HomeMy WebLinkAboutResolutions - No. 2002-131RESOLUTION NO. 2002-131
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF LODI
CONSIDERING AND MAKING FINDINGS AS TO THE FINAL
ENVIRONMENTAL IMPACT REPORT FOR THE PROPOSED
REDEVELOPMENT PLAN FOR THE LODI REDEVELOPMENT PROJECT
NO. 1; ADOPTING A STATEMENT OF FINDINGS, FACTS, AND
OVERRIDING CONSIDERATIONS; AND ADOPTING A MITIGATION
MONITORING PLAN
WHEREAS, as the Lead Agency, the Redevelopment Agency of the City of Lodi (the
"Agency") has prepared an Environmental Impact Report (the "EIR") on the proposed
Redevelopment Plan (the "Redevelopment Plan") for the Lodi Redevelopment Project No. 1 (the
"Project") pursuant to the California Environmental Quality Act (Public Resources Code Section
21000 et seq., hereinafter referred to as "CEQA"), the Guidelines for Implementation of the
California Environmental Quality Act (14 California Code of Regulations, Section 15000 et seq.,
hereinafter referred to as the "State CEQA Guidelines"), and procedures adopted by the Agency
relating to environmental evaluation; and
WHEREAS, the Agency transmitted for filing a Notice of Completion of the Draft EIR and
thereafter in accordance with CEQA and the State CEQA Guidelines forwarded the Draft EIR to
the State Clearinghouse for distribution to those state agencies which have discretionary
approval or jurisdiction by law over natural resources affected by the Redevelopment Plan, to
the affected taxing agencies, and to other interested persons and agencies and sought the
comments of such persons and agencies; and
WHEREAS, notice to all interested persons and agencies inviting comments on the Draft
EIR was published in accordance with the provisions of CEQA and the State CEQA Guidelines;
and
WHEREAS, the Draft EIR was thereafter revised and supplemented to adopt changes
suggested, to incorporate comments received during the public review period pursuant to CEQA
and the State CEQA Guidelines, and to incorporate the Agency's responses to said comments,
and as so revised and supplemented, a Final EIR was prepared by the Agency; and
WHEREAS, a joint public hearing was held by the Agency and the City Council of the
City of Lodi (the "City Council") on June 19, 2002, on the Redevelopment Plan and the Final
EIR, following notice duly and regularly given as required by law, and all interested persons
expressing a desire to comment thereon or object thereto have been heard, and said Final EIR
and all comments and responses thereto have been considered; and
WHEREAS, the Final EIR consists of the Draft EIR, as revised and supplemented to
incorporate all comments received and the responses of the Agency thereto, and is part of the
Agency's Report to the City Council on the Redevelopment Plan; and
WHEREAS, the City of Lodi is a Responsible Agency, as defined in Section 21069 of the
Public Resources Code, with respect to the Redevelopment Plan.
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF LODI DOES HEREBY
RESOLVE AS FOLLOWS:
Section 1. The City Council has evaluated all comments, written and oral, received from
persons who have reviewed the Final EIR and has duly reviewed and considered the Final EIR
prepared and certified by the Agency prior to adopting this resolution and acting on the
Redevelopment Plan.
Section 2. The City Council hereby adopts the Statement of Findings, Facts, and
Overriding Considerations relating to the environmental impact of the Redevelopment Plan for
the Lodi Redevelopment Project No. 1 as set forth in Exhibit A attached hereto and incorporated
herein by this reference (including, without limitation, the mitigation measures therein set forth).
Based upon such Statement of Findings, Facts, and Overriding Considerations, the City Council
hereby finds that all significant environmental effects have been eliminated or substantially
lessened except the following unavoidable adverse impacts:
(1) Long Term Regional Emissions Increases.
Based upon the foregoing, the City Council finds and determines that the
Redevelopment Plan will have a significant effect upon the environment but that the benefits of
the Redevelopment Plan outweigh the unavoidable adverse impacts for the reasons set forth in
the Statement of Findings, Facts, and Overriding Considerations, in particular, Part V thereof.
Section 3. The City Council hereby adopts the Mitigation Monitoring Plan set forth in
Exhibit B attached hereto and incorporated herein by this reference.
Section 4. Upon approval and adoption of the Redevelopment Plan by the City Council,
the City Clerk is hereby directed to file a Notice of Determination with the County Clerk of the
County of San Joaquin pursuant to the provisions of Section 21152 of CEQA and Section
15096(i) of the State CEQA Guidelines.
Dated: June 19, 2002
hereby certify that Resolution No. 2002-131 was passed and adopted by the Lodi City
Council in a special joint meeting of the Lodi City Council and the Redevelopment Agency of the
City of Lodi held June 19, 2002 by the following vote:
AYES: COUNCIL MEMBERS — Howard, Land, Nakanishi, and Mayor Pennino
NOES: COUNCIL MEMBERS — None
ABSENT: COUNCIL MEMBERS — None
ABSTAIN: COUNCIL MEMBERS — Hitchcock
i
Raw=M
11
SUSAN J. BLACKSTON
City Clerk
2002-131
MAS/CCResoEIRFndgs 2 10/2/01
EXHIBIT A
STATEMENT OF FINDINGS, FACTS, AND OVERRIDING
CONSIDERATIONS RELATING TO THE ENVIRONMENTAL
IMPACTS OF THE REDEVELOPMENT PLAN FOR THE
LODI REDEVELOPMENT PROJECT NO. 1
I. INTRODUCTION
The California Environmental Quality Act (Public Resources Code Section 21000 et
seq., "CEQA") provides, in Section 21081, that:
"[N]o public agency shall approve or carry out a project for which an
environmental impact report has been certified which identifies one or more
significant effects on the environment that would occur if the project is approved
or carried out unless both of the following occur:
"(a) The public agency makes one or more of the following findings with
respect to each significant effect:
"(1) Changes or alterations have been required in, or incorporated
into, the project which mitigate or avoid the significant effects on the
environment.
"(2) Those changes or alterations are within the responsibility and
jurisdiction of another public agency and have been, or can and should
be, adopted by that other agency.
"(3) Specific economic, legal, social, technological, or other
considerations, including considerations for the provision of employment
opportunities for highly trained workers, make infeasible the mitigation
measures or alternatives identified in the environmental impact report.
"(b) With respect to significant effects which were subject to a finding under
paragraph (3) of subdivision (a), the public agency finds that specific overriding
economic, legal, social, technological, or other benefits of the project outweigh
the significant effects on the environment."
As defined in CEQA, "'significant effect on the environment' means a substantial, or
potentially substantial, adverse change in the environment." (Public Resources Code Section
21068.)
II. DESCRIPTION OF THE PROJECT PROPOSED FOR APPROVAL
For purposes of CEQA, the "project" addressed in the Final Environmental Impact
Report (the "Final EIR") is the adoption and phased implementation of the Redevelopment Plan
(the "Redevelopment Plan") for the Lodi Redevelopment Project No. 1 (the "Project"). As more
particularly identified in the Final EIR, the Project Area covers approximately 1,184 acres of land
within the City of Lodi, including commercial, industrial, parks, residential and public right of way
1
Exhibit A
land uses. Under the Redevelopment Plan, the Project would be developed in accordance with
the land uses designated and permitted by the General Plan for the City of Lodi. The Final EIR
describes the environmental impacts that may occur as a result of the adoption and phased
implementation of the Redevelopment Plan and identifies, where applicable, measures which
would mitigate significant effects on the environment to a level of insignificance. Findings
regarding the significant effects of the Project are set forth below.
III. ENVIRONMENTAL IMPACTS OF THE PROJECT; FINDINGS REGARDING
SIGNIFICANT EFFECTS OF THE PROJECT
This Part III identifies the potentially significant and unavoidably significant effects of the
Project as determined by the Agency, including the findings and facts supporting the findings in
connection therewith. The Final EIR discussed Hazardous Materials but no impacts were
anticipated. The following areas were discussed in the Final EIR and include mitigation
measures that are incorporated into the Redevelopment Plan or are unavoidably significant
effects on the Project:
A. Land Use and Visual Factors
Environmental Impact
Adverse Land Use Compatibility Impacts. Some project -
facilitated land use changes within the Project Area could result in
adverse land use compatibility impacts. Given the proximity of
some existing, planned and anticipated residential uses in the
Project Area to existing and planned commercial and industrial
areas, project -assisted development could introduce significant
new land use conflicts among specific residential, commercial and
industrial developments.
Finding: The mitigation
feasible and shall be required
The mitigation measures will
significant' level.
measures identified below are
in or incorporated into the Project.
reduce the impact to a "less than
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) During City review and prior to approval of individual
projects within the Project Area, emphasize the need to avoid
significant new land use conflicts between non-residential and
residential development, between sensitive new commercial uses
and existing nuisance -prone commercial and industrial uses, and
between new nuisance prone commercial and industrial uses and
sensitive existing commercial uses.
