnlllnltion, lllllOI Reeves • TR-4, the current Mitigation Measure, has not mitigated the reported current excess Traffic impacts caused by those 1 32 weekday students and therefore, for the IS/MND to proclaim that even greater Traffic (TR-4-AF) and Parking impacts (TR- 7-AF) would be "mitigated" by the same exact measure is complete folly and nonsense. Since excess Traffic and Parking impacts have not actually been mitigated or the related maximum weekday enrollments brought back within the established maximum limits already set (793 weekday students 15 I Page enrolled), it becomes illogical to claim that any environmental impacts, significant or otherwise have been or could actually be "mitigated" as CEQA 1 5162 requires in order to properly process the environmental review as a Mitigated Negative Declaration instead of a comprehensive EIR in accordance with the Standards listed in Section 15162, including l 5 l 62a(l) l. • Even more illogical is the studied avoidance by the IS/MND of those Significant changes post 2010, including the lapse of Phase One entitlements after September 30, 2013. Marymount has consistently exceeded approved EIR "Weekday" maximum enrollment limits since Fall 2011 Mitigation Measures TR-4 (Traffic) & TR-7 (Parking) limit weekday enrollments to a maximum of 793 students Reporti ng Period Weekday Student Enrollment Reported Maximum Weekday (see Notes 1, 2 & 3) Traditional Non-Traditional BA Students Actual CUP/EIR Included (7) Reported Limits Fall 2011 786 98 8 884 793 Spring 2012 734 106 93 840 793 Fall 2012 769 143 None 912 793 - Spring 2013 754 101 None 855 793 (~.il BA Actual} Fall 2013 793 132 20 925 793 • Reported Enrollments understates actual enrollments by the number of un-reported BA students Note 1 Appendix Don pase 3.3-39, Assumptions, studied a maximum weekday student enrollment of 793 Note 2 Mitigation Measure TR-7 states that parking Impacts studied assume a maximum of 793 weekday students Note 3 Mitigation Measure TR -4 specifies traffic Impacts assume a maximum of 793 weekday students Studied In EIR? NO NO NO NO NO - "Weekday" student enrollment is defined as "the courses offered at Marymount College (that) occur on weekdays between 8 AM and 10 PM . Classes offered as part of the BA Prosram would occur durins these stated hours ." (FEIR & Appendix 0, Course Offerings). Excess Not studied " 1/ l l<\ b) i • The IS/MND completely fails to demonstrate how the prior and/or proposed Mitigation Measures TR-4/TR-4-AF and TR- 7 /TR-7-AF will mitigate the existing added Traffic and Parking environmental impacts since Marymount reported "weekday" enrollments well above 16 I Pag e has consistently the limits of the * * stipulated 793 weekday student enrollment maximum levels. The existing Mitigations TR-4 and TR-7 are not working now, so how is it possible that TR-4-AF and TR-7-AF will provide any mitigation in the future for the impacts created by the Revised Athletic Field project? • The IS/MND of October 31, revised November 26, 2013, provides only a non-descriptive listing of numerous "Required Approvals" (item 1 0 on page 6). Therefore, until and unless these Required Approvals are specified fully, it is not possible to offer appropriate comments or review without further elaboration. • The lapse and voiding of all uncompleted Phase I components after September 30, 2013 per City Code and Condition #60a represents a very significant change since the 2010 EIR and CUP approvals. As such, a MND is obviously not appropriate. • For example, after September 30, 2013, the previous maximum allowed Grading specified in Condition #67 (79, 155 cubic yards), reverts back to the actual completed grading of 29,000 cubic yards acknowledged by Staff as the actual amount of grading utilized for the Modified Parking Lot. • Although Marymount Counsel Don Davis, in his letter to RPV of February 27, 2013 (page 3), has viewed the City's request for detailed information on any proposed revisions to the grading plans and quantities associated with the (October 29, 2012) application to extend the phasing schedule "as a valid request 17 I Pa g e under the circumstances, and promptly directed its engineers to provide such information." "City Staff was further advised that the phasing amendments would be resubmitted ('i.e. piecemealing) at a later date once the requested grading information was prepared." It has not been submitted to date. • The problem is that, post September 30, 201 3, this grading is still a no-show from Marymount. And the IS/MND Athletic Field Plan (Figure 6) has a redacted Earthwork section which no longer provides that basic grading information. • One reason why the IS/MND removed the Revised Field grading quantities from Figure 6, may be opined from a review of a very revealing table of grading earthwork quantities for all remaining re-phased construction. This key Table data demonstrates that there is no remaining grading available post September 30, 2013! Summary of Proposed Grading Quantities • Marymount Athletic Field Expansfon -as revealed behind door number Three I I I l ' I I GRADING: Condition 67: I ' Mod Pkg Lot !New Field 1 Library Athletic Facllity Total All Phases I I I (Actual) a Maximum Total Grading I '. I N/A N/A I N/A N/A 1 79,155 I I 232,690 I Actual/Planned I I l i 29,000 ~daeted Nat ShOW[l Not Shown Not Shown I I I I 39.01'# 23,6'13 'l<>.913 103,690 Balanced on-site gradir:uz project I ! I : NO ! NO ' NO 0 I NO I I :Actual/Planned Export/Import 0 -19,225 8,013 ' -19.659 46,927 : I I l I I I I I • The table also discloses that the total future grading quantities (103,690 cubic yards) for the Revised Field, Library and Athletic Facility, greatly exceed the original approved 79, 1 S 5 18 IP age cubic yards of earthwork in the 2010 Resolutions. As such a MND is unsuitable because of this very Significant Change and related environmental impacts. • In this respect, the Draft 15/MND is notable for an obfuscation of grading quantities (see redacted Figure 6), perhaps that is intentional because no maximum additional grading quantities are available due to the lapse of all uncompleted Field and Pad grading previously approved in 2010 for Phase I. • As shown in Katzoff v. California Department of Forestry (op. cit.) Mitigation Measures, once adopted, cannot summarily be removed, altered or re-configured as TR-9-AF (Athletic Field). • In 2010, the governing body (RPV City Council) adopted Mitigation Measure TR-9 only after extensive investigation and consideration. For the lack of any supporting substantial evidence to the contrary, TR-9 cannot be so summarily waived as this IS/MND proposes. • Another such duly considered proscription is Condition #1 75; specifically that; "Use of the Athletic Field shall be prohibited for activities involving baseballs, golf balls, or other similar sized balls that cannot be adequately contained by the use of the field net." That Condition is one of those that Require Approval (pending?) • The standard of "substantial evidence" needed to overturn or revise a Mitigation or protective Condition is also in evidence by Marymount's application to continue use of this field as 19 I Page before including for Lacrosse, which balls come under the "small balls" prohibition of Condition #1 75. Note also the exception to chain link fencing as provided in Conditions #1 76 and #1 77 by the 201 0 CUP approval that would also be inappropriately eliminated by the terms of this Revised Athletic Field project specified in the IS/MND. • Marymount is requesting an enrollment increase from 943 to 1,200 students; That is an unrecognized significant change which also and of itself disqualifies use of a MND for the Revised Athletic Field Project. To prepare for an anticipated increase in enrollment, largely due to student desire for four-year degrees, Marymount College is requesting from the City of Rancho Palos Verdes an increase of enrollment capacity from 943 to 1,200 students. Also for consideration by the City of Rancho Palos Verdes, is the college's need for a 20- year window to build the city council-approved facilities on the college's Main Campus . Approved in June 2010, library and recreational facilities are slated in the campus' future to enhance the educational experience of Its students and serve as a community resource . • In 2010, Marymount promoted an Initiative, Measure P, to the RPV Community which allowed, among other revisions (as Attachment D), a change in the approved location of the Athletic Field. That Measure and specifically the change in field location, was unanimously opposed by the City Council in their June 2010 Resolution 2010-64. The Planning Commission also rejected that proposed new field location in their Resolution PC 2010-24. On November 2, 2010, Measure P, including the revised field location was rejected by a substantial margin. 20 I Page Rancho Palos Verdes Shoots Down Measure P, Marymount Expansion Weanesday November 3 2010 by Dakota Smith The Daily Bmeze reports that Marymount College's controversial bid to expand its campus in Rancho Palos Verdes was rejected by voters . "Councilman Brian Campbell - a aitic of the initiative who is no stranger to hyperbole -said in an e-mail that the outcome was the ''biggest political upset in Southern California history ." Previously, the college tried to get its plan approved through the city <http://la .curbed .comlarchives/2010/03/fed_ up_ with_ opposition_ to. php> , a process which frustrated Marymount executives . · Rancho Palos Verdes rejects Measure P <http://www .dailybreeze.com/news/ci_ 16506546> [Daily Breeze] RANCHO PALOS VERDES POLITICS • Not to worry, however because in his MCU 201 3 President's Report, Dr. Brophy noted that MCU had obtained Athletic Field and other uses of facilities at the newly-opened John M and Muriel Olguin High School Campus in San Pedro. • 11 Beginning in Fall 2013, MCU students will..have the opportunity to use the Olguin facilities for .. physical education." 21 I Page Maryrnount Expands 'Footprint' in San Pedro M~ Califof1lla~(MCU) kars.Mlf'IOUnCed 11.$ el!part~ dt thrtt S8n Ped-a loi:atiol'6 ~we dfllil r1pldly gt.,......ng to tntrel ~ Ufl~rsffy't •ncreHing enroltmefit, ' ~ MCU President Mkha.N Bropry, PhD ~San Pedro olhw.> DUr ~udetati manv oul§lendif\g loallo/\5 :O loam .,d oppo"1.lnflle5 for sef'Vi<o IN'ning, In Apnl 201J, the Gty of lm ~approved University~ to 1N:re.e ~' ait MCU\ San Pedro Re:sidentiitl CMOpUS.. The master plan For this campus 1ridudlrs the c.Qf1$troct)on of das5roo"" ~nded food .md sh.den! seM...--es • ....cl addrtiorial hQU!l1r19 at ttvJ srtit locited on Palos~ Driw North Construction 'lflM be oompletM m phasff over .a 20-year period Bitgmning in Fall 7.013, MCU studtonB wrH .Ntend d&ssM .tt the! John M and Muriel ~in CJmpU! of San Pei*<> Hqi School This Los An~ Un1hod School OWict (lAUSO) Qrnpld, which opened in 2012, hill!I the CepKrfy to serve add"rtional 1nidentJ, so the UniveBity will h""9 thn oppor1unity to Uk lhe Olg.Jln hic1litiM /or darsMl9 in fio-o ans. perlormiflg Mts ¥kl physicaf &<Lcation In an ag1eement with LAUSO lor lhe cooperative' Liie of campus lacilttie5, MCU wil PfO'IGa San Pede Kgti School student:; the opporturuty to efV'DU in uni\lemty-level courses for academic:~. ThUi means hlgh school studeots are .abkt to get"° ee1ty ~on co11ege ;md, ah-high school gr~. CM\ 4tflroll in pn'laie or public colteges wd ~"'"-~0-an Mf1~11td ~ •t.nd"'f> Sines •ts opetllrtg •n 2012, the W..iterfront Campw looted m the. his:tOfic district of Sim Pedro has served upper-dr..rsl()JI students Mld now wiH 5"efVe gradual& ~IS;,.. ~ral ~lions, •ncluding '1Z2. W Slrtti 5U'h( flOrmerl)I tho N<irthrup Grumman ~kingl, Uwt Arc~ Gat'ery arid the Grand Alinell. 9egin,..i~ 1n fill '2013, MCU wiN expM\d itlstudent das511Xims .wod ser~ and~;a5* KlditiaMlspace at the mw. Siirth Stteet IOG11tl0'1 Work IS &lso under.qy lo remodel and e<JJi1' lhe i(l;,us Cenl~ for Media Arts at 430 W. Sur: th StrMt. Th°' k>cation wii offer 11udenb statf!'-!Jt-cn...rt !e<hl'lology and il'l!:trl.l(tiori for film and video production, video a111rnation, ;i,nd vide.o compuUt ~ign ThE. ~ Centor •s expected lo open in dla 2()14 Marvmount California Unrvers;t;v Armounc85 New Tl'\l:ftee5 • Ever since August 26, 2010, Marymount has participated in NAIA Athletics, beginning with a Men's Soccer home field game (7:00 PM) against Embry-Riddle University - a "home" game for Marymount) the day before Dr. Brophy signed his acceptance agreement of the approved Resolutions for the 2010 EIR and CUP. In those documents, Dr. Brophy was on public record as denying that Marymount then had any current intentions or plans for joining a new Athletic Conference. Accordingly, a special Mitigation Measure, LU-1, requiring an Athletic Associations Membership Report annually, to document the corresponding sports in order to determine if a revision to the Conditional Use Permit (CUP) is required. Such Report was not provided until 2012. 22 I Page • NAIA sports have been successfully conducted by Marymount teams for years since August 26, 20 l 0, without having any special NAIA fields in RPV. • Notably, Dr. Brophy signed the EIR and CUP acceptance letter August 27, 2010, one day after Marymount's first NAIA game. PLANNING. BUlDINC .... CODE fN~NED Certification of Acceptance of Project AUG 2 7 2a1n PROJECT: PROJECT LOCATION: APPROVAL DATE: Conditions of Approval "'=~ ZON2003-00317 {COHDITIONAL USE PERMIT NO. a REVISION E, GRADING PERMrr, VARIAHCE, MINOR EXCEPTION PERMIT .utD ENVIRONMENTAL ASSESSMEHT) 30100 PALOS VERDES DRIVE EAST - MARYMOUNT COLLEGE JUNE 1,2010 (Nolo: Puniuanl to Condition No . 