HomeMy WebLinkAbout1999-09-01; Planning Commission; Resolution 4601I 0 0
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PLANNING COMMISSION RESOLUTION NO. 4601
A RESOLUTION OF THE PLANNING COMMISSION OF THE
CITY OF CARLSBAD, CALIFORNIA, APPROVING A
MITIGATED NEGATIVE DECLARATION AND MITIGATION
MONITORING AND REPORTING PROGRAM TO
BUILDINGS WITH A TOTAL AREA OF 250,093 SQUARE
FEET ON A 25.28 ACRE SITE LOCATED ON THE SOUTH
SIDE OF PALOMAR AIRPORT ROAD EXTENDING FROM
AN AREA WEST OF HIDDEN VALLEY ROAD ON THE
WEST TO AVIARA PARKWAY ON THE EAST IN THE
COASTAL ZONE AND LOCAL FACILITIES MANAGEMENT
ZONE 5
CASE NAME: KELLY CORPORATE CENTER
CASE NO.: SDP 97-25/CDP 97-52
CONSTRUCT FOUR TWO-STORY MULTI-TENANT OFFICE
l1 I/ WHEREAS, Kelly Ranch Corporate Center I, LLC, “Developer”, h;
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verified application with the City of Carlsbad regarding property owned by Kell:,
Corporate Center I, LLC and the Kelly Family Trust, Trust 3, “Owner”, described a
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Parcels 1 &2 of City of Carlsbad Boundary Adjustment No.
494 & Parcel 2 of City of Carlsbad Boundary Adjustment No.
388, excepting therefrom the portion lying easterly of Aviara
Parkway
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(“the Property”); and
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WHEREAS, a Mitigated Negative Declaration and Mitigation monitol
Reporting Program was prepared in conjunction with said project;
and
23 ll WHEREAS, the Transportation Analysis for the project inch
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the project and it has become apparent recently that Reach 2 may not be com: 25
assumption that Cannon Road Reaches 1 and 2 would be constructed prior to the op
previously assumed in the study, additional background information and a cond 26
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approval has been added to the Environmental Impacts Assessment Form - Part I1
Mitigation Monitoring and Reporting Program to address this timing issue.
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2 WHEREAS, the Planning Commission did on the 1st day of Septemb
3 hold a duly noticed public hearing as prescribed by law to consider said request; and
4 WHEREAS, at said public hearing, upon hearing and considering all t
5 and arguments, examining the initial study, analyzing the information submitted by I
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considering any written comments received, the Planning Commission considered a
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relating to the Mitigated Negative Declaration.
NOW, THEREFORE, BE IT HEREBY RESOLVED by the
10 Commission as follows:
11 A) That the foregoing recitations are true and correct.
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B) That based on the evidence presented at the public hearing, the
Commission hereby APPROVES the Mitigated Negative Declaration a
to Exhibit "ND" dated August 6, 1999, and "PII" dated May 5, 1999
Mitigation Monitoring and Reporting Program, attached hereto anc
part hereof, based on the following findings:
l6 /I Findinm:
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1. The Planning Commission of the City of Carlsbad has reviewed, analy
considered the Mitigated Negative Declaration, the environmental impacts
identified for this project and said comments thereon, and the Mitigation Mo
and Reporting Program, on file in the Planning Department, prior to APPROV
project. Based on the EIA Part I1 and comments thereon, the Planning Con
finds that there is no substantial evidence the project will have a significant effe
environment and hereby APPROVES the Mitigated Negative Declaration I
Mitigation Monitoring and Reporting Program.
22 2. The Planning Commission does hereby find that the Mitigated Negative Dec
23 and Mitigation Monitoring and Reporting Program have been prepared in acc
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with requirements of the California Environmental Quality Act, the State Guide1
the Environmental Protection Procedures of the City of Carlsbad.
25 3. The Planning Commission finds that the Mitigated Negative Declaration ref
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independent judgment of the Planning Commission of the City of Carlsbad.
4. The Planning Commission finds that all feasible mitigation measures or
alternatives identified in the MEIR 93-01 which are appropriate to this project ha
PC RES0 NO. 4601 -2-
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Conditions:
1. The Developer shall implement, or cause the implementation of the Kelly C
Center Mitigation Monitoring and Reporting Program.
PASSED, APPROVED AND ADOPTED at a regular meeting of the
Commission of the City of Carlsbad, California, held on the 1st day of September 199
following vote, to wit:
AYES: Chairperson Heineman, Commissioners Compas, L’
Trigas and Welshons
NOES:
ABSENT: Commissioners Nielsen and Segall
ABSTAIN:
COURTNEY E. HEINEMAN, Chairperson
CARLSBAD PLANNING COMMISSION
ATTEST:
MICHAEL J. HWZMIL~ER
Planning Director
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PC RES0 NO. 4601 -3-
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- City of Carlsbac
AMENDED MITIGATED NEGATIVE DECLARATION
Project AddresdLocation: South side of Palomar Airport Road extending from an area wc
of Hidden Valley Road on the west to Aviara Parkway on the eas
Project Description: A Site Development Development Plan and Coastal Developme
Permit to construct four two-story multi-tenant office buildini
with a total area of 250,093 square feet. Individual building are;
are 72,593 square feet, 50,000 square feet, 50,000 square feet, ar
77,500 square feet. A total of 1,006 at grade parking spaces will 1
provided. The total site area is 25.28 acres.
The City of Carlsbad has conducted an environmental review of the above described proje
pursuant to the Guidelines for Implementation of the California Environmental Quality Act ar
the Environmental Protection Ordinance of the City of Carlsbad. As a result of said review, th
initial study (EIA Part 2) identified potentially significant effects on the environment, but (I
revisions in the project plans or proposals made by, or agreed to by, the applicant before th
proposed negative declaration and initial study are released for public review would avoid th
effects or mitigate the effects to a point where clearly no significant effect on the environmer
would occur, and (2) there is no substantial evidence in light of the whole record before the Cit
that the project “as revised” may have a significant effect on the environment. Therefore,
Mitigated Negative Declaration is hereby issued for the subject project. Justification for th:
action is on file in the Planning Department.
A copy of the Mitigated Negative Declaration with supportive documents is on file in th
Planning Department, 2075 Las Palmas Drive, Carlsbad, California 92009. Comments fiom th
public are invited. Please submit comments in writing to the Planning Department withm 21
days of date of issuance. If you have any questions, please call Don Neu in the Planniq
Department at (760) 438-1 161, extension 4446.