(b) During review procedures and the formulation of conditions
of approval, require assurances to City satisfaction of: (1)
adequate land use separation, scale transition, and noise
buffering; (2) creative siting of buildings to avoid conflicts; (3)
Exhibit A
adequate protections against light, glare, and shadow impacts; (4)
adequate odor control; (5) adequate offstreet parking provisions;
(6) adequate and safe truck access and offstreet loading
provisions; and (7) other common measures warranted to avoid
such land use conflicts.
2. Environmentallmpact
Visual Impacts on Specific Streetscapes Within the Proiect
Area. The visual quality of future development in specific
opportunity areas within the Project Area would directly affect the
quality of important city streetscapes. Without adequate design
control, the Project could facilitate new industrial or mixed-
use/commercial development that could adversely affect the visual
quality of these highly visible industrial and mixed-use
streetscapes, as well as the visual character of surrounding
neighborhoods, and of the central area as a whole.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) Through the City's currently adopted development permit
and design review process, future development in the Industrial
Rail Corridor, East Industrial Area, Cherokee Lane Corridor and
Lodi West subareas, as designated in the EIR, shall be subject to
particularly focused and detailed design review. Implement
specific visual impact mitigation guidelines set forth in the City's
General Plan, Zoning Ordinance, Downtown Development
Standards and Guidelines and Central City Revitalization Program
in a manner that, to the satisfaction of City staff and the City's
Architectural Approval Committee and Planning Commission, are
sufficient to adequately protect and enhance the visual quality of
these areas.
(b) Applications for future development and property
improvements that are subject to discretionary approval in the
Industrial Rail Corridor, East Industrial Area, Cherokee Lane
Corridor and Lodi West subareas, as designated in the EIR, shall
incorporate the appropriate combination of specific design
guidelines listed in section 4.3 of the EIR in a manner that, to the
satisfaction of City staff and the City's Architectural Approval
Committee and Planning Commission, are sufficient to adequately
reduce project related visual impacts on streets, residential
neighborhoods, and the central area as a whole.
Exhibit A
3. Environmental Impact
Potential Impacts on Visual Character and Image of Eastside
Residential Neighborhood. Project facilitated new multi -family
development built in the Eastside neighborhood would have the
potential to clash visually with the neighborhood's older,
predominantly single-family residential character.
Finding: The mitigation measure identified below is feasible and
shall be required in or incorporated into the Project. The
mitigation measure will reduce the impact to a "less than
significant" level.
Facts in Support of the Findinq: The following mitigation
measure is incorporated into the Redevelopment Plan:
In review and processing of residential development projects
within the Eastside residential neighborhood, place special
emphasis on implementation of locational strategy contained in
the Central City Revitalization Program to protect and improve the
visual character and integrity of the neighborhood. Encourage
locations at the edge of the neighborhood and require appropriate
visual buffering and scale transition between new multi -family
structures and existing single-family development, to the
satisfaction of City staff and the City's Architectural Approval
Committee and Planning Commission.
B. Population. Housing and Employment
1. Environmentallmpact
Potential Jobs/Housing Balance Impacts. Project -facilitated
development and the projected addition of a substantially greater
number of jobs than housing units in the Project Area may
exacerbate the existing jobs/housing imbalance (weighted towards
jobs in comparison to the County as a whole).
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measure is incorporated into the Redevelopment Plan:
Implementation of mitigation measures identified below in Section
III.C.1 of this Statement of Findings, Facts and Overriding
Considerations pertaining to project -related commute period
vehicular traffic increases and associated project and cumulative
transportation system impacts.
Exhibit A
C.
III
Transportation and Parking
1. Environmentallmpact
Impact on Intersection Signalization Requirements. Additional
redevelopment related traffic would increase PM peak hour traffic
volumes at the Pine Street/Central Avenue intersection above
criteria levels set by Caltrans to determine whether installation of a
traffic signal is warranted.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
Caltrans has established eleven possible tests, or "warrants", for
determining whether installation of a traffic signal should be
considered. Usually, two or more of these must be met before a
signal is warranted. The EIR analysis indicates that only the
warrant related to peak hour traffic volume would be met for the
Pine Street/Central Avenue intersection. The City shall monitor
traffic volumes and conditions at the Pine Street -Central Avenue
intersection, and when two or more Caltrans signal warrant criteria
are met, shall place the intersection on the City's priority list for
Signalization.
Infrastructure and Public Facilities
1. Environmental Impact
Anticipated Water Supply Impacts. Anticipated increases in
commercial activity, employment and residential population
associated with the Project would result in corresponding
increases in the demand for water service. The City is prepared
to provide the additional domestic water necessary for anticipated
additional development in the Project Area, but water table
fluctuations due to basin overdraft give rise to some uncertainty
regarding available water supply for the City's future needs.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Exhibit A
• Facts in Support of Finding: The following mitigation measure
is incorporated into the Redevelopment Plan:
Implement the City of Lodi General Plan Land Use and Growth
Management Element policies which require the City to (1)
develop new facilities, as necessary, to serve new develop in
accordance with the City's Water, Wastewater and Drainage
Master Plans, and (2) assess water, wastewater and drainage
development fees on all new residential, commercial, office and
industrial development sufficient to fund required systemwide
improvements.
2. Environmentallmpact
• Water Distribution System Inadequacies. The existing water
distribution system may not be adequate to serve anticipated new
redevelopment facilitated development and intensification in the
Project Area.
• Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
• Facts in Support of Finding: The following mitigation measures
are incorporated into the Redevelopment Plan:
As project facilitated development takes place over the next 20
years, implement remaining needed central area water distribution
system improvements identified in Chapter 8 of the City's Water
Master Plan. Water conservation should also be promoted as the
Project Area redevelops.
3. Environmentallmpact
• Sewage Collection System Inadequacies. The existing
wastewater collection system may not be adequate to serve
anticipated new redevelopment facilitated development and
intensification in the Project Area.
• Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
• Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
Continue to implement the central area sewage collection system
improvements identified as needed in the City of Lodi General
6
Exhibit A
4.
5.
Plan, and the City's Sanitary Sewer System Technical Report,
including planned improvements to the Eastside neighborhood
collection system.
Environmental Impact
Police Service Demand in Protect Area. Project -facilitated
development and intensification within the Project Area would
increase demands for police services in the Project Area.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Facts in Support of the Findina: The following mitigation
measures are incorporated into the Redevelopment Plan:
Police Department shall monitor the rate of additional police calls
per year associated with the Project Area and the adequacy of
associated response times. If warranted by the monitoring data,
the City shall provide additional officers and facilities (funded
through the City's general fund). Following established City
procedures, the Police Department shall also review discretionary
approvals for project -facilitated commercial and residential
development within the Project Area.
Environmental Impact
Fire Protection and Emergencv Medical Service Demand in
Protect Area. Project -facilitated development and intensification
within the Project Area would increase demands for fire protection
and emergency medical services in the Project Area.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Facts in Support of the Findina: The following mitigation
measures are incorporated into the Redevelopment Plan:
Fire Department shall monitor the rate of additional fire protection
service calls per year associated with the Project Area and the
adequacy of associated response times. If warranted by the
monitoring data, the City shall provide additional firefighters and
equipment (funded through the City's general fund). Following
established City procedures, the Fire Department shall also review
discretionary approvals for project -facilitated commercial and
residential development within the Project Area.
Exhibit A
6.
7.
Environmental Impact
School Service Demand. Existing Lodi Unified School District
(LUSD) schools serving the Project Area may not have sufficient
capacity to accommodate the additional school population
generated by project -facilitated residential development.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) Redevelopment Agency shall make the statutory pass-
through payment of tax increment revenue to the LUSD and the
San Joaquin County Office of Education pursuant to Health and
Safety Code section 33607.5.
(b) City shall require developers in the Project Area to pay
state authorized school impact fees to the extent approved by the
LUSD. Individual project applicants may also choose to enter into
agreements with the LUSD to provide additional impact fees
negotiated with LUSD.
Environmental Impact
Project Park Demand. Park and recreation facilities in the
Project Area are already operating at capacity. Project -facilitated
development and intensification in the Project Area would
incrementally increase the demand for park and recreation
services. Based on estimated population increase in the Project
Area, the City will need approximately 1.83 acres of additional
park land to meet the increased demand.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
City shall ensure that at least 1.83 acres of parkland is developed
within or convenient to the Project Area. As project -facilitated
build -out takes place in the Project Area, adequate corresponding
park and recreation provisions shall be provided through required
Exhibit A
E.
F.
dedication of land and/or in -lieu payment of City adopted park and
recreation fees.