1, !his cerUtloulJon ahsl be s;gnad and Clllumad kl the City or Ron<iho Palos Verdeo Convnunily O..Votopmont Depallmonl B1 30940 Hawtl>Omo BQJlevanl, Rancho P-v-... Cl\ 90276 by AUCIUST 30. 2010). :awaH111111~ Or.1J fR-W..llUP""ll'l-\tll.ll'\,a~ A,,,...NC-JUIUI fHl(JRUMINI ~lq&of<!-6228 I ailOff; lllCl285-7800 ( l>l:Pl. IAXPICl54•·62Q3 if·~ PUl'tNJ«;.°'1f'v_(._Ot.! • Another extreme example of a post 2010 EIR Significant change took place on April 11 , 201 3, when the Los Angeles City Planning Commission approved a major expansion of residential and educational facilities at Marymount"s Palos Verdes Drive North (PVDN) site. 23 I Page 5. CPC-2011-2480-CU CEQA: ENV-2011-2478-MND Plan Area: Wilmington-Harbor City Council District: 15 -Buscaino Expiration Date: 4-11-13 Appeal Status: Appealable to City Council PUBLIC HEARING -Completed on January 24. 2013 Location: 1600 PALOS VERDES DRIVE NORTH Proposed Project: The subject site is currently developed with 86 dwelling units that provide off-campus housing for students attending the Marymount College Rancho Palos Verdes Campus. The stated goal of the College is to develop a five phase undergraduate and graduate campus. which at total build out would accommodate 1,500 students, with 84 7 students being housed on the site. The project proposes: to convert the garages of the existing dwellings into additional bedrooms, construct a surface parking lot along Palos Verdes Drive, construct new structures comprised of a 27 ,000 square foot dining facility, with classrooms an ct administrative offices , (called the Old Main), a 17,500 square foot building located south of Old Main containing classrooms, laboratories design studios and administrative offices and a 4,077 square foot maintenance building. The proposed buildings will be two to four stories 30-75 feet in height. The Old Main building will have an 87 foot 6 inches in height tower element which will serve as a focal point for the campus. Rancho Palos Verdes City Council Meeting r h ·1'J'··'f'' '• • . { I ; 1 "' Approved April 11, 2013 May 7, 2013 (; 1. cec.2911..wa.cu CEQA: Etfll·2011-2UllA>INO Pl.,, !UH: Whlngton.JWbor City PUB UC HEMING -Compteled on J•nur, 24. 201 J Council Olllrict 15 -Buacalno Expiration DMe 4-11-13 -"'S'""'" --'° CltyCountll ~ 1600 PAlOS VERDES DRIVE NORTH ~~---~ .... aa~ ......... ..-.. _.,,......,.. 1tudentl ~the M:aryn.ounl O:ilfge RMdlo Palot Vetdn Catnput The .Ua.d golf~ "1e CG11ogolotod.-P1 ... pn..~--o•-._ -·--..., __ UOOOllld ..... -~7-•llolt>g-onlheoile Thepn>jod :;:"'~-==~=~..=--==o';"~~ ==-~~-:.....-==~.::..""=.=:~~ ....,...,,,., ___ ond14,071""" ... '°"'"'""-o.lldolg. ,.., _ ....,.,.., ............ ,.,,,_30-151ootlofl0i9ht, Th10ld--inllwil)low on87 lo<>t0-loholgl11-1olo"'""'..tllch""-"a-poo1llOftt!0<1mpu1 •• F...,LAMC-.1u1.1.,_"'"'"-"-but.trigo"'_'_,_ o1-...,, _ ,3> "'""" m-. ...,, hefg1111'"'"'""" :io '"'"' 1&'"' (ilc*ldlrig--)lolN_h<l_°"""8•--llOlll.olldl1 IOOIO-lo<ilo_iMr_ ... Jld;ng,,,_t.-.lo-ollhe :JO.IHI-ii the 1XL zone b From I.AMC Sedloft 1Z.09at B 3to'Nln'91n the 1~11 Jeaf Vlf'dNIHK*of tOfeet lnllead of the 25 foo1 res yard reqund In the ROEi zone CITY PLANNING COMMISSION APRIL 11, 2tlt3 • The prospective increase in Traffic and Parking environmental impacts of the newly added 847 Residential and 1,500 daytime enrollments at PVDN has not been taken into account by the proposed IS/MND. Because this foreseeable increase in Traffic 24 I fl ;Jg c and Parking impacts at the proposed Revised Athletic Field has not been mitigated or examined, a MND is not appropriate for this Project. • Condition 67 requires that all grading for all components of these entitlements be "balanced on site", with no import or export of grading materials except as may be otherwise provided for required material, including removal of demolition material and import of minor construction-related materials, as stated. As shown (again) below, the instant project requires an export of a reported 19,255 cubic yards of earthwork material without any or even sufficient rationale or evidence. Summary of Proposed Grading Quantities -Marymount Athletic Field Expansion -as revea led behind door number Three I I I I GRADING: Condition 67: Mod Pkg lot !New Field ! Library Athletic Facility Total All Phases I I I I I ' l (Actual)1 I I I I I a Maximum Total Grading I I I N/A l N/A N/A I I N/A I 79,155 . I I I I I m.690 I I : Actual/Planned I 29,000 ' "RPdaeted N0t Shown N0tShown Not Shown l I I I I 39,m 23.6¥3 'I0,913 103,690 Balanced on-site grading project 0 NO NO : NO I NO I Actual/Planned :Export/Import i 0 19,225 8,013 ' -19,659 1 46,927 I I I I I I I j • But this is just the tip of the unbalanced iceberg that Marymount is requesting. The proposed export of 19,255 cy of earthwork for the Revised Athletic Field requires future significant additional amounts of imported and exported earthwork grading which totals 46,927 cubic yards. The IS/MND provides no justification, mitigation or other supporting rationale for these quantities, because the analysis is limited to only the environmental impacts 25 I Page associated with the Revised Athletic Field in isolation from the entire project. • As previously documented, "A public Agency is not permitted to subdivide a single project into smaller individual subprojects in order to avoid the responsibility of considering the environmental impact of the project as a whole." 'The requirements of CEQA, "cannot be avoided by chopping up proposed projects into bite- size pieces which, individually considered, might be found to have no significant effect on the environment or to be only ministerial." • This important principle has been totally dismissed and omitted from the current IS/MND process. As fully documented by Staff to Dr Brophy in the March 8, 201 3 rebuttal letter (v. Don Davis's February 27, 2013 claims), the following key points in dispute are revealed; 1 . Marymount has failed to provide promised grading data and information, agreed by Davis in his correspondence, as it relates to the construction phasing in the Master Campus Plan, the College .. did not address the question regarding the revised grading quantities in relation to the Campus Master Plan. 2. "The College's January 25th submittal raised a concern with the proposed grading plan as it relates to the Campus Master Plan as a whole." 26 IP age March 8, 2013 VIA EMAIL & U.S. MAIL Dr. Michael lllophy Pl'Bllden! Maryrnount College OTY OF t L PALOS VERDES PIANNINC, BUILDING. & CODf fNFORCEMlNI 30800 Pam Verdell Drive Eaat Rancho Piiot v.-, CA 90275 Subject Conditional U'8 Penni! No 9 Ravlalon "F" et al (ZON2012-00386) - Amandmenla ID Ille Council Adopled Athletic Field and Condlliona of ApprOYlll De« Dr . llRlplly, I am writing you In respo,_ ID ~. Don Davio' (Collage'• lllgal oounaaQ leltllr to the Cily d.tlld Febrwuy 27, 2013 regarding lhe Cily'a delenninetion that the aubjecl appflco!lon la "-tied in<:OmplelB for proooaalng. Aa lndlcatBd In Mr. Dav1e' February 27"' lllllM, the Ctty-Informed of the p~ 19'1111on beine conle""*1eci bylhe CoUego 11ootly .. May2012, bul the aub)ect appbtion ·-not toml•lly aulJmlttod ID the Ctty for ptOOMalng umll """' 6 rnonll>• lalat'. FW1Jlet, In roopotWO to the Coltege'o May 2012 -· on Jilna 2G, 20 12. the Clly praWled the College with lnfotrMllOn. baled on a prelimlnory roYlew (al no oost to the College) of llmlied 1nlonnallon provided, teganling what would be needeCI to ptOCUll the Collego'o COllUlmplallld rlOYlllld propooaL In tumr1181y, Clly Sbl!l lndicalecl 111111 lho Collogo -.kl ,_ ID W>nVI 1 """"'°" to ill Condi1lon91 UM Ponn-efld Gtadlng Porrnl eppllcetiooe along with Qllldlng lnlolmlllon indudlng gnocfll'lg quantiJeo IOI CU. fill, •-II and lmpol1. Clly Slldl' oancluded by Nllng that •lddiUonlll oommon11 1111y be torthoomlng _, lilll ~ appu..tlonll and projecl plans •I'll formally submlllad to the City for p-.lng." 0.. October 29, 201 2. lhe Colloga rcm..iiy oubmltted a requeel lo 111vloo Ila DXll1!JIQ Conditional U111 Pannk -UwcMld ~ opeci(IC req-1a. lnQudll'G a <-' IO rcMle the oonflguralloo of the 2010 COUl1Cll lj)p!OVOIO a111iellc llelcl end ID amend the~ phaalng candl!lon (Cotldilion Ho. 80) Iha! would -lialy -tlle Maaler ~ Plen ID be oonetrwtod ""'' a 20 -period flllter thin lllO 8 ~ period Ofllltna!ly approwd by lhe City Counc:il In 2010 Alla! lll\lle\ltlnQ the fnforma!lon IUbrnilled by IM College, Sblfl - the appllcallon lnoompiell on NovombDt 27. 2012. In rospor!la ID lhe Clly'1 ~lier 27. 2012 ~ req...ting addltionll lnlonM1!on . ~lly vpd11lng the grading pl111 to Dddme lho Collova'• pmpoMI to add,_ Illa cllangoe ID the gradk'Q quall1ll!et u M - Oi(lj.t .... ~..._ a \u ·~1 or~v, •. u., c11 ... an .. ~1 1·.11~ ... ((l()tlNl"lllllfMfM1:11a&1.<1~1 .-.,r1n.te ::1·0~1 -:DI.,. fM0 1(1~(~<"iitJ I C..w ....... .-...... 1'-1 ,0ltP..1..~ 3. "Specifically, the proposal to export 17,625 cubic yards of earth. Which according to the approved grading plan was to be repurposed on-site for the Campus Master Plan, raised the question as to how this revision affects the overall project." 4. "Because the College is unable to provide the information necessary to address changes to the approved grading plan occasioned by the new 17,625 cubic yards of export, the question still remains outstanding as to how the proposed export impacts the accuracy of remaining grading for the overall Campus Master Plan, and validity of the other grading plans for the other portions of the site." 27 I P age MARYllOUNTCOLI.EGECUPNO.IREVl~ON"P' MARCH 8, 2013 PAGE2 to the construction phasing for the Master Campus Plan, the College submitted a revised application on January 25. 2013 that essentially removed the original request to amend the construction phasing schedule. However, the College's January 25111 submittal did not address the question regarding the revised grading quantities in relation to the Campus Master Plan. The College's January 25111 submittal raised a concern with the proposed grading plan as it relates to the Campus Master Plan as a whole . Specially, the proposal to export 17,625 cubic yards of earth, which according to the approved grading plan was to be repurposed on- site for the Campus Master Plan, raised the question as to how this revision affects the overall project. City Staffs concem was discussed with Mr. Davis during a conference call on February 22, 2013. Because the College is unable to provide the infofmation necessary to address changes to the approved grading plans occasioned by the new 17,625 cubic yards of export, the question still remains outstanding as to how the proposed export Impacts the accuracy of remaining grading for the overall Campus Master Plan , and validity of the grading plans for the other portions of the site . • "CEQA requires that no matter who prepares the initial version of an EIR, the EIR must be subject to the Lead Agency's own review and analysis and reflects the Lead Agency's independent judgment with regard to the scope, content, and adequacy. The Lead Agency is responsible for the objectivity of the Draft EIR. When a Draft EIR is prepared by another party, .. such as a consultant, the Lead Agency should review preliminary or administrative drafts of the EIR to enable the Lead Agency to exercise its independent judgment concerning the scope, content and general adequacy." (Chapter 4, Lead Agency Responsibilities, Preparation and Review of an EIR and Agency Decision Making. CEQA Handbook) • "Clearly this is a significant change that does need to be addressed. Maybe there will be no impacts ... but I'm not a traffic engineer, and I don't know." Carol Lynch, Rancho Palos Verdes City Attorney. September 13, 2009 281Page Rancho Palos Verdes City Council Meeting May7, 2013 () '"" IN••_... ... -,.,.-..-reeze MUYllDWIT COUdlJ RAB..it11 Palm Vft'llcl 91Dtl b>-t1r l1lqwl ptquR ft>ur1UJ' ~ proaams w111 lw\'C' on c11y -a.tr ...... 5:' ......... __.. ...,.. ........ ... ..,__ ""'"" -· 1111111 ..... ...illlodl -·· .:::= ,_.., - • 11 Adding to the reasons for the new name change are the recent admission into the NAIA Cal Pac Athletic Conference and the school's increased enrollment, which has doubled in the past three years." Daily Breeze, March 16, 2013 Rancho Palos Verdes City Council Meeting May7, 2013 "this ii-::i "ignificant change" Adding to the reasons for the new name are the recent admission into the NAIA cal Pac Athletic Con- ference and the school's increased enrollment, which has doubled in the past three years. MARYllOUNT A2. • A very logical as well as troubling question remains unanswered with regard to the lapse of Phase I entitlements and the significant effects thereof. This issue was brought to 29 I Page light beginning on page 3 of RPV's March 8, 2013 letter to Dr. Brophy. It should be noted that currently, Phase I is valid until May 7, 2013 (extended by the City Council at its December 1B, 2012 meeting), at which time, the City Council will consider whether to extend Phase I up to September 30, 2013. It also worth noting for clarification purposes to Mr. Davis' February 27°' letter, that according to Condition No. 60, which was drafted based on the College's written narrative submitted to the City in August 2008 for CUP No. 9 Revision ·o: ~All maior rough grading (emphasis added) needed for the reconfiguration of the parking tots and the establishment of building pads for the new improvements would be completed within the first three months of the start of construction.· Moreover, Phases 2 and 3 describe grading as "Fine grade (emphasis added) for new construction associated with this phase .