DATED: AUGUST 6,1999
CASE NO: SDP 97-25/CDP 97-52
CASE NAME: KELLY CORPORATE CENTER
PUBLISH DATE: AUGUST 6,1999
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MICHAEL J. H~MIL~R
Planning Director
2075 La Palmas Dr. Carlsbad, CA 92009-1 576 - (760) 438-1 161 - FAX (760) 438-089.
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ENVIRONMENTAL IMPACT ASSESSMENT FORM - PART 11
(TO BE COMPLETED BY THE PLANNING DEPARTMENT)
CASE NO: SDP 97-25/CDP 97-5
DATE: May 5,199
BACKGROUND
1. CASE NAME: Kelly Comorate Center
2. APPLICANT: Kelly Ranch Comorate Center I, LLC
3. ADDRESS AND PHONE NUMBER OF APPLICANT: 4365 Executive Drive, Suite 850, Sa.
Dieao, CA 92121
4. DATE EIA FORM PART I SUBMITTED: November 17,1997
5. PROJECT DESCRIPTION: A Site Development Plan and Coastal Development Permit t
construct four two-stow multi-tenant office buildings with a total buildinp area of 250.09
square feet. Individual building areas are 72,593 square feet, 50,000 square feet, 50.000 sauar
feet, and 77,500 square feet. A total of 1.006 at grade parking spaces will be provided. The tots
site area is 25.28 acres. The proiect site is located on the south side of Palomar Airport Road an
extends from an area west of Hidden Valley Road on the west to Aviara Parkway on the east.
SUMMARY OF ENVIRONMENTAL FACTORS POTENTIALLY AFFECTED:
The summary of environmental factors checked below would be potentially affected by this projecl
involving at least one impact that is a “Potentially Significant Impact,” or “Potentially Significant Impac
Unless Mitigation Incorporated” as indicated by the checklist on the following pages.
0 Land Use and Planning [XI TransportatiodCirculation 0 Public Services
0 Population and Housing [XI Biological Resources Utilities & Sewice Systems
Geological Problems 0 Energy & Mineral Resources [7 Aesthetics
water Hazards Cultural Resources
[XI Air Quality [XI Noise Recreation
0 Mandatory Findings of Significance
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DETERMINATION.
(To be completed by the Lead Agency)
I find that the proposed project COULD NOT have a significant effect on tk
environment, and a NEGATIVE DECLARATION will be prepared.
I find that although the proposed project could have a significant effect on tl
environment, there will not be a significant effect in this case because the mitigatic
measures described on an attached sheet have been added to the project. A NEGATIV
DECLARATION will be prepared.
0 I find that the proposed project MAY have a significant effect on the environment, and E
ENVIRONMENTAL IMPACT REPORT is required.
[XI I find that the proposed project MAY have significant effect(s) on the environment, but
least one potentially significant effect 1) has been adequately analyzed in an earlic
document pursuant to applicable legal standards, and 2) has been addressed by mitigatio
measures based on the earlier analysis as described on attached sheets. A Mitigate
Negative Declaration is required, but it must analyze only the effects that remain to b
addressed.
I find that although the proposed project could have a significant effect on th
environment, there WILL NOT be a significant effect in this case because all potential1
significant effects (a) have been analyzed adequately in an earlier Master Environment:
Impact Review (MEIR 93-01) pursuant to applicable standards and (b) have been voide
or mitigated pursuant to that earlier Master Environmental Review (MER 93-01:
including revisions or mitigation measures that are imposed upon the proposed projec
Therefore, a Notice of Prior Compliance has been prepared. LA 7-27-97 Planner Signature Date
t +Mm
Date
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ENVIRONMENTAL IMPACTS
STATE CEQA GUIDELINES, Chapter 3, Article 5, Section 15063 requires that the Ci
conduct an Environmental Impact Assessment to determine if a project may have a significa
effect on the environment. The Environmental Impact Assessment appears in the followir
pages in the form of a checklist. This checklist identifies any physical, biological and hum:
factors that might be impacted by the proposed project and provides the City with information
use as the basis for deciding whether to prepare an Environmental Impact Report (EIR), Negatil
Declaration, or to rely on a previously approved EIR or Negative Declaration.
e A brief explanation is required for all answers except “No Impact” answers that a]
adequately supported by an information source cited in the parentheses following eac
question. A “No Impact” answer is adequately supported if the referenced informatic
sources show that the impact simply does not apply to projects like the one involved. .
“No Impact” answer should be explained when there is no source document to refer to, (
it is based on project-specific factors as well as general standards.
e “Less Than Significant Impact” applies where there is supporting evidence that tl
potential impact is not adversely significant, and the impact does not exceed adopt<
general standards and policies.
e “Potentially Significant Unless Mitigation Incorporated” applies where the incorporatio
of mitigation measures has reduced an effect from “Potentially Significant Impact” to
“Less Than Significant Impact.” The developer must agree to the mitigation, and th
City must describe the mitigation measures, and briefly explain how they reduce th
effect to a less than significant level.
e “Potentially Significant Impact” is appropriate if there is substantial evidence that a
effect is significant.
0 Based on an “EIA-Part 11”, if a proposed project could have a potentially significar,
effect on the environment, but &l potentially significant effects (a) have been analyze1
adequately in an earlier EIR or Mitigated Negative Declaration pursuant to applicab18
standards and (b) have been avoided or mitigated pursuant to that earlier EIR or Mitigatec
Negative Declaration, including revisions or mitigation measures that are imposed up01
the proposed project, and none of the circumstances requiring a supplement to o
supplemental EIR are present and all the mitigation measures required by the prio
environmental document have been incorporated into this project, then no addition:
environmental document is required (Prior Compliance).
e When “Potentially Significant Impact” is checked the project is not necessarily require
to prepare an EIR if the significant effect has been analyzed adequately in an earlier E11
pursuant to applicable standards and the effect will be mitigated, or a “Statement o
Overriding Considerations” has been made pursuant to that earlier EIR.
e A Negative Declaration may be prepared if the City perceives no substantial evidence tha
the project or any of its aspects may cause a significant effect on the environment.
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0 If there are one or more potentially sipficant effects, the City may avoid preparing z
EIR if there are mitigation measures to clearly reduce impacts to less than si@ficant, ar
those mitigation measures are agreed to by the developer prior to public review. In th
case, the appropriate “Potentially Significant Impact Unless Mitigation Incorporatec
may be checked and a Mitigated Negative Declaration may be prepared.