Drainage and Water Quality
Environmental Impact
Erosion, Sedimentation and Urban Runoff Pollutants. Building
construction and infrastructure improvements in the Project Area
could further degrade downstream water quality. Factors
contributing to downstream water quality problems include soil
disturbance during construction, new impervious surfaces created
with project -facilitated developments, increased vehicle traffic, and
herbicides, pesticides and fertilizers from new landscaping
associated with project -facilitated development.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a less than
significant level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) City shall require applicants for each future project -
facilitated development requiring a discretionary approval to
comply with all applicable state, regional and City water quality
provisions.
(b) For projects involving the grading of more than five acres,
applicant shall be required to (1) file with the Regional Water
Quality Control Board a Notice of Intent to comply with the
Statewide General Permit for Construction Activities, (2) prepare
and implement a project -specific Stormwater Pollution Prevention
Plan (including erosion control plan) if grading is involved, (3)
implement a monitoring, inspection and documentation program to
assure the effectiveness of control measures, (4) obtain or comply
with existing General Stormwater Discharge Permits for Industrial
Activities, where applicable, and (5) comply with the NPDES
Phase II Non -Point Discharge program.
Noise
1. Environmentallmpact
Exposure of Sensitive Land Uses to Excessive Environmental
Noise
Project facilitated intensification of and changes in land uses in the
Exhibit A
'rA
Project Area could expose additional people to noise levels
exceeding acceptable levels.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) Noise impacts can be reduced through appropriate site
planning, construction of noise barriers, and/or incorporation of
noise insulation features into a project's design as specified in the
City of Lodi General Plan. Evaluate the impact of each
redevelopment -facilitated discretionary development application in
the Project Area on the noise environment, particularly when
proposed near major transportation noise sources.
(b) Require noise assessments for all redevelopment -
facilitated discretionary applications in areas adjoining commercial
or industrial noise sources, and for noise -generating development
facilitated by the redevelopment plan when proposed adjacent to
noise sensitive land uses.
Environmental Impact
Redevelopment Facilitated Construction Noise.
Residential and other noise -sensitive uses located adjacent to
project -facilitated construction activities could be exposed to noise
levels that would interfere with normal activities.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
City shall require the use of a combination of the following
reasonable construction practices for projects when noise -
sensitive receptors are located in the project vicinity, including
restricting construction to avoid noise generating activity in the
early morning, evening, and on Sundays and holidays, muffling
and properly maintaining all internal combustion engine driven
equipment, locating stationary noise -generating equipment as far
as possible from sensitive receptors, routing construction traffic to
and from the project site via designated truck routes, utilizing
is
Exhibit A
G. Air Quality
1.
2.
"quiet" air compressors and other stationary noise sources where
such technology exists, and designation of a "noise disturbance
coordinator" who would be responsible for responding to any local
complaints about construction noise.
Environmental Impact
Construction Activity Air Quality Construction activities
facilitated by the proposed redevelopment plan could generate
construction period exhaust emissions and fugitive dust that could
affect local air quality. In addition, buildings constructed prior to
1979 could have Asbestos Containing Materials (AGMs) which
could be released into the air during building demolition.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
City shall require that individual redevelopment -facilitated projects
involving new construction shall comply, where applicable, with
the current San Joaquin Valley Unified Air Pollution Control
District ("SJVUAPCD") Regulation VIII requirements. In addition,
the City may also require a limitation on traffic speeds on unpaved
roads to 15 miles per hour, installation of wheel washers for all
exiting trucks, or wash off all trucks and equipment leaving the
site, suspension of excavation and grading activities when winds
exceed 20 miles per hour, and/or a limitation on the size of the
area subject to excavation, grading or other construction activity at
any one time to avoid excessive dust. To mitigate any potential
demolition -related air quality impacts from ACMs, the demolition
contractor would be required to comply with all local, state and
federal regulations regarding determination of existence of ACMs
and proper removal and disposal to reduce air quality risks
associated with airborne ACMs. Prior to the start of construction,
the applicant shall submit a dust control plan demonstrating
compliance with all SJVUAPCD and City required control
measures.
Environmental Impact
Lona -Term Regional Emissions Increases Emissions resulting
from new vehicle trips generated by redevelopment facilitated
intensification in the Project Area would, by the year 2020,
generate Reactive Organic Gases and Nitrogen Oxides in
ii
Exhibit A
amounts that would exceed the applicable thresholds of
significance for each pollutant. These emissions would constitute
a significant project impact and would be expected to contribute to
a significant cumulative impact.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project.
Notwithstanding incorporation of these mitigation measures, the
Long -Term Regional Emissions Increases are an unavoidable
significant effect. Specific economic, legal, social, technological or
other benefits of the Project make the alternatives infeasible and
outweigh this significant effect.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
(a) Where practical, future development proposals shall
include physical improvements that would act as incentives for
pedestrian, bicycle and transit modes of travel.
(b) Employment -generating development projects of 10,000
square feet or more shall be required to provide secure and
weather -protected bicycle and shower/locker facilities for
employees.
(c) Employment -generating development projects shall
provide carpool/vanpool incentives, develop an employee
rideshare incentives program, or use other feasible transportation
demand measures to reduce vehicle trip generation.
The specific economic, legal, social, technological or other
benefits of the Project are more particularly described in the
Statement of Overriding Considerations contained in Part V of this
Statement of Findings, Facts and Overriding Considerations.
H. Vegetation and Wildlife
1. Environmentallmpa
Potential Loss of Special -Status Species Redevelopment -
facilitated development consistent with the City of Lodi General
Plan may result in impacts on special status species.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant' level.
12
Exhibit A
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
If disturbance to suitable giant garter snake habitat is proposed as
part of a redevelopment assisted development or improvement
project, systematic surveys shall be conducted before such a
development is approved in order to determine definitively
whether any giant garter snakes occur. If any populations are
encountered, an appropriate mitigation plan shall be developed in
consultation with, and meeting the mitigation criteria of, the
California Department of Fish and Game and the United States
Fish and Wildlife Service and in compliance with specifications of
section 5.2.4.8 of the San Joaquin County Multi -Species Habitat
Conservation and Open Space Plan.
2. Environmentallmpact
Jurisdictional Wetland Impacts Redevelopment -facilitated
development could affect potential jurisdictional wetland habitat.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a "less than
significant' level.
Facts_ in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
All redevelopment -facilitated development that would involve
modifications to potential wetlands and other waters, such as
seasonal wetlands that could be present in vacant or under used
parcels, shall be coordinated with representatives of the California
Department of Fish and Game and the U.S. Army Corps of
Engineers, as required by federal and state law, to ensure that
any required mitigation protocols and associated project design
modifications are incorporated into proposed improvement plans
during the initial stages of project review.
I. Cultural and Historic Resources
1. Environmentallmpact
Protect -Related Potentials for Disturbance of Archaeological
Resources
Development encouraged and improvements funded by the
proposed redevelopment program could disturb sensitive
archaeological resources in the Project Area.
13
Exhibit A
2.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a 'less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
In the event that subsurface cultural resources are encountered
during approved ground -disturbing activities for a redevelopment
program -related construction activity, work in the immediate
vicinity shall be stopped and a qualified archaeologist retained to
evaluate the find. The discovery or disturbance of any cultural
resources should also be reported to the Central California
Information Center, and if prehistoric, to the Native American
Heritage Commission. Identified cultural resources should be
recorded on a State Department of Parks and Recreation Form
422. Mitigation measures prescribed by these groups and
required by the City should be undertaken prior to resumption of
construction activities.
Environmental Impact
Destruction/Degradation of Historic Resources Project -
facilitated development in the Project Area has the potential to
destroy or substantially. degrade historic resources, if these
resources are not identified or recognized and their maintenance,
rehabilitation or appropriate reuse are not promoted.
Finding: The mitigation measures identified below are feasible
and shall be required in or incorporated into the Project. The
mitigation measures will reduce the impact to a 'less than
significant" level.
Facts in Support of the Finding: The following mitigation
measures are incorporated into the Redevelopment Plan:
All future redevelopment -assisted public improvement projects
and private development projects shall be evaluated for the
presence of and potential impacts on historic resources. If
disturbance of a historic resource cannot be avoided, a mitigation
program shall be implemented. The City and private sponsors of
future individual projects on sites that contain unlisted structures
45 years or older shall have a qualified professional architectural
historian prepare a report to evaluate the suitability of the structure
for historic status. If the structure is determined to be eligible for
historic status, the Lodi Planning Commission should determine
whether the structure should be preserved in place, offered for
relocation to another site, or documented with photographs and a
report for submittal to a museum or library prior to demolition.
14
Exhibit A
Alternatively, a single survey of the Project Area shall be
completed and any buildings 45 years of age or older be
evaluated and their potential architectural and/or historic
significance be determined, prior to any project -facilitated
development.