· The City would like to further clarify what may be a misconception by the College regarding Construction Phasing Condition No. 60. On August 2 , 2011 , the City Council was asked to interpret the 2010 Council adopted Conditions of Approval because of the apparent inactivity on the construction aspect of the project by the College. As stated in the August 2nc1 City Council Staff Report and affinned by the Council that evening: "A concem was raised regarding the timing periods stated in this condition. According to this condition, the entire Facilities Expansion ProJ'ect. approved by the City Council is to be completed by June 1, 2018, which is 8 years from June 1, 2010, the date the C-Ouncil took ifs final action regarding the application by adopting the resolution approving the Facililies Expansion Project. Moreover. if components described in each phase are not completed within the pennffted time frames, and extensions 818 not granted by the City as described in Condition No. 60, those uncompleted items MARYMOUNT COLLEGE CUP NO. 9 REVISION uF" MARCH 8, 2013 PAGE4 become null and void and cannot be completed as part of the following phase. For example, if grading for the athletic building pennitted in Phase I is not completed in the time period specified in Condition No . 60, construction of the athletic building can no longer occur. Extensions to the time limits established for each phase may be considered provided that ccnstruction activities do not exceed a total of 3 years and that project construcffon is completed within 8 years from June 1, 2010. It should Blso be noted that pursuant to Condition No. 60(d) a/f elements not completed wffhin the time periods specified will requim additional review and approval through a 1'8Vision to the Conditional Use Permit and additional CEC1A review. • • Per the City Council Review of August 2, 2011, "if components described in each phase are not completed within the permitted time frames, and extensions are not granted by the City as described in Condition No. 60, those uncompleted items become null and void and cannot be completed as part of the following phase." Bottom Line First? 30 I Page • "For example, if grading for the athletic building permitted in Phase I is not completed in the time period specified in Condition No. 60a, construction of the athletic building can no longer occur." • In similar fashion, if grading for the athletic field permitted in Phase I is not completed in the time period specified in Condition No. 60a, construction of the athletic field cannot occur! • The 15/MND makes questionable claims regarding the reconfigured athletic field vs. the approved field. These claims are presented on page 103. Upon review of the revised field and "D-2" approved field plans, the following has been determined: 1 . The Revised field is significantly closer to PV Drive East than the approved field. 2. The Revised field removes the approved 20' high chain link fencing around the western tennis courts perimeter (TR-9) which was considered in the findings as an important protection against errant balls. (Resolution 2010-42, 2.1. l 0) 3. The Revised Field adds no replacement physical or distance features to protect against errant balls, nor does the 15/MND even discuss the omission of the TR-9 20' high chain link fencing that is included in TR-9. 4. At the southwestern corners of each field, the approved field is positioned 65' farther away towards the east, and 80' 31 I Pa g e farther north than the Revised Field proposed. 5. At the northwestern corners of each field, the approved field is 2 5' farther east and 30' farther south from PV Drive East than the Revised field. 6. The westernmost 11 touchline" of the approved field is consistently 3 5' farther east away from PV Drive East than the Revised Field. 7. Thus the quoted IS/MND distance comparisons are incorrect as noted here. The IS/MND also fails to provide any supporting rationale or substantial evidence for removing those mitigating features of TR-9, contrary to CEQA. No additional restraining physical features to protect against errant balls have been proposed, except "hot air." 32 I Pa g e CITY OF RANCHO PALOS VERDES TO: FROM: DATE: SUBJECT: HONORABLE MAYOR & CITY COUNCIL MEMBERS CITY CLERK DECEMBER 2, 2014 ADDITIONS/REVISIONS AND AMENDMENTS TO AGENDA** Attached are revisions/additions and/or amendments to the agenda material presented for tonight's meeting: Item No. c 3 Description of Material Memorandum from Senior Administrative Analyst Fox; Emails from: Janet Gunter; Ronald Conrow Emails from: Diane Smith; Jim Reeves Respecff~ ~cA -~ Carla Morreale ** PLEASE NOTE: Materials attached after the color page(s) were submitted through Monday, December 2, 2014**. W:IAGENDA\2014 Additions Revisions to agendas\20141202 additions revisions to agenda.doc MEMORANDUM RANCHO PALOS VERDES TO: FROM: DATE: CITY MANAGER'S OFFICE HONORABLE MAYOR AND CITY COUNCIL MEMBERS KIT FOX, AICP, SENIOR ADMINISTRATIVE ANALYST DECEMBER 2, 2014 SUBJECT: LATE CORRESPONDENCE REGARDING THE 5883 CREST ROAD CONDOMINIUM PROJECT IN ROLLING HILLS ESTATES (BORDER ISSUES STATUS REPORT-AGENDA ITEM 'C') 5883 Crest Road Condominium Project, Rolling Hills Estates At last night's meeting, the Rolling Hills Estates Planning Commission conducted a public hearing to review the proposed 4-unit residential project at 5883 Crest Road, located at the northeast corner with Highridge Road (see attached Staff report). The Planning Commission expressed a number of serious concerns with the proposed project, including the size, number and design of the proposed homes; the proposed site grading; and the justification for the requested General Plan Amendment, Zone Change and Zone Text Amendment. A representative of the nearby Seabreeze homeowners' association in Rancho Palos Verdes expressed a number of objections to the project. Staff was also provided with a formal response to our comments on the project's Mitigated Negative Declaration (see attachments). At the conclusion of the meeting, the project proponent agreed to continue the matter to a future date uncertain in order to work with Rolling Hills Estates Staff to address the issues raised by the Planning Commission. Staff will continue to monitor this project in future Border Issues reports. Attachments: Rolling Hills Estates Planning Commission Staff report (dated 12/1/14) Response to RPV Comments (received 12/1/14) M :\Border lssues\Staff Reports\20141202_ CC_LateCorrespondence .docx 1 of 26 c AGENDA Staff Repor DEc-12014 ITEM NO. ~A City of Rolling Hills Estates!--~~:...=:::===-Jl l DATE: DECEMBER 1, 2014 TO: PLANNING COMMISSION FROM: NIKI WETZEL, AICP, PRINCIPAL PLANNER SUBJECT: PLANNING APPLICATION NO: 25-14; APPLICANT: MS . JUDY CHAI LOCATION: 5883 CREST ROAD OVERVIEW The following is a request to approve: 1. A General Plan Amendment to change the land use designation from Neighborhood Commercial to High Density Residential; 2. A Zone Change from Commercial Limited {CL) to Residential Planned Development (RPO); 3. A Zone Text Amendment for development standards for lot size in the RPO Zone; 4 . A Tentative Parcel Map for a one-lot subdivision; 5. A Grading Application; 6. A Minor Deviation for lot coverage; 7 . A Conditional Use Permit for a Residential Planned Development; 8. A Neighborhood Compatibility Determination for the construction of four single-family patio homes; and 9. A Mitigated Negative Declaration under the California Environmental Quality Act (CEQA), finding that the project, with mitigation measures, will not have a significant impact on the environment. BACKGROUND Application Filed: Application Deemed Complete: Public Notices Mailed: Public Notices Posted: Public Notices Published: 3/21/14 10/7/14 10/9/14 10/9/14 10/16/14 Approval of a General Plan Amendment is required to modify the Land Use Element of the General Plan to change the land use designation of the subject property from Neighborhood Commercial to High Density Residential. General Plan Amendment procedures are set forth in Section 65350 of the Government Code. Approval of a Zone Change is required to change the zoning designation of the property from Commercial Limited (CL) to Residential Planned Development (RPO). Approval of a Zoning Text Amendment is required to amend Section 17.18 .040(A) of the Municipal Code related to minimum lot size. Approval of a Tentative Parcel Map is required under Section 66426 of the California Government Code and Chapter 16.12 of the Municipal Code. Approval of a Grading Plan is required pursuant to Section 17 . 07 . 030 of the Municipal Code for any importation onto or exportation from any site in the City which exceeds 20 cubic yards of earth or any vertical change in the grade of any site which is 3' or more. · Approval of Conditional Use Permit is required pursuant to Section 17 .18 .020(8) of the Municipal Code for a Residential Planned Development (RPO) subdivision. Approval of a Minor Deviation is required pursuant to Section 17 .66 .100(A)(6) of the Municipal Code for an increase of not more than 10% in the maximum allowable lot coverage . Approval of a Neighborhood Compatibility Determination is required pursuant to Chapter 17 .62 of the Municipal Code to review the natural amenities, neighborhood character, style, privacy, and landscaping of the proposal. Approval of a Mitigated Negative Declaration is required under the California Environmental Quality Act (CEQA), finding that the project, with appropriate mitigation measures as stated in the Initial Study, will not have a significant impact on the environment. The subject property, located in the C-L (Commercial Limited) Zone, is .51 acres in size and currently undeveloped . The property is unique in that it is one of two C-l designated properties in the City and the only one that does not have a Mixed Use Overlay designation (the other property is the Pepper Tree Lane project site). The General Plan Land Use designation for the site is Neighborhood Commercial, and the site is located in Planning Area Number 7 in a Cultural Resources Overlay area . To the north and east of the subject property are residential uses in the Seaview Villas townhome complex zoned Residential Planned Development (RPO). To the south of the subject property , across Crest Road, are single-family residences in the City of Rancho Palos Verdes. To the west of the subject property, across Highridge Road are residential uses in The Ranch community zoned RPO. The following is a list of previous discretionary permits for the subject property : • LS·105-65: Approved a lot split to create the subject property for the location of a gas station; • PPD-102-75: Approved an expansion to a garden nursery facility (Crest Garden Center); • PPD~ 107-75: Approved construction of a greenhouse at a garden nursery facility (Crest Garden Center); • PPD-107-78 : Approved construction of an additional greenhouse at a garden nursery facility (Crest Garden Center); 2 3 of 26 • PPD-109-88: Approved an addition and sign plan for a garden nursery facility (Kim's Crest Nursery); • OC-161-89: Approved replacement of an existing sign at garden nursery facility (Sunset Garden Center); • CUP-113-92: Request for consideration by the Planning Commission of either a two-story, 7,240 square foot office/retail building or a two-building, four-unit residential development; (Note : Planning Commission was in general support of commercial development of the site and continued the matter for project revision/Precise Plan of Design application); • OC-116-00: Approved demolition of all existing buildings . • PA-27-03: Approved a Precise Plan of Design, Variances to exceed the maximum allowable coverage of the lot by buildings or structures , permit less landscaping than required in the parking lot area, and a grading application for a 5,760 square foot commercial building. As shown above, an application for a commercial building was approved in 2004 for the subject property. The applicant, Ms. Judy Chai, indicates that she attempted unsuccessfully to construct and tenant the approved commercial building. As such , she now requests a residential use which is the predominant use in the surrounding area. A "First Look" meeting was held before the Planning Commission and City Council on July 9, 2013 to discuss conversion of the subject property to residential use and the development of four patio homes. There was general support of such a project The project presented here is largely the same as that presented at that meeting. At the time of this writing, staff has received three comment letters on the proposed project (see Attachment 1 ). Staff will prepare a Response to Comments document upon closure of the public review period for the project Mitigated Negative Declaration (November 24, 2014). The Response to Comments document will be provided to the Planning Commission under separate cover on November 26, 2014 and will include any other correspondence received during the remainder of the public comment review period . DISCUSSION The applicant proposes to construct a one-lot subdivision with four, two-story patio homes on the .51- acre property. Two homes would be located on either side of a shared driveway accessible from Highridge Road . Four existing curb cuts (two each on Highridge Road and Crest Road) would be closed and replaced with full curb and gutter with the project. Each home would have an enclosed two-car garage and a guest parking space accessible from the shared driveway. The remainder of the site would be developed with private yard areas and landscaping. A stairway is proposed in the easterly portion of the property to provide access to raised private yard areas and secondary entries for the two easterly homes. The two westerly homes would have entries on the first floor facing Highridge