0 An EIR must be prepared if “Potentially Significant Impact” is checked, and includir
but not limited to the following circumstances: (1) the potentially significant effect hL
not been discussed or mitigated in an Earlier EIR pursuant to applicable standards, an
the developer does not agree to mitigation measures that reduce the impact to less tha
significant; (2) a “Statement of Overriding Considerations” for the significant impact h
not been made pursuant to an earlier EIR; (3) proposed mitigation measures do not reduc
the impact to less than significant, or; (4) through the EIA-Part I1 analysis it is nc
possible to determine the level of significance for a potentially adverse effect, (
determine the effectiveness of a mitigation measure in reducing a potentially significa
effect to below a level of significance.
A discussion of potential impacts and the proposed mitigation measures appears at the end of tf
form under DISCUSSION OF ENVIRONMENTAL EVALUATION. Particular attentio
should be given to discussing mitigation for impacts which would otherwise be determine
significant.
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Issues (and Supporting Information Sources). Potentially
Significant Impact
I. LAND USE AND PLANNING. Would the proposal:.
a) Conflict with general plan designation or zoning?
(Source #(s): (#l:Pgs 5.6-1 - 5.6-18)
b) Conflict with applicable environmental plans or
policies adopted by agencies with jurisdiction over the
project? (#l:Pgs 5.6-1 - 5.6-18)
c) Be incompatible with existing land use in the vicinity?
d) Affect agricultural resources or operations (e.g. impacts
to soils or farmlands, or impacts from incompatible
landuses? (#l:Pgs 5.6-1 - 5.6-18)
e) Disrupt or divide the physical arrangement of an
established community (including a low-income or
minority community)? (#l:Pgs 5.6-1 - 5.6-18)
(#l:PgS 5.6-1 - 5.6-18)
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11. POPULATION AND HOUSING. Would the proposal:
a) Cumulatively exceed official regional or local
b) Induce substantial growth in an area either directly or
population projections? (#l:Pgs 5.5-1 - 5.5-6) o
indirectly (e.g. through projects in an undeveloped area 0
or extension of major infrastructure)? (#l:Pgs- 5.5-1 -
5.5-6)
c) Displace existing housing, especially affordable
housing? (#l:Pgs 5.5-1 - 5.5-6) 0
111. GEOLOGIC PROBLEMS. Would the proposal result
in or expose people to potential impacts involving:
a) Fault rupture? (#l:Pgs 5.1-1 - 5.1-15; #7)
b) Seismic ground shaking? ((#l:Pgs 5.1-1 - 5.1-15; #7)
c) Seismic ground failure, including liquefaction?
d) Seiche, tsunami, or volcanic hazard? (#l:Pgs 5.1-1 -
e) Landslides or mudflows? (#l:Pgs 5.1-1 - 5.1-15; #7
f) Erosion, changes in topography or unstable soil
0 0
((#l:Pgs 5.1-1 - 5.1.15; #7) 0
5.1-15;#2: Pgs 111-1 12 - 111-1 18; #7) 0 0
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conditions from excavation, grading, or fill? (#l:Pgs 0
5.1-1 - 5.1-15; #7)
g) Subsidence ofthe land? (#l:Pgs 5.1-1 - 5.1-15; #7)
h) Expansive soils? (#l:Pgs 5.1-1 - 5.1-15; #7)
i) Unique geologic or physical features? (#l:Pgs 5.1-1 -
5.1-15; #7) t3
IV. WATER. Would the proposal result in:
a) Changes in absorption rates, drainage patterns, or the
rate and amount of surface runoff? (#l:Pgs 5.2-1 - 5.2- 0
such as flooding? ((#l:Pgs 5.2-1 - 5.2-1 1; #8; #9) 0
surface water quality (e.g. temperature, dissolved
oxygen or turbidity)? ((#l:Pgs 5.2-1 - 5.2-1 1; #8; #9)
11; #8; #9)
b) Exposure of people or property to water related hazards
c) Discharge into surface waters or other alteration of
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Potentially
Significant Unless Mitigation
Incorporated
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Less Than No
Significant Impac Impact
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Issues (and Supporting Information Sources).
d) Changes in the amount of surface water in any water
e) Changes in currents, or the course or direction of water
movements? ((#l:Pgs 5.2-1 - 5.2-11; #8; #9)
f) Changes in the quantity of ground waters, either
through direct additions or withdrawals, or through
interception of an aquifer by cuts or excavations or
through substantial loss of groundwater recharge
capability? ((#l:Pgs 5.2-1 - 5.2-11; #8; #9)
g) Altered direction or rate of flow of groundwater?
h) Impacts to groundwater quality? ((#l:Pgs 5.2-1 - 5. 2-
11; #8; #9)
i) Substantial reduction in the amount of groundwater
otherwise available for public water supplies? ((#I :Pgs
body? ((#l:PgS 5.2-1 - 5.2-11; #X; #9)
((#l:PgS 5.2-1 - 5.2-11; #8; #9)
5.2-1 - 5.2-11; #8; #9)
V. AIR QUALITY. Would the proposal:
a) Violate any air quality standard or contribute to an
existing or projected air quality violation? (#l:Pgs 5.3-
b) Expose sensitive receptors to pollutants? (#l:Pgs 5.3-1
c) Alter air movement, moisture, or temperature, or cause
any change in climate? ((#l:Pgs 5.3-1 - 5.3-12)
d) Create objectionable odors? ((#l:Pgs 5.3-1 - 5.3-12)
1 - 5.3-12)
- 5.3-12)
VI. TRANSPORTATION/CIRCULATION. Would the
a) Increased vehicle trips or traffic congestion? (#l:Pgs
b) Hazards to safety from design features (e.g. sharp
curves or dangerous intersections) or incompatible uses
(e.g. farm equipment)? (#l:Pgs 5.7-1 - 5.7.22; #5)
c) Inadequate emergency access or access to nearby uses?
d) Insufficient parking capacity on-site or off-site?
e) Hazards or barriers for pedestrians or bicyclists?
f) Conflicts with adopted policies supporting alternative
transportation (e.g. bus turnouts, bicycle racks)?
g) Rail, waterborne or air traffic impacts? (#l:Pgs 5.7-1 -
proposal result in:
5.7-1 - 5.7.22; #5; #6)
(#l:PgS 5.7-1 - 5.7.22; #5)
(#l:PgS 5.7-1 - 5.7.22; #2: PgS 111-58 - 111-69)
(#l:PgS 5.7-1 - 5.7.22; #5)
(#l:PgS 5.7-1 - 5.7.22; #5)
5.7.22; #5)
Potentially
Significant
Impact
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Potentially Significant
Unless Mitigation Incorporated 0
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Less Than No
Significant Impac Impact
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VII. BIOLOGICAL RESOURCES. Would the proposal
result in impacts to:
a) Endangered, threatened or rare species or their habitats
(including but not limited to plants, fish, insects, no
animals, and birds? (#l:Pgs 5.4-1 - 5.4-24; #2; #3)
b) Locally designated species (e.g. heritage trees)?