IV. FINDINGS REGARDING ALTERNATIVES TO THE PROJECT
CEQA requires that an EIR describe a range of reasonable alternatives to the Project or
to the location of the Project which could feasibly attain the basic objectives of the Project and to
evaluate the comparative merits of the alternatives. Section 15126(d)(1) of the State CEQA
Guidelines states that the "discussion of alternatives shall focus on alternatives to the project or
to its location which are capable of avoiding or substantially lessening any significant effects of
the project, even if these alternatives would impede to some degree the attainment of the
project objectives, or would be more costly."
As more particularly set forth in the Final EIR, the Project was compared to the following
alternatives: (1) a "no project" alternative; (2) a modified Project Area boundary; (3) a modified
list of Project Area redevelopment actions and/or modified allocation of redevelopment funds to
the various actions; (4) an alternative Project Area location; and (5) the Project incorporating the
mitigation measures listed in the Final EIR. The following discussion briefly summarizes the
listed alternatives.
No Project Alternative: Under the No Project alternative, the Redevelopment Plan
would not be adopted. No actions would be taken by the Lodi Redevelopment Agency to
remove blighting conditions and stimulate additional private investment in the proposed Project
Area. No Redevelopment Agency funding would be provided towards housing assistance in the
Project Area, and no Redevelopment Agency actions would be taken to fund infrastructure and
facility improvements, or to redevelop property. Although it is not possible to quantify the exact
level of public and private development that would occur in the proposed Project Area under the
No Project alternative, it is reasonable to assume that, with no Redevelopment Agency activity
in the Project Area to fund public improvements and to attract an increased level of private
investment, existing blighting conditions would remain or worsen. The No Project Alternative is
not a viable alternative because it will not meet the basic goal of eliminating and removing blight
in the Project Area.
Modified Project Boundary Alternative: This alternative would be similar to the
proposed project in terms of allocation of funding, but would involve either a reduced area
boundary or an enlarged area boundary. Under the reduced area boundary, the overall
effectiveness of the redevelopment program would be lessened, since selected activities would
have to be reduced or eliminated to compensate for the reduced tax increment revenues
accruable to the Redevelopment Agency. If the reduced boundary alternative were selected,
the extent of potential growth in the Project Area subject to redevelopment assistance and
incentives would be reduced and a corresponding decrease in the land use, traffic, public
services, visual, vegetation and wildlife, noise, air quality, and other impacts identified in the EIR
could be anticipated. The reduced project area alternative will not effectively reduce and
eliminate the blight existing throughout the Project Area and therefore is not a viable alternative.
The enlarged area boundary alternative would not be a viable alternative under state
redevelopment law. The proposed boundaries of the Project Area were carefully selected
15
Exhibit A
based on identification of areas that contain blighted conditions, could benefit from
redevelopment activities, and could meet certain other redevelopment law parameters. A
combination of blight and general urbanization conditions has not been identified outside the
Project Area at the present time.
Modified Redevelopment Activities: This alternative would include the same boundaries
proposed by the project, but with a modified allocation of project -generated revenues to
redevelopment activities within the Project Area. The modified allocation would increase the
percentage of total project -related revenue for affordable housing from approximately 20
percent (as proposed in the Project) to approximately 35 percent, with the 15 percent difference
taken from the public infrastructure improvement, site assembly and other components of the
redevelopment program. Although this alternative would have some positive environmental
effects, it would also reduce the beneficial land use compatibility effects of the project, reduce
the rate of market rate housing and job growth, and decrease the funding available for storm
drainage and flood control improvements, assistance for preservation and maintenance of
historic resources, and development driven hazardous waste clean-up. This alternative could
further result in a reduced overall level of physical rehabilitation in the proposed Project Area
and an associated reduction in facilitation of blight elimination. Because this alternative will not
meet the basic goal of eliminating and removing blight in the Project Area, it is not a viable
alternative.
Alternative Project Area Location: This alternative examined the potential for the
Project Area to be located on other sites. However, the boundaries of the proposed Project
Area were precisely established based on the maximum area within which identified blighted
conditions currently occur, in combination with other urbanization parameters set forth in state
redevelopment law. No additional areas are currently identified in the project vicinity that
appear to meet redevelopment law criteria for blight. The fundamental purpose of the
redevelopment project is to authorize activities and financing to enable the Redevelopment
Agency to eliminate blighted conditions. Redevelopment Agency establishment of an
alternative site for the Project Area would fail to attain the basic objectives of the proposed
project. Therefore, this is not a viable alternative.
Project Incorporating Mitigation Measures: This alternative consists of the Project as
proposed with the incorporation of all mitigation measures recommended in the EIR. As stated
above, the mitigation measures recommended in the EIR shall be incorporated into the Project.
This is therefore the Project to be considered by the City Council and the Agency. This
alternative effectively achieve the goals of the Redevelopment Project and would mitigate all
environmental effects to a less than significant levels, except for long-term regional emissions of
air pollutants, which is a significant and unavoidable effect.
Finding: After consideration of all the alternatives, the Agency and City Council
find that the Project Incorporating Mitigation Measures is the "environmentally superior"
alternative since the proposed Project Incorporating Mitigation Measures most effectively
achieves the basic goal of eliminating and removing blight in the Project Area, and provides a
funding source for the proposed public improvements which are necessary to alleviate existing
blighting conditions in the Project Area. In addition, all potentially significant impacts identified
in the Final EIR except for the long-term regional emissions have been eliminated or reduced to
a less than significant level by incorporation of appropriate mitigation measures as part of the
proposed Project.
16
Exhibit A
V. STATEMENT OF OVERRIDING CONSIDERATIONS
CEQA requires a public agency to balance the benefits of a proposed project against its
unavoidable environmental risks in determining whether to approve the project. As set forth in
Part III hereof, the Agency and the City Council have determined that the only unavoidable
environmental consequence of the Project is the following:
Long -Term Regional Emissions Increases.
The Agency and the City Council find that the above -referenced unavoidable
environmental consequence of the Project is acceptable when balanced against its benefits.
This finding is based on the following facts:
The Project will serve a critical need, that being the elimination and prevention of
the spread of blight and deterioration in the Project Area and the conservation,
rehabilitation and redevelopment of the proposed Project Area in accordance
with the Redevelopment Plan, the General Plan for the City of Lodi and local
codes and ordinances.
2. The promotion of new and continuing private sector investment within the Project
Area will prevent the loss of and facilitate the capture of commercial sales
activity.
3. The Project will allow for the elimination of blight through abatement or code
enforcement, rehabilitation and reconstruction, new development, and the
assembly of parcels into more developable sites for more desirable uses.
4. The Project will result in the elimination or amelioration of certain environmental
deficiencies, including substandard vehicular circulation systems, inadequate
storm drainage systems, inadequate off-street parking, and other similar public
improvement deficiencies adversely affecting the Project Area.
5. New construction within the Project Area will result in an environment reflecting a
high level of concern for architectural, landscape, and urban design and land use
principles appropriate for attainment of the objectives of the Redevelopment
Plan.
6. Project implementation would result in the retention and expansion of businesses
by means of redevelopment and rehabilitation activities and by encouraging and
assisting in the cooperation and participation of owners, businesses, and public
agencies in the revitalization of the Project Area.
7. Revitalized commercial and industrial development will result in the creation and
development of local job opportunities and the preservation of the area's existing
employment base.
Project implementation will strengthen the economic base of the Project Area
and the City by installing needed site improvements and stimulating commercial,
industrial, and residential development.
17
Exhibit A
9. Project implementation will expand and improve the City's supply of affordable
housing.
is
Exhibit A
t EXHIB16 ..es..
,MITIGATION MONITORING CHECKLIST-LODI REDEVELOPMENT PLAN
•
June 7, 2002
rhe environmental mitigation measures listed In column two below have been incorporated into the conditions of approval for the Lodi Redevelopment Plan in order to mitigate EIR-identified environmental impacts.
k completed and signed chart will Indicate that each mitigation requirement has been compiled with, and that City and State monitoring requirements have been fulfilled with respect to Public Resources Code
Section 21081.6.