Road. In addition to 400 square foot garages, each home has four bedrooms and is proposed to have 2,880 square feet of livable area . Street elevations are provided on Sheet A-5 attached separately to this report. Additional building elevations and a materials and colors board will be provided at the public hearing. Elevations show Monterey-style exposed rafter tails , painted wood trellis and window headers, flat clay tile, and smooth stucco finish. The architect indicates that roof tiles will be terra cotta in color, and building walls will be painted neutral colors . Street elevations and the site plan also show new fencing along the 3 4 of 26 perimeter of the property and in the upper private yard areas to be 30"-high wrought iron fence on top of 42"-high concrete walls. It is anticipated that the project would generate 38 daily vehicle trips. Three of these would be in the AM peak-hour and four in the PM peak-hour. LOS thresholds would not be increased with the proposed project, and no new signal is warranted. Section 17.28.050(0) of the Municipal Code requires a 25'-wide front yard and 20'-wide side and rear setback areas where the site abuts residential districts. The project provides a minimum 25' wide setback area between the building and Highridge Road (considered the front yard) and 20' for the remaining setback areas in conformance with Code requirements. Section 17 .28.050(G) of the Municipal Code · permits developments of two-story structures with a maximum 35' height. The proposed homes are approximately 22' in height from finished grade and two stories. Furthermore, this Code section indicates that the Planning Commission will make reasonable efforts to preserve existing views enjoyed by neighboring properties when reviewing all applications. It should be noted that the project applicant worked with and has received support from the adjoining Seaview Villas homeowners association for the proposed project. A flag silhouette for the project has been erected, and the Planning Commission should visit the project site to better understand site characteristics and proposed building mass. General Plan Applicability The purpose of the General Plan is to provide a comprehensive, long-range plan designed to serve as a guide for the physical development of the City. The General Plan consists of an integrated and internally consistent set of goals, policies, and implementation measures. The Municipal Code is a tool to implement the General Plan's goals, policies, and implementation measures. The City's present General Plan was adopted on August 18, 1992 (Housing Element on January 28, 2014). The "Introduction" section of the Land Use Plan (page 2-19) indicates that land use designations largely correspond to development as it existed at the time of General Plan adoption. The project site is within the Neighborhood Commercial land use designation (as described on page 2-20 in Table 2-1, Summary of General Plan Designations) which "refers to smaller single commercial uses located at key intersections". Table 2-2, Land Use Designation Standards (page 2-21), further describes the designation indicating that it is implemented by the C-L Zone, allows business, professional service, and retail uses, and that a maximum floor area ratio of 4 to 1 is permitted. The Overlay Map for Planning Area Number 7 (Exhibit 2-14 of the Land Use Element of the General Plan) shows that the subject property is in a Cultural Resources Overlay Zone. Page 2-22 of the Land Use Plan indicates that this designation "applies to a portion of the City where archaeological resources are known or suspected to exist." Mitigation Measures included in the project Initial Study address actions to be taken should an archaeological resource be discovered during project construction. As mentioned previously in the report, the applicant received approval for construction of a commercial building on the property, but was not successful in having it built. The property is surrounded on all sides by residential uses, and the applicant proposes residential use of the property. As such, a General Plan Amendment is proposed to remove the property from the Neighborhood Commercial designation and to place it in the High Density Residential designation. The High Density Residential designation corresponds to the Residential Planned Development (RPO) zone designation requested for the property, and is the General Plan land use designation of the Seaview Villas development to the north and east of the site. The designation provides for up to 4 5 of 26 8 units per acre, and the project proposes 7.8 units per acre in conformance with General Plan density. Because the project requires a General Plan Amendment, pursuant to Government Code §65352.3, staff is required to notify tribal governments for the purpose of preserving or mitigating impacts to, or cultural places located on land, within the City's jurisdiction that is affected by the proposed plan adoption. As such, staff requested and received a list of tribal governments to contact for consultation from the Native American Heritage Commission . Ten governments were listed and contacted for the required minimum 45-day review period. Only the Gabrieleno Band of Mission Indians commented on the project (as seen in Attachment 1) requesting that one of their monitors be onsite during any and all ground disturbances. Staff will include a related condition of approval in any resolution approving this project. Zoning Applicability Currently, the site is zoned Commercial Limited (CL) which corresponds to the Neighborhood Commercial General Plan land use designation. The applicant requests that the property be rezoned to Residential Planned Development (RPO) with the proposed application. This is the zoning designation of the Seaview Villas development to the north and east of the site . The RPO zone is described in Chapter 17 .18 of the Municipal Code and provides for cluster housing subject to approval of a Conditional Use Permit. Single family detached structures are permitted in the RPO zone, and common and private open space shall not comprise less than 70% of the project site. The applicant requests a Minor Deviation to permit 33% of the site to be covered by building and structures as discussed below. The maximum permitted density in the zone is established by the General Plan designation, and the proposed land area may not be less than 1 O acres. As further described below, the applicant requests a Zone Text Amendment permitting an RPO development on less than 10 acres if a site is contiguous to a 10-acre site zoned RPD. Zoning Text Amendment Section 17.18.040(8)(1) states that following : "Area. The proposed development plan shall include a parcel or parcels of land containing not less than ten acres. The area, width and frontage requirements of lots in a planned residential development shall be as required in the approved plan of development. The dwelling units and buildings and the land within the development may be divided in ownership only in the manner authorized in the approval of the development." Thus, a development in the RPD zone requires a minimum of ten acres. While the subject property is only .51-acres in size, the adjoining Seaview Villas development to the north and east of the subject property is 10.66 acres in size . Together, the properties form 11.17 acres of RPO development. The applicant requests a Zone Text Amendment to permit an RPO development on a property that is less than ten acres in size if the site adjoins an RPO development that is over ten acres in size. This amendment would provide for a similar scale and pattern of development for smaller parcels contiguous to currently RPO-zoned property while continuing to preserve all other development standards of the RPD designation (i.e., maximum coverage, height limitation, and setback requirements). Importantly, approval of any RPO development would continue to require approval of a Conditional Use Permit which provides for discretionary approval by the Planning Commission and the inclusion of any applicable conditions of approval. 5 6 of 26 Tentative Parcel Map The applicant has submitted a Tentative Parcel Map for Condominium Purposes for the project as included separately to this report. Regarding maps, Chapter 16.12 of the Municipal Code requires that the plan must be prepared by a registered civil engineer for all public works improvements to be constructed as a condition of the subdivision and for all site development including (but not limited) to grading, drainage facilities, and structures in accordance with the City standards. Furthermore, plans for all irrigation and landscaping subject to the approval of the Planning Director and a plot plan showing details of the entire development and all improvements to be constructed are required. In addition, the project must be consistent with the General Plan Mixed·Use land use designation and corresponding Municipal Code. Pursuant to Chapter 16.04 of the Municipal Code, the Planning Commission's actions shall be as an advisory agency only, and all actions of the Planning Commission with reference to tract maps shall be reported to the City Council who shall act approve, deny or conditionally approve the map. Given that all proposed entitlements are bundled for review by the Planning Commission and that the Tentative Parcel Map requires approval of the City Council, the Planning Commission Resolution for the project shall provide a recommendation only to the City Council regarding the subject request. Grading Plan Proposed cuts would primarily occur to lower the building pad elevations by approximately 3' to minimize building height. Fill would be placed near the easterly property line for development of private patio areas. Approximately 1, 150 cubic yards of earthwork is proposed including 650 cubic yards proposed as fill and 500 cubic yards exported from the site (which results in approximately 50 truck loads). The grading application is included as Attachment 2. Minor Deviation Section 17.18.040(8)(5) of the RPO zone indicates that building and structures may not occupy more than 30% of the gross lot area. Further, Section 17.66.100(6) permits that a Minor Deviation may be approved for an increase of not more than 10% in the maximum allowable lot coverage. Accordingly, a Minor Deviation is required for the proposed 33% lot coverage. The excess lot coverage provides for slightly larger building footprints in light of the small size of the property. Conditional Use Permit A Condition Use Permit (CUP) is required to establish a Residential Planned Development (RPD) community. Requirements for CU P's are provided in Chapter 17 .68 of the Municipal Code. Section 17.68.010 of the Municipal Code indicates that conditionally permitted uses may be allowed when such uses are necessary to the development of the community, and which uses are in no way detrimental to existing uses or to those permitted in the district. In no case shall a CUP be issued for a specifically prohibited use. Neighborhood Compatibility Section 17.26.020 (Neighborhood Compatibility) of the Municipal Code provides for a review process for residential construction proposals to protect and maintain the established character of all residential neighborhoods. The primary purpose of this review is to ensure that proposals will not create privacy issues, obstruct views, create obtrusive light sources, or establish an unaesthetic architectural appearance when considered from the residential property. Neighborhood compatibility criteria as it relates to the proposed project is described below. 6 7 of 26 1. Natural Amenities . Improvements to residential property shall respect and preserve to the greatest extent possible existing topography, landscaping, and natural features. No major topographical, landscaping or natural features exist on this previously-developed site . Proposed grading is minor and will not result in the loss of natural site amenities . 2. Neighborhood Character. Proposals shall be compatible with the existing neighborhood character in terms of scale of development , architectural style and materials . The Seaview Villas complex surrounds the project on two sides and provides the most visually prominent buildings in relation to the proposed project. The complex consists of neutral-toned buildings with red tile roofs, exposed rafter tails, and wood balconies in a Mission Revival and Spanish Colonial Revival style. The project proposes neutral-toned buildings, flat terra cotta roofs, exposed rafter tails, and wood trellises, all of which are similar to the Seaview Villas complex. In addition, the scale of the proposed development is the similar to the Seaview Villas complex in that the requested RPD zone designation and High Density Residential land use (with a corresponding maximum of 8 units per acre) are the same as the Seaview Villas zoning and land use designations . 3. Scale . Designs should minimize the appearance of overbuilt property to both public and private view. The square footage of the residence and total lot coverage should reflect the rural character of the City and neighborhood . The proposed homes would be surrounded on all sides by landscaped areas and yards that would minimize the appearance of an overbuilt lot. The proposed square footage of the residences, at 2,880 square feet, are larger than the 1,800 to 2,200 square foot Seaview Villas townhomes, but not excessive. The proposed 33% lot coverage would only slightly exceed the permitted 30% and would respect the rural character of the City and neighborhood. 