(#l:PgS 5.4-1 - 5.4-24; #2; #3) 0 I7 DEI
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Issues (and Supporting Information Sources).
c) Locally designated natural communities (e.g. oak
forest, coastal habitat, etc.)? (#l:Pgs 5.4-1 - 5.4-24; #2;
d) Wetland habitat (e.g. marsh, riparian and vernal pool)?
e) Wildlife dispersal or migration corridors? (#l:Pgs 5.4-1
#3)
(#l:PgS 5.4-1 - 5.4-24; #2: Pgs 111-37 - 111-58; #3)
- 5.4-24; #2; #3)
Potentially Potentially Significant Significant Impact Unless Mitigation Incomorated 0 IxI
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Less Than No
Significant Impac Impact
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VIII. ENERGY AND MINERAL RESOURCES. Would the
proposal?
a) Conflict with adopted energy conservation plans?
b) Use non-renewable resources in a wasteful and
inefficient manner? (#l:Pgs 5.12.1-1 -5.12.1-5 & 5.13-
"
(#l:PgS 5.12.1-1 - 5.12.1-5 & 5.13-1 - 5.13-9) 0 OH
0 OH
1 - 5.13-9)
c) Result in the loss of availability of a known mineral
resource that would be of future value to the region and
the residents of the State? (#l:Pgs 5.12.1-1 - 5.12.1-5
0 0 OH
& 5.13-1 - 5.13-9)
IX. HAZARDS. Would the proposal involve:
a) A risk of accidental explosion or release of hazardous
substances (including, but not limited to: oil, pesticides,
chemicals or radiation)? (#l:Pgs 5.10.1-1 - 5.10.1-5)
b) Possible interference with an emergency response plan
or emergency evacuation plan? (#l:Pgs 5.10.1-1 -
c) The creation of any health hazard or potential health
d) Exposure of people to existing. sources of potential
e) Increase fue hazard in areas with flammable brush,
0 OH
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5.10.1-5)
hazards? (#l:Pgs 5.10.1-1 - 5.10.1-5)
health hazards? (#l:Pgs 5.10.1-1 - 5.10.1-5)
grass, or trees? (#l:Pgs 5.10.1-1 - 5.10.1-5)
X. NOISE. Would the proposal result in:
a) Increases in existing noise levels? (#l:Pgs 5.9-1 - 5.9-
b) Exposure of people to severe noise levels? (#l:Pgs 5.9- 15) 0 OH
1 - 5.9-15) 0 lxl nu
XI. PUBLIC SERVICES. Would the proposal have an
effect upon, or result in a need for new or altered
government services in any of the following areas:
a) Fire protection? (#l:Pgs 5.12.5-1 - 5.12.5-6)
b) Police protection? (#l:Pgs 5.12.6-1 - 5.12.6-4)
c) Schools? (#l:Pgs 5.12.7.1 - 5.12.7-5)
d) Maintenance of public facilities, including roads? (#l,
e) Other governmental services? (#l:Pgs 5.12.1-1 -
0 0 ON 0 0 OH 0 0 ON 0 UEI pgs 5.12.1-1 - 5.12.8-7)
5.12.8-7) 0 0 OH
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Issues (and Supporting Information Sources). Potentially Potentially
Significant Significant
Impact Unless Mitigation
Incorporated XII. UTILITIES AND SERVICES SYSTEMS. Would the
proposal result in a need for new systems or supplies,
or substantial alterations to the following utilities:
a) Power or natural gas? (#l:Pgs 5.12.1-1 - 5.12.1-5 &
b) Communications systems? (#l; pgs 5.12.1-1 - 5.12.8-7)
c) Local or regional water treatment or distribution
d) Sewer or septic tanks? (#l:Pgs 5.12.3-1 - 5.12.3-7)
e) Storm water drainage? (#l:Pg 5.2-8)
f) Solid waste disposal? (#l:Pgs 5.12.4-1 - 5.12.4-3)
g) Local or regional water supplies? (#l:Pgs 5.12.2-1 -
5.13-1 - 5.13-9) o
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facilities? (#l:Pgs 5.12.2-1 - 5.12.3-7)
5.12.3-7) I7 0
XIII. AESTHETICS. Would the proposal:
a) Affect a scenic or vista or scenic highway? (#l:Pgs
b) Have a demonstrate negative aesthetic effect? (#l:Pgs
c) Create light or glare? (#l:Pgs 5.11-1 - 5.11-5)
5.11-1 -5.11-5) 0 0
5.11-1 -5.11-5) 0
XIV. CULTURAL RESOURCES. Would the proposal:
a) Disturb paleontological resources? (#l:Pgs 5.8-1 - 5.8-
b) Disturb archaeological resources? (#l:Pgs 5.8-1 - 5.8-
c) Affect historical resources? (#l:Pgs 5.8-1 - 5.8-10)
d) Have the potential to cause a physical change which
would affect unique ethnic cultural values? (#l:Pgs
e) Restrict existing religious or sacred uses within the
10)
10; ##4)
5.8-1 - 5.8-10)
potential impact area? (#l:Pgs 5.8-1 - 5.8-10)
XV. RECREATIONAL. Would the proposal:
a) Increase the demand for neighborhood or regional
parks or other recreational facilities? (#l:Pgs 5.12.8-1 -
b) Affect existing recreational opportunities? (#1 :Pgs
5.12.8-7)
5.12.8-1 - 5.12.8-7)
XVI. MANDATORY FINDINGS OF SIGNIFICANCE.
a) Does the project have the potential to degrade the
quality of the environment, substantially reduce the
habitat of a fish or wildlife species, cause a fish or
wildlife population to drop below self-sustaining levels,
threaten to eliminate a plant or animal community,
reduce the number or restrict the range of a rare or
endangered plant or animal or eliminate important
examples of the major periods of California history or
prehistory?