1- Impl. Entity ■ Implementation Entity
p211A f WP5116161FEIRIMMCHT.616
MONITORING
V RIF C TI N
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
CONDITION OF APPROVAL
Entl '
Acton
Re uirements
Verification nt
Si rtat re
Date
LAND USE AND VISUAL FACTORS
Impact 4.1: Adverse Land Use Compatibility
Mitigation 4.1: During City review and prior to
City,
Verify during plan
Prior to any
Lodi
Impacts. In addition to beneficial land use
approval of Individual development projects within
indt-
check
bldg. or
Redevelop -
compatibility effects, some project -facilitated
the redevelopment area, emphasize the need to
viduai
grading
ment Agency
land use changes within the Project Area could
avoid significant new land use conflicts between
appli-
permit
or City
result In adverse land use compatibility Impacts.
non-residential and residential development,
cants
Given the proximity of some existing, planned
between sensitive new commercial uses and
and anticipated residential uses in this area to
existing nuisance -prone commercial and industrial
existing and planned commercial and industrial
uses, and between new nuisance prone
areas, project -assisted Intensification could
commercial and industrial uses and sensitive
Introduce significant new land use conflicts
existing commercial uses. During these review
among specific residential, commercial, and
procedures and the formulation of conditions of
industrial developments (e.g., traffic, visual, light,
approval, require assurances to City satisfaction
noise, parking, odor and other conflicts). Such
of: (1) adequate land use separation, scale
project -induced effects represent potentially
transition, and noise buffering; (2) creative stung
significant adverse land use compatibility.
of buildings to avoid conflicts; (3) adequate
protections against light, glare, and shadow
impacts; (4) adequate odor control; (5) adequate
offstreet parking provisions: (6) adequate and safe
truck access and offstreet loading provisions; and
(7) other common measures warranted to avoid
such land use conflicts. Implementation of these
measures would be expected to reduce potential
land use compatibility impacts to a less-than-
slgMflcant level.
Impact 4.2: Visual Impacts on Specific
Mitigation 4.2: Through the City's currently-
City,
Verify during plan
Prior to any
Lodi
Streetscapes Within the Project Area.
adopted development permit and design review
indi-
check and design
bldg. or
Redevelop -
Portions of the Industrial rall corridor and east
process, future development in the Industrial Rail,
vidual
review
grading
ment Agency
industrial subareas have been Identified by City
Corridor, and East Industdal Area, Cherokee lane
appli-
permit
or City
staff (see subsection 4.3.2) as anticipated
Corridor and Lodi Avenue West subareas shall be
cants
Industrial development opportunity areas, and
subject to particularly focused and detailed design
are largely visible from adjoining major through-
review. Implement specific visual impact
routes (e.g., Cherokee Lane, Lookeford Street,
mitigation guidelines set forth in the General Plan,
Stock(on Street, Pine Street and Lodi Avenue)
Zoning Ordinance, Downtown Development
and from adjoining residential neighborhoods
Standards and Guidelines and Central City
and the downtown. Similarly, anticipated
Revitalization Program that, to the satisfaction of
commercial development Intensification along
City staff and the City's Architectural Approval
Lodi Avenue West and the Cherokee Lane
Carnrnittee and Planning Commission, are
Corridor (see section 4.3.2) would be highly
sufficient to adequately protect and enhance the
visible from those primary travel routes. The
visual quality of these areas. in addition,
visual quality of future development in these
applications for future new developments and
1- Impl. Entity ■ Implementation Entity
p211A f WP5116161FEIRIMMCHT.616
0 0 0
IDENTIFIED IMPACT
specific opportunity areas would directly affect
the quality of these important city streetscapes.
Without adequate design control, the project
could facilitate new industrial or mixed-
use/commercial development that could
adversely affect the visual quality of these highly
visible industrial and mixed-use streetscapes, as
well as the visual character surrounding
neighborhoods, and of the central area as a
whole. Such possible effects constitute a
potentially significant adverse visual Impact.
Impact 4.3: Potential Impacts on the Visual
Character and Image of the Eastside
Residential Neighborhood. Although the
Eastside neighborhood has been downzoned to
preclude Infiltration of additional multi -family
development within predominantly single-family
areas, some multi -family development would be
expected to occur along the edge of downtown.
Such project -facilitated multi -family development
has the potential to add to Eastside
neighborhood visual deficiencies created by
existing, poorly designed, multi -family residential
units. Project -facilitated new multi -family units
would have the potential to clash visually with
the neighborhood's older, predominantly single-
family residential character. Such an effect
would represent a potentially significant
adverse visual Impact
POPULATION AND HOUSING
Impact 5:1: Potential Jobs/Housing Balance
Impacts. Project -facilitated development may
contribute to the existing jobsthousing imbalance
In Lodi (weighted towards jobs In comparison to
the County as a whole). The projected addltton
of a substantially greater number of jobs than
housing units in the Project Area would
I - tmpL Entity s Implenwmatlon Entity
Page 2
RELATED MITIGATION MEASURE Impl.
(CONDITION OF APPROVAL) Entity'
Mitigation 4.3: In the review and processing of
City,
residential development projects within the
indi-
eastside residential neighborhood, place special
vldual
emphasis on implementation of locational
appii-
strategies contained In the Central City
cants
Revitalization Program to protect and Improve the
visual character and integrity of the neighborhood.
Encourage locations at the edge of the
neighborhood and require appropriate visual
buffering and scale transition between new multi-
family structures and existing single-family
development, to the satisfaction of City staff and
the City's Architectural Approval Committee and
Planning Commission. This measure would
reduce the impact to a less -then -significant
level.
Mitigatlon 5.1: Implement Mitigations 6-1 and City
10.2 pertaining to project -related commute period
vehicular traffic increases and associated project
and cumulative transportation system and air
quality impacts. Implementation of these
measures would reduce the one identified
significant environmental effect associated with
rype of Monitoring Timing Monitoring and
Action Requirements Veriflcatlon Entity I Signature Date
Verity during plan Prior to any Lodi
check and design bldg. or Redevelop -
review grading ment Agency
permit or City
Monitor traffic
volumes at Pine
Street/Central Ave.
Intersection; install
signal when
warranted
Annually
Lodi
Redevelop-
ment Agency
or City
WP5116161 FE1 R I MMCHT.616
1- impl. En*y s hnplementsam Entuy
Page 3 WP5116161FE/RIMMCNT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
exacerbate this imbalance. Such an effect
project -related incommuting increases to a less -
would constitute a potent/aMr significant
than significant level.
adverse Impact.
TRANSPORTATION AND PARKING
Impact 6.1. Impact on Intersection
Mitigation 6-1. Caltrans has established 11
City stati
Monitor traffic
Annually
Lodi
Signalbzatlon Requirements. The added PM
possible tests or "warrants" for determining
volumes at Pine
Redevelop -
peak hour traffic due to the redevelopment-
whether Installation of a traffic signal should be
Street/Central Ave.
ment Agency
related additional traffic would Increase PM peak
considered. These warrants each consider
intersection; install
or City
hour volumes above Caltrans Signal Warrant
different criteria such as peak hour traffic volume,
signal when
#11 criteria levels at the Pine Street/Central
pedestrian volume, presence of school children,
warranted
Avenue all -way -slop intersection. Although
and accident history. Usually, two or more
projected PM peak hour operation at this
"warrants" must be met before a signal is
intersection with the project would not exceed
warranted. The fact that this EIR analysis
LOS D. this signal warrant effect would
indicates that Warrant #11 (related to peak hour
represent a potent/apo significant Impact
traffic volumes) would be met indicates that a
detailed signal warrant analysis covering all
possible Caltrans warrants is appropriate. The
City shall therefore monitor traffic volumes and
conditions at the Pine Street/Central Avenue
Intersection, and when two or more Caltrans
signal warrant criteria are met, shall place the
intersection on the City's priority list for
signalization. This measure would reduce this
Impact to a /ess-thanslgnifIcant level.
INFRASTRUCTURE AND PUBLIC
FACILITIES
impact 7.1-1: Anticipated Witter Supply
Mitigation 7.1-1. Implement the following two
City
Develop new
Condition of
Lodi
Impacts. Additional development facilitated by
City of Lodi General Plan Land Use and Growth
andlor
facilities as
approval for
Redevelop -
or otherwise associated with implementation of
Management Element policies:
redevel.
necessary; assess
major new
ment Agency
the proposed redevelopment plan and
agency
established fees on
development
or City
associated increases in commercial activity,
The City shall develop new lacilifles, as
staff
new development
projects
employment, and residential population (see
necessary, to serve new development in
housing, population and employment increase
accordance with the City's Water,
estimates in section 5.3 of this EIR) would result
Wastewater, and Drainage Master Plans.
in corresponding increases in the demand for
(Policy 1)
water service. The City, as water purveyor, is
prepared to provide the additional domestic
The City shall assess water, wastewater, and
water necessary for anticipated additional
dmlr? a development fees on all new
development In this area, including anticipated
residential, commercial, offreae and Industrial
project -facilitated commercial growth and
development sulifcient to hind required
population increases, within the City's existing
systemwide Improvements. (Policy 2)
water entitlements and distribution systems.