4 . Style . Proposals shall address the following design elements : fa9ade treatments (avoid stark and unbroken walls), structure height(s). open spaces, roof design , appurtenances, mass and bulk. These design elements should be compatible with the existing home and neighborhood and in all instances seek to minimize the appearance of a massive structure. The proposal indicates that building walls and mass would be broken by balconies, trellises and pop- out features. Building height at approximately 22 ' from finished grade would be much lower than the 35 ' maximum permitted, and the roof design is low in pitch. Like the Seaview Villas complex, the project is proposed to be "courtyard" in style such that buildings are surrounded by landscaping and yard areas which also serve to minimize the appearance of building mass. 5. Privacy . Proposals shall maintain an adequate separation between the proposed structures and adjacent property lines. In addition, proposed balconies, decks and windows shall respect the existing privacy of surrounding properties . The proposed residences would be located downslope from the Seaview Villas townhomes to the east and separated by a property line wall and landscaping to ensure privacy between the uses. Given the grade differences between the properties, it is not anticipated that the yard areas or windows of the proposed residences will adversely impact the surrounding property . Further, the approximately 100'- wide roadway widths of both Highridge and Crest Roads accompanied by project setbacks of 20' to 25' ensure privacy to homes to the south and west. 7 8 of 26 6. Views. Designs should respect existing neighboring views . This finding has been met because the proposed homes are located down slqpe from the townhomes above and have been designed with a low roof profile. In addition, the building pads are proposed to be lowered 3' to minimize any potential view impacts . Init ial Stud y and Negati ve Decl ara ti on fo r the Cali forn ia Enviro nm enta l Quality Ac t (CEQA) The proposed development has been defined as a project under CEQA which requires completion of an Initial Study to determine if the project would have significant impacts on the environment. The City contracted with PMC to perform the Initial Study . (The Initial Study/Mitigated Negative Declaration was provided to the Planning Commission on October 9, 2014 and is also available on the City website under What's New/Project Updates/5883 Crest Road.) Staff reviewed the Initial Study and determined that, with proper mitigation as specified in the Initial Study, the proposed project will not have a significant impact on the environment; therefore, staff prepared a Mitigated Negative Declaration for Planning Commission consideration . As required by CEQA, a public comment period for the Mitigated Negative Declaration is be ing conducted. The review period is from October 9, 2014 to November 24 , 2014 . A Notice of Intent to Adopt a Mitigated Negative Declaration was provided to all affected properties within a 500' radius of the project, adjacent cities , and other government agencies. The notice provides a brief description of the project, the Planning Commission Public Hearing date/time/location, and how to obtain detailed information about the project including the Initial Study. The notice, Initial Study, and Mitigated Negative Declaration were filed with the Los Angeles County Clerk on October 8, 2014 and were made available at the Peninsula Center Library . A copy of the project plans, Initial Study, and Mitigated Negative Declaration have been made available at the public counter and on the City's website . RECOMMENDATION Staff recommends that the Planning Commission : 1. Open the Public Hearing; 2. Take Public Testimony 3. Discuss the issues ; 4 . Close the Public Hearing; and 5. Direct staff to prepare a Resolution recommending approval of PA-25-14 to the City Council for the next Planning Commission meeting of December 15, 2014, subject to a condition of approval requiring a Gabrieleno Band of Mission Indians to be present during any and all ground disturbances. EXHIBITS Attached 1. Comment Letters 2. Grading Application Pa25-14 pm 8 9 of 26 ATTACHMENT 1 10 of 26 Page 1 of l Niki Wetzel ----··-----·---· __ ,,_,, _______ _ From: Gabrieleno Band of Mission Indians (gabrielenoindians@yahoo.com] Sent: Wednesday, October 22, 2014 11 :21 PM To: Niki Wetzel; Dr. Christina Swindall Martinez; Matt Teutimez.Kizh Gabrieleno; Tim Miguel; Gary Stickle; Martha Gonzalez. Kizh Gabrieleno · Subject: four Patio-Home Development project 5883 crest road rolling Hills Estates Los Angeles County -Tribal Consultation Native Americans [edit) Today Rolling Hills is a city within Palos Verdes, The peninsula was the homeland of the Gabrielirio Native Americans people for thousands of years. In other areas of the Los Angeles Basin archeological sites date back 8,000 years.l41f51 Their first contact with Europeans in 1542 with Joao Cabrilho (Juan Gabri/Jo), the Portuguese explorer who also was the first to write of them. Chowigna and Suangna were two Tongva settlements of many in the peninsula area, which was also a departure point for their rancherias on the Channel Islands. Dear Niki Wetzel, AJCP Principle Planner This is regards to the above project The Point Vicente Lighthouse on the Palos Verdes Peninsula and ''The project locale lies in an area where the traditional territories of the Kizh(Kitc) Gabrieleflo, villages the National Register of Historic Places. ( Chowi and Suangna) adjoined and overlapped with each other, at least during the Late Prehistoric and Protohistoric Periods. The homeland of the Kizh (Kite) Gabrielenos, probably the most influential Native American group in aboriginal southern California (Bean and Smith 1978a:538). was centered in the Los Angeles Basin, and reached as far east as the San Bernardino-Riverside area. The homeland of the Serranos was primarily the San Bernardino Mountains, including the slopes and lowlands on the north and south flanks. Whatever the linguistic affiliation, Native Americans in and around the project area echibited similar orgainization and resource procurement strategies. Villages were based on clan or lineage groups. Their home/ base sites are marked by midden deposits, often with bedrock mortars. During their seasonal rounds to exploit plant resources, small groups would migrate within their traditional territory in search of specific plants and animals. Their gathering strategies often left behind signs of special use sites, usually grinding slicks on bedrock boulders, at the locations of the resources . Therefore in order to protect our resources we would like to request one of our experienced & :::ertified Native American monitors to be on site during any and all ground disturbances. In all cases, when the NAHC (Native American Heritage Commission) states there are " NO" records of sacred sites'' in the subject area; they always refer the contractors back to the Native American Tribes whose tribal territory is within the project area. This is due to the fact, that the NAHC is only aware of general information on each California NA Tribe they are NOT the "experts" on our Tribe. Our Elder Committee & Tribal Historians are the experts and is the reason why the NAHC wlll always refer contractors to the local tribes. Please contact our office regarding this project to coordinate a NA monitor to be present. Thank You Sincerely, £\ndrew Salas, Chairman 3abrieleno Band of Mission Indians -Kizh Nation ::io Box 393 ~ovina, CA 91723 ;ell (626)926-4131 :imail: gabrielenoindians@yahoo.com Nebsite: www.gabrielenoindians@yahoo.com 10/23/2014 11 of 26 COUNTY OF LOS ANGELES FIRE DEPAH.TMENT ----···-""'"":-'""~""'" .... ~,.. ..... ---- DARYL L. OSBY FIRE CHIEF 1320 NORTH EASTERN AVENLJ.l ~ ,-., '\l ··""' -1 ~ 7 [~" ID) LOS ANGELES CALIFORNU06J.> t) [-~v ;o\~-~ -1 0 I FORESTER & FIRE WARDEN CITY OF ROLLING HILLS ESTATES November 6, 2014 Niki Wetzel, Planner City of Rolling Hills Estates Planning Department 4045 Palos Verdes Drive North Rolling Hills Estates, CA 90274 Dear Ms. Wetzel: MITIGATED NEGATIVE DECLARATION, "5833 CREST ROAD PROJECT (PA-25-14),'' CONSISTS OF THE CONSTRUCTION OF FOUR TWO-STORY, DETACHED PATIO HOMES WITH A SHARED DRIVEWAY, 5833 CREST ROAD, ROLLING HILLS ESTATES (FFER #201400184) The Mitigated Negative Declaration has been reviewed by the Planning Division, Land Development Unit, Forestry Division, and Health Hazardous Materials Division of the County of Los Angeles Fire Department. The following are their comments: PLANNING DIVISION: 1. We hav~ no comments at this time . LAND DEVELOPMENT UNIT: 1. . The statutory responsibilities of the County of Los Angeles Fire Department's Land Development Unit are to review of and comment on all projects within the unincorporated areas of the County of Los Angeles. Our emphasis is on the availability of sufficient water supplies for firefighting operations and AGOURA HILLS ARTESIA AZUSA BALOVVIN PARK BELL BELL GARDENS BELLFLOWER BRADBURY local/regional access issues. However, we review all projects for issues that may have a significant impact on the County of Los Angeles Fire Department. We are responsible for the review of all projects within contract cities (cities that contract SERVING THE UNINCORPORATED AREAS OF LOS ANGELES COUNTY AND THE CITIES OF: CALABASAS CARSON CERRITOS CLAREMONT COMMERCE COVINA CUOAHY DIAMOND BAR DUARTE . EL MONTE GARDENA GLENDORA HAWAIIAN GARDENS HAWTHORNE HIDDEN HILLS HUNTINGTON PARK INDUSTRY INGLEWOOD IRVVINDALE LA CANADA FLINTRIDGE LA HABRA LA MIRADA LA PUENTE LAKEWOOD LANCASTER LAWNDALE LOMITA LYNWOOD MALIBU MAYWOOD NORWALK PALMDALE PALOS VEROES ESTATES PARAMOUNT PICO RIVERA POMONA RANCHO PALOS VERDES ROLLING HILLS ROLLING HILLS ESTATES ROSEMEAD . SAN DIMAS SANTA CLARITA SIGNAL HILL SOUTH EL MONTE SOUTH GATE TEMPLE CITY WALNUT WEST HOLL YWOOI WESTLAKE VILLAG WHITIIER 12 of 26 Niki Wetzel, Planner November 6, 2014 Page 2 with the County of Los Angeles Fire Department for fire protection services). We are responsible for all County facilities, located within non-contract cities. The County of Los Angeles Fire Department's Land Development Unit may also comment on conditions that may be imposed on a project by the Fire Prevention Division, which may create a potentially significant impact to the environment. · 2. The development of this project must comply with all applicable code and ordinance requirements for construction, access, water mains, fire flows and fire hydrants . 3. This property is located within the area described by the Forester and Fire Warden as a Fire Zone 4, Very High Fire Hazard Severity Zone (VHFHSZ). All applicable fire code and ordinance requirements for construction, access, water mains, fire hydrants, fire flows, brush clearance and fuel modification plans, must be met. 4 . When involved with subdivision in a city contracting fire protection with the County of Los Angeles Fire Department, the requirements for access, fire flows and hydrants are addressed during the subdivision tentative map stage. 5 . Every building constructed shall be accessible to the Fire Department apparatus by way of access roadways, with an all-weather surface of not less than the prescribed width . The roadway shall be extended to within 150 feet of all portions of the exterior walls when measured by an unobstructed route around the exterior of the building. 6 . Fire sprinkler systems are required in some residential and most commercial occupancies . For those occupancies not requiring fire sprinkler systems, it is strongly suggested that fire sprinkler systems be installed . This will reduce potential fire and life losses. Systems are now technically and economically feasible for residential use. 7 . Single family detached homes shall require a minimum fire flow of 1,250 gallons per minute at 20 pounds per square inch residual pressure for a two-hour duration . Two family dwelling units (duplexes) shall require a fire flow of 1,500 gallons per minute at 20 pounds per square inch residual pressure for a two-hour duration. When there are five or more units taking access on a single driveway, the minimum fire flow shall be increased to 1,500 gallons per minute at 20 pounds per square inch residual pressure for a two-hour duration. 13 of 26 Niki Wetzel, Planner November 6, 2014 Page 3 8. Fire hydrant spacing shall be 600 feet and shall meet the following requirements : a) No portion of lot frontage shall be more than 450 feet via vehicular access from a public fire hydrant. b) No portion of a structure should be placed on a lot where it exceeds 750 feet via vehicular access from a properly spaced public fire hydrant. c) When cul-de-sac depth exceeds 450 feet on a residential street, hydrants shall be required at the corner and mid-block. d) Additional hydrants will be required if hydrant spacing exceeds specified distances. 9 . The Fire Department approved turning area shall be provided for all driveways exceeding 150 feet in-length and at the end of all cul-de-sacs. 10. Provide a minimum unobstructed width of 20 feet, exclusive of shoulders, except for approved security gates in accordance with Section 503.6, and an unobstructed vertical clearance "clear to sky" Fire Department vehicular access to within 150 feet of all portions of the exterior wall s of the first story of the building, as measured by an approved route around the exterior of the building. Fire Code 503.1.1 & 503.2.1. 