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Less Than No
Significant Impacr Impact
UIXI nIXI OH
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Issues (and Supporting Information Sources). Potentially Potentially Less Than No
Significant Significant Significant Impac Impact Unless Impact Mitigation Incorporated
b) Does the project have impacts that are individually
limited, but cumulatively considerable? IXI 0 00
(“Cumulatively considerable” means that the
incremental effects of a project are considerable when
viewed in connection with the effects of past projects,
the effects of other current projects, and the effects of
probable future projects)?
c) Does the project have environmental effects which will
cause the substantial adverse effects on human beings,
either directly or indirectly?
0 0 El5
9 Rev. 03/28/96
0 a
XVII. EARLIER ANALYSES.
Earlier analysis of this proposed multi-tenant office building project has been completed throug
the General Plan Update (GPA 94-01) and related Master Environmental Impact Report (ME1
93-01) . The MEIR is cited as source #1 in the preceding checklist. This proposal is consistel
with the applicable portions of the General Plan and is considered a project that was describc
in MEIR 93-01 as within its scope. All feasible mitigation measures identified in MEIR 934
which are appropriate to the project have been incorporated into this project.
The project incorporates additional mitigation measures identified in site specific technic
studies prepared to evaluate potential impacts and feasibility of the proposal as it relates
biological resources, archaeological resources, transportation system impacts, geotechnic;
feasibility, hydrology/drainage and that no additional significant unmitigated impacts beyon
those identified by the Program EIR will result from this project. The following environment;
evaluation briefly explains the basis for this determination along with identifying the sourc
documents which support the environmental determination.
10 Rev. 03/28/96
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DISCUSSION OF ENVIRONMENTAL EVALUATION
I. PROJECT DESCRIPTIONDCNVIRONMENTAL SETTING
The project site is approximately 25.28 acres in size and is located on the south side of Palom
Airport Road and extends fiom an area west of Hidden Valley Road on the west to Avia
Parkway on the east. The project consists of four two-story multi-tenant office buildings with
total building area of 250,093 square feet. Individual building areas are 72,593 square fet
50,000 square feet, 50,000 square feet, and 77,500 square feet. A total of 1,006 at grade parkir
spaces will be provided. The project includes detention basins adjacent to Palomar Airport Roac
Routine maintenance of the basins will occur to maintain their function. The site has historical1
been used for agriculture and is bordered or bisected by roadways. Encinas Creek runs throug
the southern and western areas of the project site. The property contains four vegetatic
communities. These include southern willow scrub, coastal and valley freshwater mars;
eucalyptus woodland, and ruderal vegetation. The areas of the site proposed to be developed a:
relatively level and range from a low of 66 feet in the northwest corner to 83 feet in the northea
comer.
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11. ENVIRONMENTAL ANALYSIS
B. Environmental Impact Discussion
V. a) AIR QUALITY
The implementation of projects that are consistent with and included in the updated 1994 Gener
Plan will result in increased gas and electric power consumption and vehcle miles travele
These subsequently result in increases in the emission of carbon monoxide, reactive organi
gases, oxides of nitrogen and sulfur, and suspended particulates. These aerosols are the majc
contributors to air pollution in the City as well as in the San Diego Air Basin. Since the Sa
Diego Air Basin is a “non-attainment basin”, any additional air emissions are considere
cumulatively significant: therefore, continued development to buildout as proposed in tl:
updated General Plan will have cumulative significant impacts on the air quality of the region.
To lessen or minimize the impact on air quality associated with General Plan buildout, a variet
of mitigation measures are recommended in the Final Master EIR. These include: 1) provisior
for roadway and intersection improvements prior to or concurrent with development; 2) measurt
to reduce vehicle trips through the implementation of Congestion and Transportation Demm
Management; 3) provisions to encourage alternative modes of transportation including mas
transit services; 4) conditions to promote energy efficient building and site design; and 5
participation in regional growth management strategies when adopted. The applicable an
appropriate General Plan air quality mitigation measures have either been incorporated into th
design of the project or are included as conditions of project approval.
Operation-related emissions are considered cumulatively significant because the project i
located within a “non-attainment basin”, therefore, the “Initial Study” checklist is marke
“Potentially Significant Impact”. This project is consistent with the General Plan, therefore, th
preparation of an EIR is not required because the certification of Final Master EIR 93-01, by Cit
Council Resolution No. 94-246, included a “Statement Of Overriding Considerations” for a
quality impacts. This “Statement Of Overriding Considerations” applies to all projects withi]
the scope of the General Plan’s Final Master EIR, including this project, therefore, no fbrthe
environmental review of air quality impacts is required. Ths document is available at thl
Planning Department.
VI. a) TRANSPORTATION/CIRCULATION
The implementation of projects that fall within the scope of and are included in the updated 199d
General Plan will result in increased traffic volumes. Roadway segments will be adequate tc
accommodate buildout traffic; however, 12 full and 2 partial intersections will be severe1
impacted by regional through-traffic over which the City has no jurisdictional control. Thes
generally include all freeway interchange areas and major intersections along Carlsbac
Boulevard. Even with the implementation of roadway improvements, a number of intersection:
are projected to fail the City’s adopted Growth Management performance standards at buildout.
To lessen or minimize the impact on circulation associated with General Plan buildout, nurnerou:
mitigation measures have been recommended in the Final Master EIR. These include: 1
measures to ensure the provision of circulation facilities concurrent with need; 2) provisions tc
develop alternative modes of transportation such as trails, bicycle routes, additional sidewalks
pedestrian linkages, and commuter rail systems; and 3) participation in regional circulatiol
12 Rev. 03/28/96
0 e
strategies when adopted. The diversion of regional through-traffic from a failing Interstate
State Highway onto City streets creates impacts that are not within the jurisdiction of the City
control. The applicable and appropriate General Plan circulation mitigation measures have eith
been incorporated into the design of the project or are included as conditions of project approva
Regional related circulation impacts are considered cumulatively significant because of tl
failure of intersections at buildout of the General Plan due to regional through-traffic, therefor
the “Initial Study” checklist is marked “Potentially Significant Impact”. This project
consistent with the General Plan, therefore, the preparation of an EIR is not required because tl
recent certification of Final Master EIR 93-01, by City Council Resolution No. 94-246, includt
a “Statement Of Overriding Considerations” for circulation impacts. This “Statement (
Overriding Considerations” applies to all projects that fall within the scope of the General Plan
Master EIR, including this project, therefore, no fwther environmental review of circulatic
impacts is required.