1- impl. En*y s hnplementsam Entuy
Page 3 WP5116161FE/RIMMCNT.616
•
1 - Inrpi. Entry . bMtementadon Entity
Page 4
WP5116161 FEIMMMCHT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
However, while aquiters yield water madly to
City and Redevelopment Agency implementation
the City's wells, water table fluctuations due to
of these two policies as project -facilitated
basin overdraft give rise to some uncertainty
development takes place over the next 20 years
regarding available water supply for the City's
would ensure that project -related impacts on the
future needs. Anticipated project -facilitated
adequacy of City water sources would be reduced
growth within the redevelopment area would
to a less-thansignilieant level.
therefore be considered to have a potentially
sWi scant impact on water service.
Impact 7.1-2: Water Distribution System
Mitigation 7.1-2: As project-fadlitated
City
Implement water
Condition of
Lodi
Inadequacies. The existing water distribution
development takes place over the next 20 years,
and/or
distribution system
approval for
Redevelop -
system may not be adequate to serve
Implement remaining needed central area water
Redevel
Improvements as
major new
ment Agency
anticipated new redevelopment -facilitated
distribution system improvements identified in
Agency
needed
development
or City
development and intensification in the Project
Chapter 8 of the City's Water Master Plan. Water
staff
projects
Area. This potential deficiency represents a
conservation should also be promoted as the
potentially significant impact
Project Area redevelops. implementation of these
measures would reduce project -related water
distribution impacts to a less -than -significant
level.
Impact 7.2-1: Sewage Collection System
Mitigation 7.2-1: Continue to implement the
City
Implement sewage
Condition of
Lodi
Inadequacies. The existing wastewater
central area sewage collection system
and/or
collection system
approval for
Redevelop -
collection system serving the Project Area may
improvements identified as needed In the Ci of
Redevel
improvements as
major new
ment Agency
not be adequate to serve anticipated new
Lodi General Plan, and the City's Sanitary Sewer
Agency
needed
development
or City
development and Intensification In the Project
System Technical Report, Including the planned
staff
projects
Area. This potential deficiency represents a
Improvements to eastside neighborhood collection
potentially signMeant Impact
system. Implementation of these measures over
the next 20 years would reduce project
wastewater collection system impacts to a less-
thanslgn/ficant level.
Impact 7.3-1: Police Service Demand
Mitigstlon 7.3-1: The Police Department shall
Lodi
Annual response
Annual
Lodi
Impacts in Project Area. Man-facilftated
monitor the rate of additional police calls per year
Police
time monitoring
monitoring;
Redevelop -
development and intensification within the
Project Area would Increase demands for police
associated with the Project Area and the
adequacy of associated response times. As
Dept.
and City
reports; normal
review of individual
condition of
approval for
merit Agency
or City
service. The City of Lodi Police Department
warranted by the monitoring data, the City shall
staff
discretionary project
major new
may require additional staffing or equipment to
provide additional officers and facilities (funded
applications
projects
serve these added demands. The proposed
through the City's general fund). Following
redevelopment plan would therefore have a
established City procedures, the Police
potentially significant Impact on police
Department shall also review discretionary
services.
approvals for project-facilliated commercial and
residential development within the Project Area.
Irnplementatfon of these measures would reduce
the impact to a less -than slgnllMant letal
1 - Inrpi. Entry . bMtementadon Entity
Page 4
WP5116161 FEIMMMCHT.616
1 - Impt Entity a Implementsll n Efstlly
Page 5 WP5116161FEIMMMCHT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Emily'
Action
Requirements
Verification Entity
Signature
Date
impact 7.41: Fire Protection and Emergency
Mitigation 7.4-1: The Fire Department shall
Lodi Fire
Annual fire call
Annually
Lodi
Medical Service Demand Impacts In the
monitor the rate of additional fire protection
Dept.
monitoring reports;
Redevelop -
Project Area. Project -facilitated development
service calls par year associated with the Project
normal review of
ment Agency
and intensification within the Project Area would
Area and the adequacy of associated response
individual
or City
Increase demands for ere protection and
times. If warranted by the monitoring data, the
discretionary project
emergency medical services. Depending on the
City shall provide additional firefighters and
applications
We of use, density, and occupancy of Individual
equipment (funded through the City's general
project -facilitated developments, the City of Lodi
fund). Following established City procedures, the
Fre Department may require additional staffing
Fire Department shall also review discretionary
or equipment to meet Its fire protection goals.
approvals for project -facilitated commercial and
The proposed redevelopment plan may therefore
residential development within the Project Area.
have a potentially signif cant Impact on fire
These measures would reduce the impact to a
protection and emergency medical services.
less-than-signlffcenf level.
Impact 7.5.1: School Service Demand
Mitigation 7.5-1: The Lodi Redevelopment
City
Ensure all pass-
Prior to final
Lodi
Impacts. Existing Lodi Unified School District
Agency shall make the statutory pass-through
and/or
throughs and school
project
Redevelop-
(LUSD) schools serving the Project Area may
payment of tax increment revenue to the LUSD
Redevel
fee payments have
approval for
ment Agency
not have sufficient capacity to accommodate the
and the San Joaquin County Office of Education
Agency
been made
new projects
or City
additional school population generated by
pursuant to Health and Safety Code section
staff
project -facilitated residential development. The
33607.5. In addition, the City of Lodi shall require
project -related Increase in demand for school
developers in the redevelopment area to pay
service would therefore represent a potentlalty
state -authorized school Impact fees to the extent
slgnUlcant Impact,
approved by the LUSD. Individual project
applicants may also choose to enter into
agreements with the LUSD to provide additional
impact fees negotiated with the LUSD. These
measures would be expected to enable the LUSD
to fund school improvements necessary to
accommodate students from project -facilitated
development, reducing this impact to a less -than -
significant level.
Impact 7.t,-1: Project Park Demand Impacts.
Mitigation 7.6-1: Mitigation for Park Demand
City
Verify parkland
Prior to
Lodi
Park and recreation facilities in the Project Area
Impacts. The City shall ensure that at least 1.83
and/or
dedication or fee
grading or
Redevelop -
are already operating at capacity. Project-
acres of parkland Is developed within or
Redevel
payment during plan
building
ment Agency
facilitated development and intensification in the
convenient to the Project Area. As project-
Agency
check
permit
or City
Project Area would incrementally increase the
facilitated buildout takes place in the Project Area,
staff
demand for park and recreation services. As
adequate corresponding park and recreation
discussed in chapter 5 (Population, Housing,
provisions shall be provided through required
and Employment) of this EIR, it is estimated that
dedication of [arid andfor in -lieu payment of City
project facilitated development would generate
adopted park and recreation fees. Implementation
approximately 210 additional households in the
of this measure would reduce this Impact to less -
Project Area. Based on the anticipated citywide
tharr sdgnlflcant levels.
year 2020 household size of 2.56 persons (see
Table 5.2 In section 5.3), the 210 new
households would generate a population
increase of approximately 538 people. Based
on the most recent City park acreage standard
1 - Impt Entity a Implementsll n Efstlly
Page 5 WP5116161FEIMMMCHT.616
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
MONITORING
VERIFICATION
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
(3.4 acres per 1,000 persons), this new
populatfon increment would generate a demand
for approximately 1.83 acres of additional
parkland. Additional project -facilitated
employment growth, estimated at 2,014 jobs by
the year 2020, may also generate some
additional demand for park and recreation
services In the Project Area. Existing Project
Area facilities do not have sufficient capacity to
accommodate this additional demand. This
project effect would therefore represent a
significant ImpecL
DRAINAGE AND WATER QUALITY
Impact 8.1: Project -Related Erosion,
Mitigation 8-1: The City shall require the
City
Verify during pian
Prior to
Lodi
Sedimentation and Urban Runoff Pollutants.
applicant for each future project -facilitated
and/or
check and during
grading
Redevelop -
Redevelopment program -facilitated (wilding
development requiring a discretionary approval to
Redevei
construction-perfod
permit, and
ment Agency
construction and infrastructure improvements In
comply with all applicable state, regional and City
Agency
Inspections
during
or City
the Project Area could further degrade
water quality provisions and, for projects involving
staff
grading
downstream water quality. Associated factors
the grading of more than live (S) acres: (a) file
that may contribute to downstream water quality
with the RWQCB a Nolicw of Intent to comply with
problems Include soil disturbance during
the Statewide General Permit for Construction
construction, new impervious surfaces created
Activities, (b) prepare and implement a project -
with project -facilitated developments; and
specific Slonnwater Pollution Prevention Plan
Increased vehicle traffic, and herbicides,
(including an erosion control plan) if grading is
pesticides, and fertilizers from new landscaping
involved, (c) implement a monitoring, Inspection,
associated with project -facilitated development.
and documentation program to assure the
This combination of factors represents a
effectiveness of control measures, (d) obtain or
potentially s/gn/flcant Impact
comply with existing General Stornwater
Discharge Permit(s) for Industrial Activities, where
applicable, and (e) comply with the NPDES Phase
II Non -Point Discharge program. Implementation
of these requirements would reduce this impact to
a less -Man slgnNkant level.