11. Streets or driveways within the development shall be provided with the following : a) Provide 36 feet in width on all streets where parking is allowed on both sides. b) Provide 34 feet in width on cul-de-sacs up to 700 feet in length .' This allows parking on both sides of the street. c) Provide 36 feet in width on cul-de-sacs from 701 to 1,000 feet in length. This allows parking on both sides of the street. d) For streets or driveways with parking restrictions: The entrance to the street/driveway and intermittent spacing distances of 150 feet shall be posted with the Fire Department approved signs stating "NO PARKING - FIRE LANE" in three-inch high letters. Driveway labeling is necessary to ensure access for Fire· Department use. -Turning radii shall not be less 14 of 26 Niki Wetzel, Planner November 6, 2014 Page 4 than 32 feet. This measurement shall be determined at the centerline of the road. 12. Should any questions arise regarding subdivision, water systems, or access, please contact the County of Los Angeles Fire Department's Land Development Unit Inspector, Nancy Rodeheffer, at (323) 890-4243 or at nrodeheffer@fire.lacounty.gov. 13. The County of Los Angeles Fire Department's Land Development Unit appreciates the opportunity to comment on this project. FORESTRY DIVISION -OTHER ENVIRONMENTAL CONCERNS: 1. The statutory responsibilities of the County of Los Angeles Fire Department's Forestry Division include erosion control, watershed management, rare and endangered species, vegetation, fuel modification for Very High Fire Hazard Severity Zones or Fire Zone 4, archeological and cultural resources, and the County Oak Tree Ordinance. 2 . Due to the limited amount of information included in your request, we are unable to respond to specific potential impacts. HEAL TH HAZARDOUS MATERIALS DIVISION: 1. Per the submitted information the site was previously occupied by a gasoline service station and a commercial plant nursery. The historical site use may have contributed to onsite ~ontaminations that may exceed the State recommended cleanup guidelines for residential use. It is requested that site is assessed and/or mitigated under oversight of a local or State jurisdictional agency and obtain a "No Further Action" letter prior to grading. If you have any additional questions, please contact this office at (323) 890-4330 . Very truly yours, 4-~,()j\LM~l ~ FRANK VIDALES; CHIEF, FORESTRY DIVISION PREVENTION SERVICES BUREAU FV:jl 15 of 26 CITY OF RANCHO PALOS VERDES CITY MANAGER'S or.:FICE ADMINISTRATION 17 November 2014 VIA ELECTRONIC AND U.S. MAIL Niki Wetzel, AICP, Principal Planner City of Rolling Hills Estates 4045 Palos Verdes Dr. N. Rolling Hills Estates, CA 90274 SUBJECT: Comments in Response to the Notice of Intent to Adopt a Mitigated Negative Declaration for a 4-Unit Detached Condominium Project at 5883 Crest Road (PA No. 25-1'4) Nll<t Dear ~.:..wetzel : The City of Rancho Palos Verdes appreciates the opportunity to comment upon the proposed Mitigated Negative Declaration (MND) for the above-mentioned project. We have reviewed the MND and project exhibits, and offer the following comments: 1. The discussion of Aesthetics in the Initial Study (pp. 22-25) notes that the proposed project is expected to have less-than-significant impacts with respect to the privacy of surrounding properties. Table 111-1 makes specific reference to the impact of proposed balconies or decks upon "the existing privacy of surrounding properties." The Initial Study correctly notes that residences in Rancho Palos Verdes to the south and southwest of the project site will be separated from the project, both horizontally by the ex.isting; improved right·of-way of Crest Road and vertically by the difference in elevation. Nevertheless, the City remains concerned about the potential for privacy infringement upon Rancho Palos Verdes residents as a result · of any 2"d_f\oor decks or balconies along the southerly facades of proposed Units 3 and 4. It is not clear if such decks or balconies are proposed for these units or not, but if they are, the City suggests requiring them .to include a solid, opaque 42- inch-tall barrier around the perimeter, measured from the surface of the deck or balcony. This will protect the privacy of downslope properties in Rancho Palos Verdes while still affording opportunities for ocean and Catalina Island views for future residents of the project. 2 . The discussion of Transportation/Traffic in the Initial Study (pp. 26-27) concludes that the proposed project will have no significant impacts on traffic. The City concurs with this assessment. In a related matter, however, we note that the project proposes to remove and replace existing driveway approaches along Crest 30!140 l·IAWTl-lORNt: BLVD./ RANCHO 11\LOS vrnoc:s. CA ll02l!i·fi391 I (310) 544'£>205 I FAX (310) [)~4-52fll WWWJ'At.OSVEf<l:.lfl3.COM/RPV PmN rw ON r~ECYGl.rn H\Prn -------·---·-·--· .. ·-·- 16 of 26 Niki Wetzel 17 November 2014 Page 2 Road as a part of the project. The driveway approaches, sidewalk and other right- of-way improvements along the Crest Road frontage of the project site are located within Rancho Palos Verdes. As such the project conditions should clearly state that any proposed modifications require the approval of the Rancho Palos Verdes Public Works Department. Furthermore, any other deficiencies in these existing right-of-way improvements should be repaired by the project proponent. 3. The discussion of Air Quality and Noise impacts in the Initial Study (pp. 28-38) identify less-than-significant air quality and noise impacts during project construction. The Rancho 1=>a1os Verdes residences located closest to the project site-and, therefore, most likely to be affected by dust and noise-are located on Highridge Road in the Seacrest neighborhood and Sail View Avenue in the Seabreeze neighborhood of Rancho Palos Verdes. The City of Rancho Palos Verdes agrees that the proposed project seems unlikely to result in significant construction-related impacts to surrounding properties. However, the City of Rancho Palos Verdes asks to be kept apprised of project status as it moves through the building permit process so that we will be able to advise our residents and City Council about the project's construction status, and to refer residents to the appropriate contacts in the event of any construction-related complaints. Again, thank you for the opportunity to comment upon this project. If you have any questions or need additional information, please feel free to contact me at (310) 544-5226 or via e-mail at kitf@rpv.com. Sincerely, ~~ Kit Fox, AJ6P Senior Administrative Analyst cc: Mayor Duhovic and City Council Carolynn Petru, Acting City Manager Joel Rojas, Director of Community Development Michael Throne, Director of Public Works M :\Border lssues\5883 Crest Road\20141117 _MNDComments.dacK 17 of 26 ATTACHMENT 2 18 of 26 GRADING APPLICATION CITY OF ROLLING HILLS ESTATES PLANNING DEPARTMENT 4045 Palos Verdes Drive North Rolling Hills Estates, CA 90274 Telephone-(310) 377-1577 Fax-(310) 377-4468 www .RolllngHlllsEstates-Ca .go v THIS GRADING PERMIT REVIEW SHALL AUTHORIZE ONLY THE GRADING WORK ft EOU ES~EE>--~'°' AND SHALL NOT CONSTITUTE APPROVAL OF OTHER STRUCTURES SHO IJ't N··ON "YT H E GRADTNG ) PLAN. Ji . t/lt,,. l;y OWNER d V>;J I C./-f k). DATE .g f 1 ft '--"! < -·A I ~ .• #·" ,_ ENGINEER ~a /J 11-1 !f ,,q·~r IY' fl"1J .~f ()v LI CENS E # /Z6{::" .g 11·t,O CONTRACTOR fll .P · LICENSE # ~---------------- LO CAT 10 N (9 8' J C-1~.£/:J /<,o·l}'J;:;. ~:If . f;. PROJECT DESCRIPTION ------------------------ ( EXTENT OF GRADING A. B. c . WILL THIS APPLICATION INVOLVE THE IMPORTATION OF ACCEPTABLE FILL MATERIAL? . 1. JF YES, HOW MANY CUBIC YARDS? •:)JO' CUBIC YARDS ,,,,--.. ,r, WILL THIS APPLICATION INVOLVE THE EXPORTATION OF/v /,\ J EARTH MATERIAL? f ~ ~ J 2. IF YES, HOW MANY CUBIC YAR U$_~ ~ 0.0 C IJ ~Q .. X6.R.9 S . _/'..._ \ _...k:..-:_ ,) --~"· WILL THE AMOUNT OF FILL EQUAL THE AMOUN T OF CUT? EXPLANATION l/o .c"; "fl7-f /~bpo.1'.(: ~, <l)<i/ J ri ,,,..c; Ct!-rJ .~f; /NI~'-'i ~& ... (, oW€-x t .0" TD .10 JN I (Vl_l -c-e ·r hf· f: p.·tof:· ):/1-E l?)t r ·~ ;t.f:r{:, r,<.,r.iJ 'G-c-r~, f.. ·~ /'v c r-1 Al(,, ~·- )lo )lo . /X/· ;'f'f .( &<1l3.Jc.. /l"ft<.1:1 ... < 1p Jc.:. f-/<-Fc~.r i ·"!Nt1 . £. • .. ? /C f' c; •. ,. A" {/{)'IN r.;~ G ) 1-;<,4'1) f fh I ~if') , a r Uj<1.· 1() .:> ' • ,;,_, 1}t f-.• 1..., JA; (.,-1) /..,;-'tJ f-/4'{ t /~·.£ .( V v ·1' C I.? f' rt-.trn-1 .+· l ; r-j ·vlf1 N c..e ti . ~f~l!v/_... / D. E. WILL THIS PROPOSAL CUT INTO AN EXISTING SLOPE? 1. IF YES, WHAT IS THE MAXIMUM LENGTH AND DEPTH OF CUT SLOPE? LE NGTH, ___ _ DEPTH ___ _ 2. IF YES, WHAT IS THE RESULTANT RATIO? 3. IF YES, WHAT IS THE TOTAL NUMBER OF CUBIC YARDS BEING REMOVED? WILL THIS PROPOSAL FILL AN EXISTING SLOPE? 1. IF YES, WHAT IS THE MAXIMUM LENGTH AND DEPTH OF THE FILL SLOPE? LENGTH /'J 0 D EPT H & fr:..r · 2. IF YES, WHAT IS THE RESULTANT SLOPE RATIO? __ _ 3. IF YES, WHAT IS THE TOTAL NUMBER OF CUBIC YARDS BEING FILLED? 'jt/. ./;f!C/f:..-f 1vv -;/XI/DIV 6 &-Prtf' ft4-r>/'€f.-,ry V;_.ar ~ .ff 1,,, IJ>-;i /"utrrir--, W!Vf/ f'o C~'ert ;r S (!Jl-1'?i1A5 _ ,;rV .&t1'1-0 ,.,::r;t.51"f· .5'" t-.-1r 1N ·:~-r....fvf i,,.. HYDROLO GY ~f' J7-)f:. ft-l..of'~A/y' fa Tl-:J~ rCif-/' r I . A. WILL THIS PROPOSAL ALTER NATURAL DRAINAGE PATIERNS? B. c. WILL THIS PROPOSAL RESULT IN CONCENTRATION OF STORM WATER RUN-OFF? WILL STORM WATER BE DISCHARGED INTO AN ACCEPTABLE DRAINAGE FACILITY? r '::. -~···· ~-·· D. WILL THIS PROPOSAL RESUL r1N 'f:i ow PATTERNS WHICH CAUSE WATER TO BE DIRECTED ONTO ADJACENT PROPERTIES? 1. IF YES, HAS TH·E.·WRITIEN APPROVAL OF THESE · PROPERTY OWNERS BEEN OBTAINED? E. WILL THIS PROPOSAL INSURE POSITIVE DRAINAGE AWAY FROM ALL STRUCTURES AND IMPROVEMENTS? F. WILL THIS PROPOSAL ADVERSELY AFFECT THE HYDROLOGY OF OTHER PROPERTIES? 2 /.fo . 110 7 ,Yt /.- !lo ·. -~ Yt1 __,,..,,... f./ t/ 20 of 26 G. WILL THIS PROPOSAL RESULT IN ANY EROSION? 1. IF YES, WHAT MEASURES HAVE BEEN TAKEN TO ENSURE EROSION PROTECTION? EXPLANATION ______________ _ GRADING METHODS A. B. WILL THIS PROPOSAL REQUIRE THE USE OF HEAVY EQUIPMENT? 1. IF YES,.WHAT MACHINERY WILL BE USED? EXPLANATION .f"""".f(V'V ./c-t<J,,f' 6~v.1~6NJ f;Jl1 '7f c.-vf v/CJ> ;Pr!(, ~. l/'f?vf' 4~7<·~ ./t'1"'e WILL THIS PROPOSAL INVOLVE THE USE OF TRUCK TRANSPORT? 1. IF YES, WHAT CAPACITY OF VEHICLE AND WHAT HAUL ROUTE IS REQUESTED? CAPACITY: /o CUBICYARDS HAUL ROUTE r: fS , b · C . DESCRIBE METHODS OF DUST CONTROL TO BE EMPLOYED DURING GRADING. EXPLANATION ... /f',1t Iv'"? 1/ .. ·•: t) /;?.v/ ;<-C/1.'i 1.1ff1-. o L-~--" ~ 6k./r/f<..!J J {.J,,. f!: Ci· t.}) ;,e, e,; r~ Jl / ca J.J Cf. GRADING COMPATIBILITY A. WILL THIS PROPOSAL RESPECT AND PRESERVE NATURAL AMENITIES, INCLUDING TOPOGRAPHY, LANDSCAPING AND NATURAL FEATURES? 3 '/_t~ - t_&J - 21 of 26 · B. c. D. E. F. WILL THIS PROPOSAL PRESERVE OPEN SPACE AND RESPECT RESPECT THE PRIVACY OF SURROUNDING PROPERTIES? EXPLANATION ________________ _ WILL THIS PROPOSAL INCORPORATE EXISTING AND/OR ADDITIONAL LANDSCAPING TO ENSURE COMPATIBILITY WITH SURROUNDING PROPERTIES? EXPLANATION------------=-------- WILL THIS PROPOSAL RESPECT AND MAINTAIN EXISTING PUBLIC AND PRIVATE VIEWS? WILL THIS PROPOSAL COMPLY WITH THE OBJECTIVES OF THE (ff... NEIGHBORHOOD COMPATIBILITY ORDINANCE? EXPLANATION ,ft,.J.tJ-Ct#r f&'-4 -VJb.-J / 1/1;;:.,,&/f/r /.j; D' 1· ,Rf;I( 1e wt!) f t.-f'-tN J. /Iv /1 o ll &:'Tfc ,.;-N-a · ,e> 8 J e '-nor~) TO /";'a ;i ,.J i:::<-r · IJ J f A /r.>,J'&p . " WILL THIS PROPOSAL COMPLY WITH ALL CONDITIONS AND ~it;)- REQUIREMENTS OF THE CITY OF ROLLING HILLS ESTATES GRADING ORDINANCE (MUNICIPAL CODE 17 .07.010)? forms/grading updated 10/23/07 4 22 of 26 5883 CREST ROAD PROJECT (PA-25-14) RECE!VEO DEC D 1 2014 RESPONSES TO COMMENTS ON THE INITltL STUDY AND PROPOSED MITIGATED NEGATIVE DECLARATION PERSONS, 0Rt NIZATIONS, AND PUBLIC AGENCIES THAT COMMENTED ON THE PROPOSED MITIGATED NEC ATIVE DECLARATION The public re ,iew period for the Initial Study and Proposed Mitigated Negative Declaration (MND) for thd 5883 Crest Road Project commenced on October 9, 2014, and ended on November 24, j 2014. The table below lists the persons, organizations, and public agencies that provided corn ents to the City of Rolling Hills Estates on the Proposed MND. Gabrieleno Band ~f Mission Indians -Kizh Nation Andrew ~alas, Chairman Cow1ty of Los An geles Fire Department ··-- Vidales, f rank City of Rancho Pa 1os Verdes Fox, Kit COMMENTS AND RESPONSES '\ 0/22/2014 1116/2014 11/17/2014 The comment and recommendations received on the Proposed MND, along with the lead agency's resp,onses to the environmental points that were raised, are presented herein. All comments on J the Proposed MND were submitted in written form and are included in their entirety. Each point raised in these comment letters was assigned a number (e.g., XY-1 ), as noted on the comment letters included in this section. The lead agency's response to each enumerated c omment is provided after the respective cornrnent letter. City of Rolling Hi Is Estates November 2014 5883 Crest Road Project Initial Study and Proposed Mitigated Negative Declaration 1 23 of 26 RESPONSES TO COMMENTS 17. November 2014 NI i Wetzel, AICP, Principal Planner Cl 1 y of Rolling Hills Estates 4045 Palos Verdes Dr. N. R lling Hills Estates, CA 90274 CITY Mt\NAGER 'S OFTICE AIJMINISrT<ATION VIA ELECTRONIC AND U.S. MAIL Sl!IBJECT: Comments in Response to the Notice of Intent to Adopt a Mitigated Negative Declaration for a 4-Unit Detached Condominium Project at 5883 Crest Road {PA No. 25-14) Nl/<I Dear ~:..Wetzel : T e City of Rancho Palos Verdes appreciates the opportunity to comment upon the I pr · posed Mitigated Negative Declaration (MND) for the above-mentioned project. We RPV-1 ha e reviewed the MND and project exhibits , and offer the following comments : 1. The discussion of Aesthetics in the initial Study (pp . 