A study by Urban Systems Associates titled “Transportation Analysis for Kelly Corporal
Center”, dated March 1 y 1999 has been accepted by the Engineering Department. The stud
concluded that no significant traffic impacts should result from the project as a multi-tena
office site, and no additional cumulative circulation mitigation measures should be neede
beyond those identified in the City of Carlsbad Master EIR and the LFMP Zone 13 Traffi
Environmental Review. The study recommends the following which is included on the projec
plans:
1) The Palomar Airport Road at Hidden Valley Road and Palomar Airport Road at Aviar
Parkway intersections shall be designed with right turn only lanes for the eastbound tl
southbound right turn. A vehicle storage length of two hundred and fifty feet wit:
transition designed to CALTRANS specifications is recommended at Aviara Parkwa
and one hundred and fifty feet with transition at Hidden Valley Road. Fully designed an
engineered improvement plans shall be prepared for these conditions for approval by th
City Engineer.
Since the time traffic count information was obtained for the project’s traffic analysis the cit]
received the annual growth management traffic monitoring report. This project could have :
potentially significant negative cumulative traffic impact on the Palomar Airport Roam
Camino Real intersection. However, this project has been conditioned to pay its fair share of thc
“short-term improvements” thereby, guaranteeing implementation of a mitigation measure tha
reduces the potential impact to a level of insignificance. The following is the required mitigatiol
measure:
2) The Developer shall pay his fair share for the “short-term improvements” to the E
Camino RealPalomar Airport Road intersection prior to the issuance of any building
permits. The amount shall be determined by the methodology ultimately selected bJ
Council, including but not limited to, an increase in the city-wide traffic impact fee; an(
increased or new Zone 5 LFMP fee; the creation of a fee or assessment district; 01
incorporation into a Mello-Roos taxing district.
The Urban Systems Associates study titled, “Transportation Analysis for Kelly Corporate
Center”, dated March 1, 1999 included an assumption that Cannon Road would be constructed
from its current western terminus to El Camino Real (Reaches 1 & 2). Due to recent events il
has been determined that Reach 2 of Cannon Road may not be complete prior to the projecl
opening. Therefore, to provide adequate mitigation in the event Reach 2 of Cannon Road is not
13 Rev. 03/28/96
0 0
complete prior to the project opening the Engineering Department is proposing the addition 1
the following traffic mitigation measure:
3) “Prior to issuance of a building permit, construction of Cannon Road Reach 2 shall 1
underway to the satisfaction of the City Engineer.”
The proposed mitigation measure is not a new item in that the traffic study assumed tl
improvement would be in place. It primarily addresses the issue of timing between the openil
of the project and the completion of Cannon Road. The availability of Cannon Road will pem
persons working in the business parks north of Palomar Airport Road to utilize that new roadw?
thereby freeing up capacity on Palomar Airport Road whch would be available for vehicle tril
generated by the Kelly Corporate Center Project.
VII. a, c. & d) BIOLOGICAL RESOURCES
A report titled, “Kelly Corporate Center Biological Resources Report”, dated August 4, 19s
and “Kelly Corporate Center Riparian Mitigation Plan”, dated April 21, 1999 both by Hell
Environmental Planning, Inc. have been prepared for the project. The determination of tl.
biologist in surveying the site is that four vegetation communities are found on the propec
These include southern willow scrub, coastal and valley freshwater marsh, eucalyptus woodlanl
and ruderal vegetation. No species listed as threatened or endangered were observed or a~
expected to occur on site. Routine maintenance of the detention basins on site adjacent t
Palomar Airport Road is permitted to ensure their function.
Impacts
The project as currently proposed will completely avoid direct impacts to Encinas Creek. 1
majority of the remainder of the site will be impacted by the project. This will result in direc
impacts to southern willow scrub of approximately 0.30 acre of habitat including 0.26 acre alon
Palomar Airport Road for the recontouring of the slope for the construction of the propose
detention basins and 0.04 acre of impacts to other areas along Encinas Creek. No freshwatt
marsh vegetation will be impacted. Impacts to the southern willow scrub are considerec
significant.
Mitigation
The United States Fish and Wildlife Service recommended that impacts to southern willow scrul
be mitigated at a 2:l ratio. As sufficient area does not exist to accomplish the creation of OJ
acres of habitat within the project area, the 2:l ratio will be met through the creation of 0.3 acre
.of riparian woodland (1 : l), with the balance to be achieved through off-site mitigatior:
Mitigation for impacts to southern willow scrub will be mitigated by restoration of this habit?
type on site at a 1:l ratio (0.30 acre). The mitigation will occur in the southwestern comer of th
site adjacent to Encinas Creek. This mitigation site is considered superior to the existing habita
on site being impacted because it will be located at least 400 feet south of Palomar Airport Roac
and will be graded down to create a natural hydrological regime that will not require a permanen
water source. The following are the biological mitigation measures required for the project:
1) Mitigation for impacts to southern willow scrub shall be mitigated by restoration of thi:
habitat type at a 1 :1 ratio within the southwestern corner of the site as depicted on Figurc
4, “Mitigation Location - Kelly Corporate Center” of the Kelly Corporate Center Riparia
Mitigation Plan dated April 21, 1999 prepared by Helix Environmental Planning, Inc. P
14 Rev. 03/28/96
0 * detailed restoration plan must be developed and approved by the California Departme
of Fish and Game. The restoration plan must identify a planting plan, including pla
palette and seed mixes, and develop success criteria for restoration. A maintenance a1
monitoring period, usually five years, will be required to assure that the restoration art
meets with identified success criteria and restoration goals.
2) Offsite mitigation for 0.3 acres of riparian woodland shall be achieved through tl
establishment and placement of initial funds into a non-wasting fund approved by tl
U.S. Fish and Wildlife Service. Ths fund would allow for various management activitic
which benefit wetlands and the least Bell’s vireo (Vireo bellii pusillus; vireo) with:
Encinas Creek to take place in perpetuity. The exact amount of this initial fimding sha
be determined by the USFWS. This amount, along with fund establishment and tl
identification of the entity charged with fund management, shall be approved by tl
USFWS prior to occupancy and written confirmation from USFWS shall be provided .
the Planning Director.
