April-17-2018-City-Council-Item-11 (PDF)

City of Paso Robles City Council Agenda Report From: Susan DeCarli, DeCarli Subject: Consultant Agreement Authorization for Preparation of an Environmental Impact Report for the propose

City of Paso Robles City Council Agenda Report From: Susan DeCarli, DeCarli

Subject: Consultant Agreement Authorization for Preparation of an Environmental Impact

Report for the proposed Beechwood Specific Plan Neighborhood Date: April 17, 2018

Project Location Map

2 In accordance with the California Environmental Quality Act (CEQA), given the scope of

environmental issues to analyze and evaluate for the Beechwood Specific Plan project, an

environmental impact report (EIR) is necessary to be prepared.

3 In 2011, the City solicited EIR proposals from several planning firms, including Firma Planning Consultants The proposal from Firma Planning Consultants included a sound methodology for preparing the EIR and it was the lowest cost proposal At the request of the project proponents and direction of City staff, Firma Planning Consultants provided an updated EIR proposal, including a Scope of Work, which was approved by the Community Development Director Given the familiarity that Firma Planning Consultants already had with this project, City staff did not request additional proposals from other firms The cost of the study is proposed in the amount of $144,290 The proposal and scope of work are provided in Attachment 1, Draft Resolution, Exhibit A.

4 The City’s Purchasing Manual, under Section 7, provides for the ability of the City to “sole source” professional services (e.g request and receive only one proposal), when it can be determined by the City Council that it is in the best interest of the City to do so In this case, Firma Planning

Consultants has the expertise and background that would be beneficial and in the best interests of the City to prepare the EIR for this project Expanding a search for other qualified consultants would

add a minimum of two months to the timeframe to complete this work, and use extra staff time that could otherwise be used moving this and other projects forward

5 The City’s Purchasing Manual, under Section 6, provides that any contract for “professional services” over the amount of $20,000 must be authorized by City Council

6 The applicant has agreed to pay the cost of the EIR of $144,290 The applicant is satisfied with the scope of work, and are anxious to initiate this EIR for the project, and is in full support to use Firma Planning Consultants No City funds will be used to prepare this study

Options

1 Take no action

2 Approve use of Firma Planning Consultants by making a determination that it is in the best interest of the City to sole source preparation of this EIR in the amount of $144,290, and direct staff to enter into a contract with Firma Planning Consultant to complete this study in accordance with the

proposal submitted

3 Amend the above-listed action

4 Refer back to staff for additional analysis

Analysis and Conclusions

The City has had favorable experiences working with Firma Planning Consultants on other projects Firma Planning Consultants has qualified staff with the necessary expertise and experience to complete this study Their proposal is acceptable to the applicant, and preparation of the study will not impact the City’s fiscal resources The City Council has the authority to sole source these services for the intended purpose, and to approve expenditures over $144,290

Option 2 Provides efficiency in expediting the EIR process for the City and applicant by using the

environmental consultant with the most experience and familiarity with the localized issues involved with this project, and saves staff resources and time by not requiring an additional RFP process for an

expenditure over $20,000 (with the cost of preparing the EIR to be 100% funded by the applicant) Options 1, 3 and 4 These options would delay the processing time of this application, which will add cost

to the applicant and the City, since extra time spent on this project by staff conducting an RFP process would use staff time that would not be available for use on other projects The outcome may also not yield any more qualified consultants to prepare this EIR

WHEREAS, the project proponents for the Beechwood Specific Plan neighborhood area has submitted a General Plan Amendment (GPA 12-004) and Specific Plan (SPA 18-001) applications that are supported with

a project description and exhibits for property located between Creston Road, Beechwood Drive, Meadowlark Road and the eastern City limits; and

WHEREAS, in accordance with the California Environmental Quality Act (CEQA), given the scope of environmental issues to analyze and evaluate for the Beechwood Specific Plan project, an environmental impact report (EIR) is necessary to be prepared; and

WHEREAS, in 2011, the City solicited EIR proposals from several planning firms, including Firma Planning Consultants The proposal from Firma Planning Consultants included a sound methodology for preparing the EIR and it was the lowest cost proposal At the request of the project proponents and direction of City staff, Firma Planning Consultants provided an updated EIR proposal, including a Scope of Work, which was approved by the Community Development Director Given the familiarity that Firma Planning Consultants already had with this project, City staff did not request additional proposals from other firms The cost of the study is proposed in the amount of $144,290; and

WHEREAS, the City’s Purchasing Manual, under Section 7, provides for the ability of the City to “sole source” professional services (e.g request and receive only one proposal), when it can be determined by the City Council that it is in the best interest of the City to do so In this case, Firma Planning Consultants has the expertise and historical background that would be beneficial and in the best interests of the City to prepare the EIR for this project Expanding a search for other qualified consultants would add a minimum

of two months to the timeframe to complete this work, and use extra staff time that could otherwise be used moving this and other projects forward; and