22-25) notes that the proposed project is expected to have less-than-significant impacts with respect to the privacy of surrounding properties . Table 111 -1 makes specific reference to the impact of proposed balcon ies or decks upon "the ex isting privacy of surrounding properties .• The Initial Study correctly notes that residences in Rancho Palos Verdes to the south and southwest of the project site will be separated from the project, both horizontally by the existi ng , improved right-of-way of Crest Roed and vertically by RPV-2 the diffe ren ce In elevation . Nevertheless, the City remains concerned about the potential for privacy infringement upon Rancho Palos Verd es residents as a result of any 2"d·floor decks or balconies along the southerly facades of proposed Units 3 and 4. It Is not clear if such decks or balconies are proposed for these units or not, but if they are, lhe City suggests requiring them to include a solid . opaque 42 - lnch -tall barrier around the perimeter, measured from the su rface of the deck or balcony. This will protect the privacy of downslope properties In Rancho Palos Verdes while still affording opportunities for ocean and Catalina Island views for future residents of the project. 2. The discussion of TransportationfTraffic in the Initial Study (pp . 26-27) concludes that the proposed project wlll havfl no significant impacts c>n traffic. The City RPV-3 concurs with this asse .ssment. In a related matter, however, we note that the project proposes to remove and replace existing driveway approaches along Crest :Hi~l40 ~14.W'ilfORN[: BLVD./ l~~\!1GHO \f\L(.~; \llf\'OES: CA !10i!'l!1-f1391 /('..HO) !)-l<l-b7.0!J J h\X (:JH,I) !l4-i S~91 \\\\i\WAIDl:'\lf::kfl:~• '.J'..JMtfil '':.' ! •r?~rr.rl\Y-11\tc.vl:~~-t> l'\l'i i? CUy of Rollfog J, &t•t" 5883 Crest Road Project Initial Study and Proposed Mitigared Negative Declaration 11 November 20 J 4 24 of 26 RESPONSES TO COMMENTS Niki Wetzel 17 November 2014 Page 2 Letter RPV Continued Road as a part of the project. The driveway approaches, sidewalk and other right- of-way Improvements along the Crest Road frontage of the project site are located within Rancho Palos Verdes. As such the project conditions should clearly state RPV-3 that any proposed modifications require the approval of the Rancho Palos Verdes Public Works Department. Furthermore, any other deficiencies in these existing cont. right-of-way improvements should be repaired by the project proponent. 3. The discussion of Air Quality and Noise impacts in the Initial Study (pp. 2B-3B) Identify less -than-significant air quality and noise impacts during project construction. The Rancho l,alosVerdes residences located closest 10 the project site-and, therefore, most likely to be affected by dust and noise-are located on Highridge Road in the Seacrest neighborhood and Sail View Avenue in the RPV-4 Seabreeze neighborhood of Rancho Palos Verdes. The City of Rancho Palos Verdes agrees that the proposed project seems unlikely to result in significant construction-related impacts to surrounding properties. However, the City of Rancho Palos Verdes asks to be kept apprised 1Jf project status as it moves through the building permit process so that we will be able to advise our residents and City Council about the project's constrL1ction status, and to refer residents to the appropriate contacts in the event of any construction-related complaints. Again, thank you for the opportunity to comment upon this project. If you have any I questions or need additional information, please feel free to contact me at (310) 544-5226 RPV-5 or via e-mail at kitf@rpv.com. Sincerely, &.7 Senior Administrative Analyst cc : Mayor Duhovic and City Council Carolynn Petru, Acting City Manager Joel Rojas, Director of Community Development Michael Throne, Director of Public Works M:\Bordor lssues\&883 Crest Road\20141117 _MNDCommonts .docx 5883 Crest Road Project Initial Study and Proposed Mitigated Negative Dec/ar<1tion 12 City of Rolling ills Estates Nov mber 2014 25 of 26 RESPONSES TO COMMENTS RESPONSES RPV-1: lntrodu • tory remarks are made. l\Jo response is required. RPV-2: The c o rnenter raises privacy issues, which are beyond the scope of CEQA, but will be provided to d cision-makers for their consideral'ion. While outside of the scope of environ mental impacts pursu , nt to CEQA, subsection Ill. Aesthetics, of the project's 15/MND discusses privacy in the context of the City of Rolling Hills Estates' Neighborhood Compatibility Ordinance. In regard to privacy, th IS/MND notes, "the residences to the south, across Crest Road [in the City of Rancho Palos Verdes], would be separated by a landscaped median in addition to the roadway ilsel and by changes in elevation." The closest residences to the south are approxima1e ly 110 feet from the project site, a sufficient distance to respect residen1"ial privacy in a suburban se tin g . RPV-3: The co1 menter expresses concurrence with the 15/MND's conclusion that the proposed project will nqt cause any significant traffic impacts. The commenter further notes that Crest Road, including the sidewalk fronting the project, is within the City of Rancho Palos Verdes and requests that i'e project's conditions state that any proposed modification to the Crest Road right-of-way ( .g., removal of driveway approaches and sidewalk modifications) require the approval of th i City of Rancho Palos Verdes Public Works Department. The project's Conditions of Approval will incorporate this sugges1ion. RPV-4: The c l mmenter expresses concurrence with the IS/MND's conclusions regarding air quality and n · ise impacts from project construction. The commenter further requests that the City of Ranch Palos Verdes be kept apprised of the project's construction schedule and status . This requested is noted. City of Rolling Hills Estates staff will continue to coordinate with staff from the City of Roi cha Palos Verdes on this project. RPV-5: Closi ng remarks are made. No response is required . City of Rolling Hi Is Estates November 2014 5883 Crest Road Project Initial Study and Proposed Mitigated Negati.ve Declaration 13 26 of 26 From: Sent: To: Subject: Kit Fox Tuesday, December 02, 2014 10:24 AM Teresa Takaoka FW: Very Important and Sad anniversary Late Correspondence for Item C (Border Issues -Rancho LPG) Kit Fox, AICP City of Ra.ncho Palos Verdes (310)544-5'2'26 ki t£@rpv.com From: Janet Gunter [mailto:arrianeS@aol.com] Sent: Tuesday, December 02, 2014 10:23 AM To: MrEnvirlaw@sbcglobal.net; noelweiss@ca .rr.com ; amartinez@earthjustice .org ; det310@juno.com; jody.james@sbcglobal.net; connie@rutter.us; igornla@cox.net; dwgkaw@hotmail.com; marciesmiller@sbcglobal.net; jhwinkler@me .com; dlrivera@prodigy.net; mandm8602@att.net; peter.burmeister@sbcglobal.net; bonbon90731@gmail.com; rregSS@hotmail.com; claudia .r .mcculloch@gmail.com; chateau4us@att.net; leneebilski@hotmail.com; darzavalney@aol.com; sarahnvaldez@gmail.com; burling102@aol.com; pmwarren@cox.net; hanslaetz@gmail.com; fbmjet@aol.com; lljonesin33@yahoo .com; ksmith@klct.com; paul_h_rosenberg@hotmail .com; lhermanpg@cox.net; pjwrome@yahoo.com; katyw@pacbell.net; jwebb@usc.edu; c.jjkondon@earthlink.net; rcraemer@aol.com; goarlene@cox.net; nancy.kalthoff@yahoo.com; johngoya@westoceanmd.com; hvybags@cox.net; robertrnch@aol.com Cc: lara.larramendi@mail .house.gov; lisa.pinto@mail.house.gov; rachel.zaiden@mail.house .gov; rob .wilcox@lacity .org; david.wulf@hq.dhs.gov; Kit Fox Subject: Fwd: Very Important and Sad anniversary Please take the 6 min. necessary to watch this. Rancho LPG is a glaring example of what the CSB is talking about. It WILL happen ......... . ps. I hope you all had a nice Thanksgiving! -----Original Message----- From : Carl Southwell <carl.southwell@gmail.com> To : Pryor, Lawrence <lpryor@usc .edu>; Janet Gunter <arriane5@aol.com> Sent: Tue , Dec 2, 2014 9:20 am Subject: Sad anniversary https ://www. youtu be. com/watch?v= HZirRB32qzU Carl Southwell Contact me at (use whichever you prefer) : carl.southwell@gmail.com carl .southwell@riskandpolicy.org 1 C. Visit : www .pressfriends.org Making writing fun for elementary school kids, empowering kids to become mentors and leaders, and creating friendships among youth from diverse backgrounds. 2 From: Sent: To: Cc: Subject: Attachments: Jacob, Ronald Conrow < Ronald.Conrow@plainsmidstream.com> Tuesday, December 02, 2014 1:44 PM jacob haik Uacob.haik@lacity.org) timothy.lippman@asm.ca.gov; eric.guerra@asm.ca.gov; Zivkovic, Jennifer (Jennifer.Zivkovic@sen.ca.gov); Houterman, Justin; 'Hon. Rudy Svorinich, Jr.'; lisa.pinto@mail.house.gov; rkim@lacbos.org; ryan.ferguson@lacity.org; Doane Liu; octaviano.rios@lacity.org; dan.tillema@csb.gov; CC Gunter_Rancho worst case fabrication Gunter_Rancho worst case fabrication.pdf; EPA_FOIA Release to Gunter.pdf; EPA_Legal Validation of Rancho Worst Case.pdf I trust your trip to China with Councilman Buscaino and Mayor Garcetti was fruitful and enlightening? Welcome back to the USA. As is our custom, Rancho has endeavored to keep CD15 informed concerning the dissemination of false information by community activists about the Facility. Attached are letters from Janet Gunter and Marcie Miller which claim that Rancho has used the "toxics" formula for calculating the "worst case" scenario and thereby has submitted an inaccurate offsite impact blast radius to endpoint. These letters were posted and downloaded from the City of Rancho Palos Verdes website under Border Issues for the December 02, 2014 City Council meeting. As is their prerogative, the City of RPV allows posting of such information without vetting for accuracy. As you know, the City of RPV has no jurisdiction over the Rancho facility. Furthermore, Rancho's "worst case" scenario vetted by the EPA using proprietary EPA software clearly shows it does not impact any residents of RPV, including Eastview, the closet community to the Facility. It is important to note, Ms. Gunter is making this claim knowing that it is in fact false! Also, attached are the "search results" downloaded from the Freedom of Information Act (FOIA) website which shows six different FOIA requests made by Janet Gunter to the EPA indicating the dates submitted, tracking number, and phase (closed/open). I would like to draw your attention to Tracking Number EPA-R9-2014-002842. The web page shows that 73 records (documents) were released to Ms. Gunter by the EPA under this request. The actual list of the 73 documents is not printable, however, the entire list can be viewed on the FOIA webpage. At the conclusion of this attachment is a letter from Enrique Manzanilla of the EPA informing Ms. Gunter of the documents released to her under EPA-R9-2014-002842. The final attachment is an e-mail correspondence from EPA Region 9 Attorney Andrew Helmlinger and Plains third party legal counsel Cliff Mc Farland dated December 10, 2013 and is part of the 73 documents released to Ms. Gunter. This legal to legal correspondence is in response to an e-mail from me to Mary Wesling of EPA Region 9 concerning prior bulleted e-mails by Janet Gunter where she states Rancho's "worst case" is 3+ miles using EPA calculations. As a result, I requested the EPA review and calculate the accuracy of Rancho's "worst case" as submitted in our RMP. EPA Attorney Helmlinger clearly states the EPA has in fact calculated Rancho's RMP to be 0.5 miles based upon the EPA regulatory formula. Helmlinger further states that it is "not 3.0 miles as Ms. Gunter asserts". It sh<;>uld be noted this is legal to legal validation of Rancho's "worst case" scenario. Therefore, any claim that Rancho's "worst case" is greater than 0.5 miles is erroneous and to state Rancho has used the "toxics" formula is false and not in accordance with EPA regulation 40CFR68. Using EPA parameters and methodologies within the regulation, site specific information is entered into EPA proprietary software RMP* Comp which automatically calculates the results. Additionally, butane is listed in RMP* 1 C. Comp drop down selection category box as a flammable and not a toxic. RMP* Comp does not allow the user to enter the wrong product classification information and continue with the offsite calculation. It is certainly within any citizens right to exercise the FOIA process to acquire information from federal agencies. However, it is shameful to have requested and acquired the information via FOIA and to disregard the facts. Moreover, it is disingenuous for anyone to continue disseminating false information in order to generate fear-mongering within the local community with the sole purpose of giving relevance to their own "cause celeb". Per law, Rancho's RMP as vetted by the EPA as being accurate is on file for public review at the LAFD/CUPA office in downtown Los Angeles. Please advise should CD15 require additional information on this subject matter or anything related to the Rancho LPG Holdings Gaffey Street facility. Regards, Ron Conrow Western District Manager Plains LPG Services, LP 19430 Beech Avenue Shafter, CA 93263 Office: 661-368-7917 Cell: 661-319-9978 ronald.conrow@plainsmidstream.com This message is intended only for the use of the individual or entity to which it is addressed. This message, including any attachments, may contain information that is privileged, confidential and exempt from disclosure under applicable law. If the reader of this message is not the intended recipient, you are notified that any dissemination, distribution or copying of this communication is strictly prohibited. If you have received this communication in error, please contact the sender and delete this message and any attachments from your system. 