NOISE
Impact 9.1: Project -Related Exposure of.
Mitigation 9.1: Noise Impacts can be reduced
City
Condition of
During
Lodi
Sensitive Land Uses to Excessive
through appropriate site planning (e.g., setbacks,
and/or
individual project
individual
Redevelop -
Environmental Noise. Project -facilitated
noise -protected areas), construction of noise
Redevel
approval; verify
project
ment Agency
intensification of and changes in land uses In
banters, and/or Incorporation of noise insulation
Agency
during plan check
environ.
or CRY
the Project Area could expose additional people
features into a project's design as specified in the
staff;
that any required
review
to noise levels exceeding acceptable levels--i.e.,
City of Lodi General Pian. As part of the future
hada-
noise studies have
to noise levels identified in the Lodi General
environmental review process for Individual
vidual
been completed
Pian as "conditionally acceptable; 'normally
projects, new developments facilitated by the
appii-
unacceptable" or "unacceptable" for the
redevelopment plan shall be evaluated. Evaluate
cants
associated land use. Such new exposure
each redevelopment -facilitated discretionary
NNW
1 -Impl. Entity.Implamentatran Enthy
Paas 6 WP5116161FE/RIMMCHT.616
t - IrW. Entity .11mbnrentatlon Entity
Pegs 7 IMP5116161FEIRIMMCHT.616
MONITORING
VERIFICATION
Imps.
Type of Monitoring
Timing
Monitoring and
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
(CONDITION OF APPROVAL)
F-ntW
Action
Requirements
Verification Entity
Signature
Date
possibilities constitute a potentially slgnfflcant
development application in the Project Area with
Impact
respect to the noise environment, particularly
when proposed near major transportation noise
sources such as SR 99, Cherokee Lane, Stockton
Street. Lodi Avenue, Tokay Street, other arterial
roadways, and/or the UPRR. Also, require noise
assessments for all redevelopment -facilitated
discretionary applications where noise -sensitive
receptors are proposed in areas adjoining
commercial or Industrial noise sources, such as
subareas 1, 3 and 4, and for noise -generating
development facilitated by the redevelopment plan
when proposed adjacent to noise -sensitive land
uses. The results of the noise assessments and
the measures identified to reduce noise levels
shall be incorporated in the project plans sufficient
to meet stipulated exterior and interior noise level
standards. All such evaluations shall be
completed to City satisfaction by a qualified
acoustical consultant With implementation of
measures Identified throughout such evaluations
to meet these standards, this potentially significant
Impart would be reduced to a less-than-
signincont level.
Impact 9-2: Redevelopment -Facilitated
Mitigation 9-2: To reduce the potential for noise
City
Condition of
Condition of
Lodi
Construction Notre. Construction activities
impacts resulting from project -facilitated
and/or
Individual project
constr.
Redevelop -
can generate considerable noise levels.
construction activities, implement a combination of
Redevel
approval; verified
(grading or
ment Agency
Construction activities facilitated by the
the following measures at all construction sites
Agency
during construction
building)
or City
redevelopment program could include site
when noise-sensifive receptors are located in the
staff;
permit; verify.
grading and preparation, building demolition,
project vicinity. The combination of measures
bndi-
during
construction of foundations and buildings,
shall be evaluated on an Individual, project -by-
vidual
construction
Installation of utilities, paving of roadways, and
project basis and shall be sufficient to achieve
project
construction of parking lots. The noise effects of
compliance with applicable City General Plan
appli-
these future construction activities would depend
and/or Noise Ordinance standards at affected
cants
upon the amount of activity, the type of
receptors.
equipment used, and the noise control measures
used. Residential and other noise -sensitive
Noise -generating constructlon activity shall
uses located adjacent to project -facilitated
be restricted to the hours of 7:00 AM to 7:00
construction activities could therefore be
PM. Monday through Friday, and 8:00 AM to
exposed to noise levels that would interfere with
5:00 PM on Saturdays. No construction
normal activities. This possibility constitutes a
adWes should occur on Sundays or
potentially signiftant impact
holidays.
All Internal combustion engine driven
equipment shall be equipped with Intake and
exhaust mufflers that are in good condition
and appropriate for itis equipment.
t - IrW. Entity .11mbnrentatlon Entity
Pegs 7 IMP5116161FEIRIMMCHT.616
0 9 0
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
4ONITORiNG
/ERIFICATION
MO.
Type of Monitoring
Tming
lonhoring and
(CONDITION OF APPROVAL)
entity'
lotion
teautrements
'ertficatlon EntBy
Signature
Date
• Stationary noise -generating equipment shall
be located as far as possible from sensitive
receptors when sensitive receptors adjoin or
are near a construction Project Area.
■ All construction traffic to and from the project
site shall be routed via designated truck
routes where possible. Construction -related
heavy truck traffic in residential areas shalt
be prohibited where feasible.
■ "Ouiet" air compressors and other stationary
noise sources shall be used where
technology exists.
A "noise disturbance coordinator" shall be
designated who would be responsible for
responding to any local complaints about
construction noise. The disturbance
coordinator would determine the cause of the
noise complaint (e.g., starting too early, bad
muffler, etc.) and would require that
reasonable measures warranted to correct
the problem be Implemented. A telephone
number for the disturbance coordinator shall
be conspicuously posted at the construction
site and included In the notice sent to
neighbors regarding the construction
schedule. (The City should be responsible
for designating a noise disturbance
coordinator and the Individual project sponsor
should be responsible for posting the phone
number and providing construction schedule
notices).
Implementation of this measure would reduce the
potential for project-reiated impacts due to
constriction noise to a leas-then-slgnillrant
levet.
I - Irnpl. Entity . Imptementedon array
Page 8 WP5I16161FEIRIMMCHT.616
1 -hML Entity .IrnphnnenWlon Entity
Fuge 9 INP5116161FE/RIMMCHT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
AiR QUALITY
Impact 10-1: Construction Activity Air
Mitigation 10-1: The City shall require that
City
Condition of
Condition of
Lodi
Duality Impacts. Construction activities
Individual redevelopment -facilitated projects within
and/or
individual project
grading
Redevelop -
facilitated by the proposed redevelopment pian
the Project Area Involving new construction shall
Redevel
approvals; verified
permit; verify
ment Agency
could generate constriction period exhaust
comply, where applicable, with current
Agency
during grading
during
or City
emissions and fugitive dust that could affect
SJVUAPCD Regulation VIII requirements, which
staff;
construction
local air quality. In addition, buildings
currently include the following:
indi-
constructed prior to 1979 could have Asbestos
vidual
Containing Materials (AGMs), which could be
. Appropriate dust suppression for land
project
released into the air during building demolition.
clearing, grubbing, scraping, excavation, land
appli-
Such constriction -period air emissions
leveling, grading, cut and fill and demolition
cants
possibilities represent a potentially slgnitieant
activities, such as the effective application of
ImpaaL
water or pre-soaking;
■ Effective stabilization of all disturbed areas of
a construction site, including storage piles,
which are not being actively used for seven
or more days;
- Control of fugitive dust from on-site unpaved
roads and off-site unpaved access roads;
and
• Removal of accumulations of mud or dirt at
the end of the work day or once every 24
hours from public paved roads, shoulders
and access ways adjacent to the site, for the
duration of the activity.
Regulation VIII also requires a Dust Control plan
for construction activity that will Include 40 acres
or more of disturbed surface area, or will include
moving more than 2,500 cubic yards per day of
bulk materials on at least three days.
in addition, where appropriate, the City may also
wish to require the following:
• A limitation on traffic speeds on unpaved
roads to 15 miles per hour (mph);
■ Installation of wheel washers for all exiting
trucks, or wash off all trucks and equipment
leaving the site;
1 -hML Entity .IrnphnnenWlon Entity
Fuge 9 INP5116161FE/RIMMCHT.616
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
MONITORING
VERIFICATION
impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
• Suspension of excavation and grading
activities when winds exceed 20 mph; and/or
• A limitation on the size of the area subject to
excavation, grading or other construction
activity at any one time to avoid excessive
dust.
Prior to each the start of construction, the
applicant shall submit a dust control plan
demonstrating compliance with all SJVUAPCD-
and City -required control measures.
To mitigate any potential demolition -related air
quality impacts from ACMs, the demolition
contractor would be required to comply with all
local, state and federal regulations regarding
determination of existence of ACMs, and proper
removal and disposal to reduce air quality risks
associated with airborne ACMs.
With Implementation of these Regulation VIII
controls and the above additional measures,
project -related construction period air emissions
Impacts would be reduced to a less-than-
81gnN1cant level.