WHEREAS, the City’s Purchasing Manual, under Section 6, provides that any contract for “professional services” over the amount of $20,000 must be authorized by City Council; and

WHERAS, the applicant has agreed to pay the cost of the EIR of $144,290 The applicant is satisfied with the scope of work, and are anxious to initiate this EIR for the project, and is in full support to use Firma Planning Consultants No City funds will be used to prepare this study

NOW, THEREFORE, BE IT RESOLVED that the City of El Paso de Robles approves authorizing execution of a consultant agreement for the City to hire Firma Planning Consultants to prepare an EIR consistent with Exhibit A – Proposal for Services for the Beechwood Specific Plan project (GPA 12-004/SPA 18-001) as a

“sole-source” for consultant services, and approving an expenditure over $20,000, in the amount of $144,290, paid for by the project applicant

PASSED AND ADOPTED THIS 17th day of April, 2018, by the following roll call vote:

Kristen L Buxkemper, Deputy City Clerk

Exhibit A - EIR Proposal – Firma Planning Consultants

Firma Consultants Incorporated

David W Foote ASLA

187 Tank Farm Road Suite 230

We are pleased to submit this proposal for your consideration I have prepared EIRs for over

30 years and for the past decade have focused almost exclusively on CEQA documents for

public agency sponsored projects, ranging from schools to public infrastructure to parks on

the project side and General Plan Element updates, annexations and Specific Plans on the

program side

Recently I have worked on the EIR for a major annexation and Specific Plan for 1,700 acres

in Price Canyon for the City of Pismo Beach That project involves 697 residences and a mix

of visitor serving commercial and open space The Beechwood Specific Plan area is less

complex environmentally and enjoys the benefit of already be annexed to the City, however

there are some substantive similarities for topics like traffic, smart growth, air quality,

adjacency to agricultural lands and LID Our very recent interaction with the RWQCB,

Caltrans and APCD, as well as the County Agriculture Department have given us insight into

how these agencies currently view the issues and mitigation strategies for projects of this

size The Price Canyon project has shown how vital it is to have the Specific Plan and WSA

really complete before circulating an EIR

For this project, Firma Associate environmental planner Lindsay Corica will assist on all

sections and we will have Michelle Gibbs with MIG consultants as a planner for several

sections and quality control Since 1997, Ms Gibbs has authored and managed over

twenty-six CEQA, NEPA, or joint documents including projects for oil and gas, Caltrans/FHWA, Air

Force, NOAA, and various school districts and municipalities Ms Gibbs worked as a senior

planner with the Santa Barbara County Development Review Division South for 3 years and

processed major conditional use permits, development plans, tract maps, lot line

adjustments, and rezones, coastal development permits Resumes for myself, Lindsay and

Michelle are attached

The Work Plan following details our approach and explains our observations and concerns

about the Specific Plan, as it stands

Attachment 2

Last, I would like to emphasize that by hiring Firma the City will get my depth of experience

in CEQA, as well as on development projects in Paso Robles, directly on every aspect of EIR

preparation through public hearings My experience as a designer as well as an

environmental consultant offers a unique skill set that will be valuable on this complex and

Project: Beechwood Specific Plan EIR

Work Tasks and Estimated Fees 3-22-18

Project Initiation

Contract & Project Administration 20 8 $ 3,960.00

Meetings with consultant team and City 12 8 1,450 $ 4,210.00 MIG

Review BSP / Project Description 8 20 1,000 $ 4,600.00 MIG

Draft EIR

Environmental Baseline /Cumulative scenario 6 6 $ 1,020.00

Consistency with Plans and Policies 2 2 2,400 $ 2,940.00 MIG

Health Risk Assessment 1 2 5,000 $ 5,390.00 MIG

Population and Housing 2 4 3,000 $ 3,780.00 MIG

Growth Inducing Effects 8 8 3,000 $ 5,160.00 MIG

Meetings with City/AdHoc Com in progress 20 12 $ 4,440.00

Final EIR

Responses to comments 40 30 2,000 $ 11,600.00 MIG

Beechwood Specific Plan EIR

PROJECT UNDERSTANDING

The City undertook the preparation of the EIR for the draft Olsen Ranch Beechwood Specific Plan

EIR in 2007 In the course of EIR preparation the City also began the process of a major update

to the General Plan Circulation Element, at which time the City determined the Specific Plan EIR

should be put on hold until the Update was complete This resulted in a partially finished EIR