2 From: Sent: To: Subject: Late correspondence Ara Michael Mihranian Ara Mihranian Tuesday, December 02, 2014 8:26 AM Teresa Takaoka FW: Marymount East Parking Lot compliance issues, OUTDOOR LIGHTING TEST Deputy Director of Community Development HO f1\Los VERDES JJ Do you really ne ed to print this e-mail? l his e-ma:I n'essa9e co11t,1ins inforrnation tidongin~i to the City of Rancho Palos Verdes, which may be privileged, confidenti'11 and/or protected frorn rfo;c!osure. The inforrnatio11 is intenrled only for 11.se of the individual or i~ntity named. Unauthorized dissrmin.otion, distribution, or copyin9 is strictly prohii.iited. If you received rt1is email in error, rn· 0re not an intencJe<l ri"cipient, please notify trie send(~!' immediately. Thank you for your assistance ancJ cooperation. From: Diane Smith [mailto:radlsmith@cox.net] Sent: Monday, December 01, 2014 4:01 PM To: Ara Mihranian Cc: PC Subject: RE: Marymount East Parking Lot compliance issues, OUTDOOR LIGHTING TEST I asked the Planning Commission about how I should approach the Marymount lighting but they did not respond. The reason I asked the Planning Commission was because on October 25, 2011 the Planning Commission requested a Staff Report of how exterior lighting for proposed non-residential development projects is reviewed by Staff. On January 24, 20~2 the Planning Commission felt that the City should have a.more specific set of rules or codes to give project applicants so that they can integrate acceptable exterior lighting into their proposed projects without having to guess what will be accepted to the City. Seven months later, on August 14, 2012, the Community Development Director submitted the Staff Report to the Planning Commission regarding how the light is reviewed after said projects are constructed. The Planning Commission created a three-member sub-committee {Commissioners Gerstner, Leon and Tomblin) and these commissioners were to review RPV's current lighting standards and compare those standards with other similar cities . I assumed our planning department would apply rigid and strict outdoor lighting requirements to maintain peace and tranquility, open space, view and semi-rural atmosphere of the Peninsula. It has been over three years and still the outdoor lighting issue has not been resolved. 1 3 The fence has helped immensely for privacy and bollard lighting. The overhead lighting, in my opinion, is not adequately shielded and does not comply with out outdoor lighting code. would like to have a simple test -where I can see the vehicles (not the unseen car test) with their lights on and see the results of the lighting contractor with the parking lot fully lit in the appropriate manner according to our city code. Our outdoor lighting code states that "testing shall be done with the entire facility illuminated -this was never done. Full text of the code is : 17.56.040 -Outdoor lighting for nonresidential uses.2~ No outdoor lighting shall hereafter be installed in any nonresidential district, except in accordance with the provisions of this section. A. Prior to the issuance of the first certificate of occupancy, a lighting plan prepared by a lighting contractor, which shall include the location, height, number of lights, wattage, estimates of maximum illumination on site and spill/glare at property lines, and in conformance with the following standards and criteria, shall be submitted for approval by the director. I. No one fixture shall exceed one thousand two hundred watts and the light source shall not be directed toward or result in direct illumination of a parcel of property or properties other than that upon which such light source is physically located. Wattage for nonincandescent lighting shall be calculated using the multiplier values described in Section 17.56.030 (A) of this chapter. 2. No outdoor lighting shall be permitted where the light source or fixture, iflocated on a building, is above the line of the eaves. If the light source or fixture is located on a building with no eaves, or if located on a standard or pole, the light source or fixture shall not be more than ten feet above existing grade, adjacent to the building or pole. 3. All estimates or testing shall be done with the entire facility illuminated. 4. Testing equipment shall be a calibrated gossen panalux electronic 2 or an equal approved by the director. B. The director may approve deviations which exceed the standards set forth in Section 17.56.040(A)(l) through (A)(3) of this chapter, when the director finds that such deviations are required for public safety." (emphasis added) Reference to the "light source" should include vehicles since vehicle headlights are designed to illuminate downward and out. We residents objecting to the lights are downslope and were never ever considered before approval and, in fact, written objections (June and July 2013) were totally ignored before the August 6, 2013 initial approval. So, I think it is at the very least mean that Marymount blindsided me after the Neighborhood Meeting by supposedly having a car drive around with headlights on last week and now refuses my request to have an SUV, truck and Van drive around with headlights on. Maybe we won't see anything from the trucks, SUVs and Vans, just like the car and everyone will only have to deal with the overhead lights. Diane Smith 2 From: Sent: To: Cc: Subject: Dear Councilmembers: Jim Reeves <JReeves@marymountcalifornia.edu> Tuesday, December 02, 2014 1:58 PM cc Michael Brophy RE: Marymount California University -Follow Up Review of East Parking Lot I am submitting these comments on the referenced agenda item as I am not able to attend this evening's meeting, although Dr. Brophy will be present to address any general concerns. As a preliminary matter, I want to thank Mr. Mihranian for his efforts and cooperation in working constructively with Marymount so that the reasonable concerns of our neighbors and the City Council were addressed and the additional improvements installed in a manner that was mutually satisfactory. Having worked closely with Mr. Mihranian over the past year on this project, I concur with his assessment of the effectiveness of the improvements in implementing the conditions of approval. Although not specifically noted in the staff report, last week I accompanied Mr. Mihranian on a site visit to three homes on San Ramon to view the parking lot. Marc Harris indicated he was quite happy with the results of the project and noted that he had not seen smoking or students gathering. When visiting the back yards of Diane Smith and Laura Mcsherry, we had two cars parked, headlights on, facing the east from the upper level of the lot. We could not see the headlights from those homes. We also asked campus security to back out and drive around the lot. We still could not see headlights. As the parking lot is primarily intended for and used by passenger vehicles, we do not believe the fencing needs to be raised any higher. With respect to the comment from "some" neighbors that all light fixtures should be fully screened from the views of neighbors, this is clearly not an appropriate or achievable condition for any private property within the City. Finally, with respect to set up activities for the annual graduation ceremony, which is proposed to be held on the East Parking Lot this year, the University has no objections to revising the SUP to better coordinate these activities with City staff. Thank you for your consideration of these comments . Sincerely, Jim Reeves Sr. Vice President Finance & Administration Marymou nt California University (310) 303-7330 J Reeves@Marymou ntCa liforn ia. ed u 1\1ARYMOUNT CAl.lJIORNiA li\11VEHS.ITY 1 3 . CITY OF RANCHO PALOS VERDES TO: FROM: DATE: SUBJECT: HONORABLE MAYOR & CITY COUNCIL MEMBERS CITY CLERK DECEMBER 1, 2014 ADDITIONS/REVISIONS AND AMENDMENTS TO AGENDA Attached are revisions/additions and/or amendments to the agenda material received through Monday afternoon for the Tuesday, December 2, 2014 City Council meeting: Item No. 3 Description of Materials Email exchange between Diane Smith and Deputy Community Development Director Mihranian Respectffibmitted, ~~L Carla Morreale W:\AGENDA\2014 Additions Revisions to agendas\20141202 additions revisions to agenda through Monday afternoon.doc From: Sent: To: Cc: Subject: Hi Diane, Ara Mihranian Monday, December 01, 2014 2:30 PM Diane Smith Carolynn Petru; Joel Rojas; Carla Morreale; Teresa Takaoka Re: Marymount East Parking Lot compliance issues, OUTDOOR LIGHTING TEST I will look into the foot candles question you are asking about. Given that, have you sent this email to the city council? I will include it as late correspondence but you may want to email it now to cc@rpv.com to give the council adequate time to read your comments and consider your requests. · Ara Sent from my iPhone On Nov 28, 2014, at 11 :55 AM, Diane Smith <radlsmith@cox.net> wrote: Dear Ara and Leza, Regarding the glare and spillover of light from Marymount's East Parking Lot, your requirement "The light emitted by the light bulbs in the standards ... may not exceed 1700 lumens." does not reveal to the City Council how much light is delivered to the surface of the parking lot. Lumen output is of the bulb in the fixture only -it is not a measure of how much light is in the space. I am objecting to the overspill and GLARE from the light fixtures and I don't know how much noise the fence buffers because Marymount and City Staff realize the students are not all parking there. The City Council needs to know how many footcandles you are measuring in the parking lot and how that complies to minimum safety standards: "152) Parking and Security lighting shall be kept to minimum safety standards and shall conform to City requirements" {emphasis added) Because of your limitation of 1700 lumens, I asked both the School District and Rancho Palos Verdes Department of Public Works to compute the lumens used in their high school and City Council meeting parking lot (Hesse Park) and they told me 1580 lumens. Based on that comparison I accused City Staff of allowing Marymount more lumens than the minimum safety standard and therefore violating City's own code. Now I find out that I should have asked : "How many footcandles are you measuring in the parking lot? In view of: 1) Marymount's numerous violations of their permits {timely construction of fence, Gala event violations of noise,. exceeding set-up time by 2.5 hours, number of tents, admitted discrepancy in enrollment, etc.) and failure to effectively stop Marymount from these continuous violations; 1 3 2) Marymount's discouraging students from parking in the parking lot this semester by charging $150 parking fees; 3) RPV Traffic Safety Commission's opposition to Staff's recommendation for imposing permit parking on community to discourage students from parking on neighborhood streets; 4) Twarting of City Staff's ability to conduct adequate noise study (Items 2 and 3 above) and complete truck, SUV & Van vehicle headlight study; 5) Failure of City Staff to conduct appropriate light testing, i.e. measuring of footcandles in Marymount's east parking lot to assess glare and overspill as compared to minimum safety standards (high school and community parking lots in residential areas). I hope you will reconsider your present recommendation to the City Council and amend your Report to recommend an additional 6-month review so that these and other issues may be properly addressed when Marymount is in compliance with their Conditional Use Permit. This really is exhausting but I am afraid that attention to detail is important in order to avoid disasters like what happened to Lomita homeowners with the erection of Green Hills mausoleum 8 feet from their property. Thank you for your patience and understanding. Diane Smith From: Diane Smith [mailto:radlsmith@cox.net] Sent: Friday, November 28, 2014 11:05 AM Subject: RE: LIGHTING COMPANY Thank you so much for your quick response. As you can tell this parking lot is driving me nuts . Actually, the 6' vinyl fence they installed greatly reduced the invasion of privacy and bollard lighting. I volunteer at the Bob Hope USO center at LAX. Last night I met another volunteer, Florence, who had retired from working for 40 years for a commercial lighting company. She told me that I have been asking the wrong questions. The City required Marymount to keep lighting to minimum safety standards. "152) Parking and Security lighting shall be kept to minimum safety standards and shall conform to City requirements" The City allowed Marymount 1700 lumens in light fixtures . I confirmed with the School District and the City Department of Public Works that their parking lots use 1580 lumen light fixtures . 152) .... There shall be no light spillover onto residential properties or halo into the night sky. The light emitted by the light bulbs in the standards must be of a warm hue (i.e., not white/blue) and may not exceed 1700 lumens." Florence said I should ask: "How many footcandles are you measuring in the parking lot? Lumen output is of the bulb in the fixture only -it is not a measure of how much light is in the space . Florence has in her possession a device that measures footcandles. She is going to demonstrate to me how to use the device so that I can measure the footcandles in the Peninsula High School parking lot 2 and the footcandles in Hesse Park parking lot {where our City Council conducts its meetings) and then compare the readings with Marymount's parking lot. If Marymount's footcandle readings are higher than the high school and RPV Council Meeting parking lot then Marymount would be in violation of Condition 152. 3