Impact 10-2: Long -Tenn Regional Emissions
Mitigation 10-2: The following emissions control
City
Condition of
Condition of
Lodi
Increases. Emissions resulting from new
strategies shall be applied to redevelopment
and/or
individual project
project
Redevelop.
vehicle trips generated by redevelopment-
program -facilitated development activities within
Redevel
approvals, incl.
approvals;
ment Agency
facilitated intensification In the Project Area
the Project Area:
Agency
annual reporting
verify through
or City
would, by the year 2020, be expected to exceed
staff,
requirements
annual
the applicable thresholds of significance for
Where practical, future development
indi-
reporting
Reactive Organic Gases (ROG) and Nitrogen
proposals shall include physical
vidual
reqmnts
Oxkfes (N0J, resulting In a slgniticant pr%ct
Improvements, such as sidewalk
project
Impact When this increase in "mobile
improvements, landscaping, lighting and the
appli-
emissions' is considered cumulatively with
installation of bus shelters and bicycle
cants
possible new industrial "stationary sources' of
parking, that would act as incentives for
emissions that could locate within the
pedestrian, bicycle and transit modes of
redevelopment area, the total of project -related
travel.
Indirect and direct emissions would also exceed
applicable significance thresholds. As a result,
Employment -generating development
the project would also be expected to contribute
projects of 10,000 square feet (approximately
to a signlRcant crmtulative Impact
25 employees) or more shall be required to
provide secure and weather -protected bicycle
and showerilocker facilities for employees.
1 - Impr. Entity - "kumtatirm Entity
Page 10 WP5116161FEIRIMMCHT.616
1 - Impl. Entity ■ Implemenuuon Etnsy
Page 11 WP511616IFEIRIMMCHT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
- Employment -generating development
projects shall provide carpooVvanpool
Incentives, develop an employee rideshare
incentives program, or use other feasible
transportation demand measures to reduce
vehicle trip generation.
Implementation of these measures would assist in
reducing Identified project and cumulative impacts
on long-term regional emissions levels. The
URBEMIS7G program estimates that the above
measures would reduce regional Indirect
emissions by five to seven percent. This
reduction would not reduce this impact to a less -
than -significant level even In the absence of
potential industrial emissions. Since no other
feasible measures are available, these Identified
project and cumulative effects on regional air
emissions would represent a significant
unavoldable Impact.
VEGETATION AND WILDLIFE
Impact 11-1: Potential Loss of Special -Status
Mitigation 11-1: If disturbance to suitable giant
City
Require completion
During
Lodl
Species. Although chances of encountering
garter snake habitat (i.e., drainage ditches) is
and/or
of giant garter snake
individ.
Redevelop -
special -status species in the Project Area are
proposed as part of a redevelopment -assisted
Redevel
survey If existing
project
ment Agency
low, redevelopment -facilitated development
Individual development or Improvement project,
Agency
drainage ditch will
environ.
or City
consistent with the adopted City of Lodi General
systematic surveys shall be conducted before
staff;
be affected by
review; prior
Plan may result in impacts on special status
species. This possibility represents a
such a development is approved in order to
determine definitively whether any giant garter
indi-
vidual
project; ensure
implementation of
to grading
permit
potentially significant Impact
snakes occur. Such surveys shall be conducted
project
mitigation plan and
issuance
by a qualified wildlife biologist or a herpetologist
appli-
coordination with
following applicable guidelines of the California
cants
juds. agencies
Department of Fish and Game (CDFG) and/or
(USACOE, USFWS
U.S. fish and Wiidltfe Service (USFWS) to
and/or CDFG) If
provide a conclusive determination on presence or
habitat affected
absence of this animal specie. If any populations
are encountered, an appropriate mitigation plan
shall be developed In consultation with, and
meeting the mitigation criteria of, the CDFG and
USFWS, and in compliance with specifications of
the SJMSCP, section 5.2.4.8. Implementation of
this measure would ensure protection of possible
populations of special -status animal species (i.e.,
giant garter snake) in the Project Area, mitigating
potential Impacts to a less-Own-signl/Icant level.
End
1 - Impl. Entity ■ Implemenuuon Etnsy
Page 11 WP511616IFEIRIMMCHT.616
0 0 0
1 - Impl. Entay ■ implementation Entity
Page 12 WP511616lFE1RiMMCHT.616
MONITORING
VERIFICATION
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity'
Action
Requirements
Verification Entity
Signature
Date
Impact 11-2: Jurisdictional Wetland Impacts.
Mitigation 11-2: All redevelopment -facilitated
City
During project
Prior to
Lodi
Redevelopment facilitated development
development that would involve modifications to
and/or
environ. review, if
approval of
Redevelop -
consistent with the adopted City of Lodi General
potential wetlands and other waters, such as
Redevel
wetlands appear to
grading
ment Agency
Plan could affect potential jurisdictional wetland
seasonal wetlands that could be present in vacant
Agency
be present, req,
permit
or City
habitat. This possibility represents a potentially
or underused parcels, shall be coordinated with
staff;
biologist to
signiticant Impact
representatives of the California Department of
indl-
determine If
Fish and Game and the U.S. Army Corps of
vidual
wetlands are present
Engineers, as required by federal and stale law,
project
and as Gond. of
to ensure that any required mitigation protocols
appli-
devel. permit, req.
and associated individual project design
cants
implementation of
modifications are incorporated Into proposed
any jugs, agency
improvement plans during the Initial stages of
mitigation regmnts.
project review. Implementation of this measure
would ensure that potential impacts on wetland
resources are minimized and adequate
replacement is provided, mitigating this potential
Impact to a less -than -significant level.
CULTURAL RESOURCES
Impact 12-1: Project -Related Potentials for
Mitigation 12-1: In the even( that subsurface
City
Grading inspection
Cond. of
Lodi
Disturbance of Archaeological Resources.
cultural resources are encountered during
and/or
and reporting
grading
Redevelop -
Development encouraged and improvements
funded by the proposed redevelopment program
approved ground -disturbing activities for a
redevelopment program -related construction
Redevel
Agency
permit;
Inspection
ment Agency
or City
could disturb sensitive archaeological resources
activity, work in the Immediate vicinity shall be
staff,
during
in the Project Area. This possibility represents a
stopped and a qualified archaeologist retained to
indi-
grading
potentisAy significant Impact
evaluate the find. The discovery or disturbance of
vidual
any cultural resources should also be reported to
project
the Central California Information Center (CCIC),
appli-
and if prehistoric, to the Native American Heritage
cants
Commission. Identified cultural resources should
be recorded on a State Department of Parks and
recreation (DPR) Forth 422 (archaeological sites).
Mitigation measures prescribed by these groups
and required by the City should be undertaken
prior to resumption of construction activities.
Implementation of this measure would reduce this
potential impact to a less-than-sfgnif/cant level.
1 - Impl. Entay ■ implementation Entity
Page 12 WP511616lFE1RiMMCHT.616
IDENTIFIED IMPACT
RELATED MITIGATION MEASURE
MONITORING
VERIFICATION
Impl.
Type of Monitoring
Timing
Monitoring and
(CONDITION OF APPROVAL)
Entity I
Action
Requirements
Verification Entity
Signature
Date
impact 12.2: Destruction/Degradatlon of
Mitigation 12-2: Evaluate all future project-
City
During environ.
Prior to
Lodi
Historic Resources. Project -facilitated
assisted public improvement projects and private
and/or
review for individ.
approval of
Redevelop -
development In the Project Area has the
development projects for the presence of, and
Redevel
projects, ensure that
grading or
ment Agency
potential to destroy or substantially degrade
potential Impacts on, historic resources. If
Agency
any affected
building
or City
historic resources, if these resources are not
disturbance of a Project Area historic resource
staff;
historical resources
permit
Identified or recognized and their maintenance,
cannot be avoided, a mitigation program shall be
indi-
have been identified
rehabilitation or appropriate reuse are not
Implemented. The City and private sponsors of
vidual
and mitigation
promoted. Such destruction or degradation
future individual projects on sites that contain
project
program
would be considered a potentially significant
unlisted structures 45 years or older shall have a
applt-
Implemented as
impact
qualified professional architectural historian
cants
appropriate
prepare a report to evaluate the suitability of the
structure for historic status. If the structure Is
determined to be eligible for historic status, the
Lodi Planning Commission should determine
whether the structure should be preserved In
place, offered for relocation to another site, or
documented wfth photographs and a report for
submittal to a museum or library prior to
demolition.
Alternatively, a single surrey of the Project Area
shall be completed and any buildings 45 years of
age or older be evaluated and their potential
architectural and/or historic significance be
determined, prior to any project -facilitated
development. Implementation of these measures
would reduce this potential Impact to a less-Man-
slgnlNt:ant level.
1 - ltnpt. Entity - Implementation Entity
Pap 13 WP51 16 1 BWEIRIMMCHT. 616