Since that time, the Olsen property has dropped out The Beechwood property interest has

proceeded, undertaking a considerable effort to resolve biological issues related to the potential

presence of fairy shrimp, and creating a preliminary draft Specific Plan, which is used as the

basis for this scope of work

The new Beechwood Specific Plan is comprised of multiple property owners and will be built-out

over many years At the time of this EIR proposal, a complete draft Specific Plan is not yet

available The proposal is based on the November 27, 2017 Beechwood Specific Plan Project

Description, the Draft Annotated Outline dated 3-13-18

Last, the City desires that the Specific Plan EIR be crafted to maximize its utility for subsequent

land use actions such as Tentative Tract Maps

APPROACH THE PROJECT

The following summarizes the approach we discussed in our recent meeting

• Although a Program EIR is a valid level of review for a Specific Plan, it is our

understanding that the City and applicant desire the EIR to be a project-level EIR As

mentioned in the cover letter, our recent involvement in the Price Canyon General Plan

update, Annexation and Specific Plan process in Pismo Beach has shown that the more

specific a Specific Plan can be the better the Project and the EIR are received

• For the purposes of analysis the project description will identify a reasonable phasing

plan and build-out horizon

• The EIR will substantiate the adequacy or applicability of Specific Plan “self-mitigating

standards” to mitigate the identified impacts Likewise, the application of Municipal Code

standards can be good mitigation, and the effectiveness needs to be substantiated in the

EIR

• The previous partially completed ADEIR for the Olsen Beechwood SP has limited

usefulness after so many years have elapsed However, we will use previous information as

appropriate

Attachment 2

Beechwood Specific Plan EIR

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landscape architecture • planning • environmental studies • ecological restoration

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• The EIR will tier from the Annexation / GPA EIR prepared for the property In particular,

we will reference findings related to conversion of agriculture land to urban uses

WORK PLAN AND SCOPE

Project initiation

Project initiation will include a discussion with the City about the content of the Specific Plan and

EIR and schedule an EIR Scoping Meeting The Scope includes time for about four meetings with

the City Ad Hoc Committee

We propose no Initial Study, rather we suggest issuing a Notice of Preparation of a full EIR The

project is large and complex enough to be unlikely to able to drop out study topics using the

Initial Study for EIR scoping

We will prepare and mail AB 52 notification letters using the City Tribal list As we understand

the project actions there is a General Plan amendment proposed, therefore, SB 18 consultation

will also be undertaken

Project Timeline

The traffic analysis (TIA) is a critical path item because noise and air quality analyses are

dependent on the first run of data from that study We assume the TIA will have trip generation

and trip distribution complete for our use within 4-6 weeks of our start-up, if this changes it will

affect our schedule

Upon contract approval, we will schedule the City / stakeholder start-up meeting and set an EIR

scoping meeting date The NOP will be issued before the scoping meeting At the conclusion of

the NOP comment period the substance of the EIR analysis will commence, however there are

tasks that can precede the NOP responses

We estimate the start-up tasks and Administrative Draft EIR process to take 14 weeks

After receiving comments from the City on the ADEIR we will have the DEIR ready for review and

distribution within four weeks

We estimate the Response to Comments, Finding and AFEIR task to take up to four weeks

Additional Information in the Specific Plan

We propose the City request documentation in the Specific Plan on the expected outcome of LID

measures In our experience on the Price Canyon project, the RWQCB was in support in of the

EIR analysis and strategy to use LID standards from the City’s Stormwater Management Program

as mitigation, but indicated the Specific Plan itself lacked detail, making it difficult for the

Attachment 2

Beechwood Specific Plan EIR

RWQCB to review the project The Beechwood Specific Plan could provide more background

analysis on this topic

It is our understanding that the Specific Plan will include analysis of pre and post development

stormwater in the 25 and 100-year storm events

Major Study Topics

Transportation Impact Analysis (under separate contract)

Associated Transportation Engineers will prepare the transportation impact analysis under direct

contract with the City We have reviewed the ATE scope of work and note the scope includes, in

addition to vehicular analysis, pedestrian and bicycle circulation and safety The ATE scope does

not include discussion of Circulation Element and other General Plan and land use consistency

This topic will be addressed in the EIR und Land Use Consistency

Noise

Ambient Noise Consultants will prepare the noise impact section The section will identify

existing and future transportation noise sources and conditions within the project study-area and

evaluate project effects on the key roadways and intersections in the vicinity of the site The

study will be prepared using sound level contours analysis to assess the project's effects on

sound levels at defined distances from roadways intersections

The scope of work addressed in this study will include a comprehensive analysis of existing and

future projected transportation noise sources in the Specific Plan area, based on data provided

by the EIR traffic engineer for the following transportation noise scenarios:

1) Existing Conditions 2) Existing + Project 3) Cumulative projects + Project 4) Year 2030 + Project