3) Prior to grading plan approval areas of the site to be preserved in their existing conditio
shall be clearly demarcated on the grading plans to the satisfaction of the Plannin
Director and City Engineer. A habitat protection fence detail approved by the Plannin
Director and City Engineer shall be included on the grading plan along with the locatio
for its installation. These areas shall be fenced in the field by a qualified biologist wh
shall also submit to the Planning Director a letter attesting to the accuracy of the fencin
location prior to the issuance of a grading permit.
4) To assure that no direct impacts to the least Bell’s vireo occur during project grading, a
grading that creates noise in excess of 60 dB Leq at the western property boundary sha,
OCCUT outside of the vireo breeding season (March 15 - September 15). Alternativelq
grading noise levels shall be reduced to below 60 dB Leq by the construction of nois
attenuation devices during the breeding season. Grading that creates noise in excess o
60 dB Leq at the western property boundary during the vireo breeding season would b
allowed if it can be shown, based on focused surveys by a qualified biologist, that nl
least Bell’s vireos are using habitat in areas where the 60 dB Leq threshold is exceedec
Alternatively, a noise bamer that reduces grading noise to below 60 dB Leq could also b
used to reduce impacts to below a level of significance. A noise monitoring prograr
indicating the type of equipment to be used to measure noise levels, the monitorin,
location, responsible personnel and the frequency of monitoring as its relates to thc
grading schedule shall be submitted for Planning Director and U.S. Fish and Wildlifc
Service approval prior to the issuance of a grading permit unless the focused survey,
indicate that no least Bell’s vireos are using habitat that would be impacted by noisl
levels exceeding 60 dB Leq. If it is determined that indirect impacts cannot be avoided
“take” would need to be authorized as part of a section 7 consultation with the U.S
Army Corps of Engineers.
5) To minimize indirect impacts to Encinas Creek, the proposed 50 foot setback shall bl
revegetated using native upland plant species. This shall be included in the landscapi
plans for the project which must be approved prior to the approval of a grading plan
Review and approval of the landscape plans for the buffer area by the USFWS is alsc
required prior to grading plan approval. Limited encroachment into the 50 foot setbacl
where access to the site is gained from Aviara Parkway is acceptable to allow fo;
appropriate traffic spacing on Aviara Parkway and is shown on the project plans.
15 Rev. 03/28/96
0 0
6) An exterior lighting plan including parking areas shall be submitted for Planning Direct1
and US. Fish and Wildlife Service approval prior to building permit issuance. A
lighting shall be designed to reflect downward and avoid any impacts on adjacent homl
or property. The maximum height of all light fixtures shall not exceed 30 feet.
X. b) NOISE
The majority of the project site is located within the 65 to 70 decibel CNEL noise contou
identified in the Comprehensive Land Use Plan for McClellan-Palomar Airport with an area 1
the northeast corner of the site falling within the 70 to 75 decibel CNEL noise contou
SANDAG prepared a site specific plot of the noise contour lines in relation to proposed buildini
and it was determined that no structures will be located within the 70 to 75 decibel CNEL noit
contour. Office buildings are listed on the McClellan-Palomar Airport Noise/Land Ut
Compatibility Matrix as conditionally compatible in the 65 to 70 decibel CNEL noise level wil
the following mitigation measures:
1) Proposed office buildings shall be noise attenuated to an interior level of 50 decibe
CNEL based on an acoustical study submitted along with building plans. Concurrent wil
the submittal of building plans the applicant shall submit an acoustical stuc
documenting what construction materials or measures must be utilized to meet requirt
interior noise levels. A letter signed by the acoustical engineer and the project architec
which contains the architects registration stamp and certifies that the recommendations c
the acoustical study have been incorporated into the building plans shall be submitted an
approved by the Planning Director prior to building permit issuance.
2) Prior to the issuance of building permits the Developer shall prepare and record a Notic
that this property may be subject to noise impacts from the proposed or existin
Transportation Corridor, in a form meeting the approval of the Planning Director an
City Attorney (see Noise Form #1 on file in the Planning Department).
3) Prior to the issuance of building permits the Developer shall prepare and record a Notic
that this property is subject to overflight, sight and sound of aircraft operating fron
McClellan-Palomar Airport, in a form meeting the approval of the Planning Director anc
the City Attorney (see Noise Form #2 on file in the Planning Department).
4) Prior to the issuance of building permits, the Developer shall record an Avigatio:
Easement for the property to the County of San Diego and file a copy of the recordel
document with the Planning Director.
16 Rev. 03/28/96
0 0
111. EARLIER ANALYSES USED
The following documents were used in the analysis of this project and are on file in the City 4
Carlsbad Planning Department located at 2075 Las Palmas Drive, Carlsbad, California, 9200
(760) 438-1161, extension 4446.
1. “Final Master Environmental Impact Report for the City of Carlsbad General P1i
Update” (MEIR 93-01), dated March 1994, City of Carlsbad Planning Department.
2. “Kelly Corporate Center Biological Resources Report”, dated August 4, 1998, Heli
Environmental Planning, Inc.
3. “Kelly Corporate Center Riparian Mitigation Plan”, dated April 21, 1999, Helj
Environmental Planning, Inc.
4. “Kelly Corporate Center Trail: Archaeological Resources”, dated August 14, 1991
Hertiage Resources.
5. “Transportation Analysis for Kelly Corporate Center” , dated March 1, 1999, Urbe
Systems Associates, Inc.
6. “Growth Management Plan, City of Carlsbad, California, 1998 Traffic Monitorin
Program”, Valley Research And Planning Associates.
7. “Geotechnical Investigation for Kelly Ranch Corporate Center”, dated April 1997, Robe]
Prater Associates.
8. “Hydraulic Analysis of Encinas Creek for Kelly Corporate Center”, dated November :
1997, Crosby Mead Benton & Associates.
9. “Preliminary Drainage Report Kelly Corporate Center”, dated November 7, 1997, Crosb
Mead Benton & Associates.
17 Rev. 03/28/96
0 0
LIST OF MITIGATING MEASURES
1) The Palomar Airport Road at Hidden Valley Road and Palomar Airport Road at Avix
Parkway intersections shall be designed with right turn only lanes for the eastbound .
southbound right turn. A vehicle storage length of two hundred and fifty feet wi
transition designed to CALTRANS specifications is recommended at Aviara Parkw:
and one hundred and fifty feet with transition at Hidden Valley Road. Fully designed ar
engineered improvement plans shall be prepared for these conditions for approval by tl
City Engineer.
2) The Developer shall pay his fair share for the “short-term improvements” to the 1
Camino ReaWalomar Airport Road intersection prior to the issuance of any buildir
permits. The amount shall be determined by the methodology ultimately selected 1
Council, including but not limited to, an increase in the city-wide traffic impact fee; ar
increased or new Zone 5 LFMP fee; the creation of a fee or assessment district; (
incorporation into a Mello-Roos taxing district.
3) Mitigation for impacts to southern willow scrub shall be mitigated by restoration of th
habitat type at a 1 : 1 ratio within the southwestern corner of the site as depicted on Figu
4, “Mitigation Location - Kelly Corporate Center” of the Kelly Corporate Center Ripari:
Mitigation Plan dated April 21, 1999 prepared by Helix Environmental Planning, Inc.
detailed restoration plan must be developed and approved by the California Departme
of Fish and Game. The restoration plan must identify a planting plan, including pla:
palette and seed mixes, and develop success criteria for restoration. A maintenance ar
monitoring period, usually five years, will be required to assure that the restoration arc
meets with identified success criteria and restoration goals.
4) Offsite mitigation for 0.3 acres of riparian woodland shall be achieved through tl
establishment and placement of initial funds into a non-wasting fund approved by tl
U.S. Fish and Wildlife Service. This fund would allow for various management activitil
which benefit wetlands and the least Bell’s vireo (Vireo bellii pusillus; vireo) with
Encinas Creek to take place in perpetuity. The exact amount of this initial funding s&
be determined by the USFWS. This amount, along with fund establishment and tl
identification of the entity charged with fund management, shall be approved by tl
USFWS prior to occupancy and written confirmation from USFWS shall be provided
the Planning Director.
5) Prior to grading plan approval areas of the site to be preserved in their existing conditic
shall be clearly demarcated on the grading plans to the satisfaction of the Plannir
Director and City Engineer. A habitat protection fence detail approved by the Plannir
Director and City Engineer shall be included on the grading plan along with the locatic
for its installation. These areas shall be fenced in the field by a qualified biologist wl
shall also submit to the Planning Director a letter attesting to the accuracy of the fencil
location prior to the issuance of a grading permit.
6) To assure that no direct impacts to the least Bell’s vireo occur during project grading, ;
grading that creates noise in excess of 60 dB Leq at the western property boundary sh;
occur outside of the vireo breeding season (March 15 - September 15). Alternative1
grading noise levels shall be reduced to below 60 dB Leq by the construction of noi
attenuation devices during the breeding season. Grading that creates noise in excess
60 dB Leq at the western property boundary during the vireo breeding season would 1
18 Rev. 03/28/96
0 0
allowed if it can be shown, based on focused surveys by a qualified biologist, that n
least Bell’s vireos are using habitat in areas where the 60 dB Leq threshold is exceedec
Alternatively, a noise barrier that reduces grading noise to below 60 dB Leq could also k
used to reduce impacts to below a level of significance. A noise monitoring progral
indicating the type of equipment to be used to measure noise levels, the monitorin
location, responsible personnel and the frequency of monitoring as its relates to tk
grading schedule shall be submitted for Planning Director and U.S. Fish and Wildlil
Service approval prior to the issuance of a grading permit unless the focused surve)
indicate that no least Bell’s vireos are using habitat that would be impacted by nois
levels exceeding 60 dB Leq. If it is determined that indirect impacts cannot be avoidec
“take” would need to be authorized as part of a section 7 consultation with the U.:
Army Corps of Engineers.
7) To minimize indirect impacts to Encinas Creek, the proposed 50 foot setback shall E
revegetated using native upland plant species. This shall be included in the landscar
plans for the project which must be approved prior to the approval of a grading pla
Review and approval of the landscape plans for the buffer area by the USFWS is als
required prior to grading plan approval. Limited encroachment into the 50 foot setbac
where access to the site is gained from Aviara Parkway is acceptable to allow fi
appropriate traffic spacing on Aviara Parkway and is shown on the project plan.
8) An exterior lighting plan including parking areas shall be submitted for Planning Direct(
and U.S. Fish and Wildlife Service approval prior to building permit issuance. A
lighting shall be designed to reflect downward and avoid any impacts on adjacent homt
or property. The maximum height of all light fixtures shall not exceed 30 feet.
9) Proposed office buildings shall be noise attenuated to an interior level of 50 decibe
CNEL based on an acoustical study submitted along with building plans. Concurrent wil
the submittal of building plans the applicant shall submit an acoustical stud
documenting what construction materials or measures must be utilized to meet require
interior noise levels. A letter signed by the acoustical engineer and the project architec
which contains the archtects registration stamp and certifies that the recommendations (
the acoustical study have been incorporated into the building plans shall be submitted an
approved by the Planning Director prior to building permit issuance.
10) Prior to the issuance of building permits the Developer shall prepare and record a Notic
that this property may be subject to noise impacts from the proposed or existin
Transportation Corridor, in a form meeting the approval of the Planning Director an
City Attorney (see Noise Form #1 on file in the Planning Department).
11) Prior to the issuance of building permits the Developer shall prepare and record a Notic
that this property is subject to overflight, sight and sound of aircraft operating fro1
McClellan-Palomar Airport, in a form meeting the approval of the Planning Director ar
the City Attorney (see Noise Form #2 on file in the Planning Department).
12) Prior to the issuance of building permits, the Developer shall record an Avigatic
Easement for the property to the County of San Diego and file a copy of the record€
document with the Planning Director.
19 Rev. 03/28/96
nrrS IS TO CERTIFY THAT 1 HAVE REVIEWGD THE ABOVE MITIGAITNG MEAsb’iREs AND
CONCUR WlTR THE ADDmON OF THESE MEASURES TO THE PROJECT.
7/27/99
Date siglklre
20 Rev. OX28196
.IC... i 137: UJ. .-..- .." -
' ,8',!2.::1999 1:: 29 7E',C_rLl38 e NFI-ICN FLU1.ii.iiI.X. 1. C.U!3E
MPLICW CONCT - WTN ~r~r~sf~o~ -1 m
THIS IS TO CER71FY THAT I IiAE WEWED THE ABOVE MITIGATING hlEASUKES .,
CONCUR Wrrw THE ADDITION OF THESE MEMWS TO THE PROJECT.
a ~&?qP"
20 Rev. 03128196
ENVIRONMENTAL MITeTION MONITORING CHECKLISmPAGE 1 OF 5
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