All sound level depictions are based on field measurements of existing ambient and

transportation sound levels, taken at key locations The circulation network in the EIR Traffic and

Circulation will be used for the noise impact analysis

Sound levels will be expressed as long-term LDN (Day-Night Level) values with associated

penalties for sound levels produced during nighttime hours Existing and Future noise contours

will be generated by acoustical computer modeling procedures that comply with Federal Highway

Administration Transportation Noise Model criteria and protocols Significance thresholds will be

derived from the City Noise Element and Noise Ordinance The EIR will evaluate the effectiveness

Attachment 2

Beechwood Specific Plan EIR

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landscape architecture • planning • environmental studies • ecological restoration

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of Specific Plan standards and design to attenuate traffic noise and identify additional measures

to achieve compliance with City standards

Ground-borne vibration levels commonly associated with onsite construction activities and

equipment operations will be discussed Ground-borne vibration impacts associated with

long-term project operations are anticipated to be minor and will be qualitatively assessed

The significance of short-term construction and long-term operational noise impacts will be

evaluated in comparison to applicable noise standards Mitigation measures will be developed for

significant impacts The effectiveness of proposed mitigation measures will be quantified and

included in the report

Air Quality

The Olsen Beechwood ADEIR preliminarily identifies a Class I impact for project generated

vehicular emissions Assuming the same will be the case of the Beechwood EIR, all feasible

mitigation measures need to be specified in the EIR The Specific Plan has numerous design

features to encourage a pedestrian community and reduce trips, such as neighborhood

commercial zoning We will consult with the APCD about efficacy of these measures to reduce

impacts, however, with a Class I impact for a project of this size, the APCD will likely ask for

off-site mitigation funding

For a project action of this size, the APCD is most interested in making sure the project

incorporates design and planning features that reduce vehicle miles traveled This overarching

strategy is, and will continue to be, the primary strategy for reducing all emissions, including

greenhouse gases, as the regulatory framework continues to evolve As a result, the proposal for

increased density may appeal to the APCD

The analysis will use the California Emissions Estimator Model (CalEEMod, Version 2016.3.2) to

estimate the level of criteria air pollutants (e.g., particulate matter or PM), toxic air contaminants

(TAC; e.g., diesel PM), and GHGs (e.g., carbon dioxide and methane) generated by the

construction and operation of the Proposed Project The resulting emissions estimates would be

compared to CEQA significance thresholds maintained by the San Luis Obispo County Air

Pollution Control District (SLOAPCD) for the purposes of determining whether a project would

cause or or contribute to an existing or projected air quality violation, expose sensitive receptors

to substantial pollutant concentrations, or result in a cumulatively considerable net increase in

emissions of a non-attainment criteria air pollutants Construction emission calculation for a

project will be a multi-decade buildout that some basic assumptions can be made for within the

existing regulatory framework

We do not propose to run CO hotspot modeling, especially due to the long-term downward trend

of CO due to vehicle fleet emission improvements

Attachment 2

Beechwood Specific Plan EIR

Health Risk Assessment

Due to the presence of nearby sensitive residential and school (Virginia Peterson Elementary

School) receptors on Beechwood Drive, we are including a construction health risk assessment

(HRA) in its scope of work It is our experience that the APCD will want this level of assessment

for this scale of project We would use the U.S EPA-approved and SLOAPCD-recommended

regulatory model (AERMOD) to predict exposure to concentrations of pollutants at sensitive

receptor locations and quantify associated health risks If necessary, the EIR would identify

mitigation measures to reduce construction emissions and health risks to less than significant

levels, such as the use of late model construction equipment meeting U.S EPA Tier 3 or Tier 4

exhaust emission standards

Biological Resources

The Biological Report prepared by Althouse and Meade dated 2014 offers the following

information in summary:

• Habitat types identified and mapped in the Study Area consist of cropland, vineyard,

anthropogenic, wetland, and ephemeral pool No sensitive natural communities are

present in the Study Area

• Botanical surveys conducted in spring and summer 2014 identified 102 species,

subspecies, and varieties of vascular plants in the Study Area Habitat and soil conditions

are appropriate for six special status plant species No special status plant species were

detected in the Study Area in 2014

• Wildlife species detected in the Study Area include 1 reptile, 28 birds, and 5 mammals

Appropriate habitat is present in the Study Area for sixteen special status animals No

state or federally listed animals were detected in the Study Area

The EIR will rely on this report as well as the 2018 Wetland Delineation Report by Althouse and

Meade It is our understanding that the absence of the federally listed fairy shrimp has been

confirmed, with concurrence from the USFWS It is also our understanding that the applicant will

provide additional information form Althouse and Meade related to biological resource impacts

and mitigation for review

The EIR will peer review the Biological Report (2014) and the Delineation of Potentially

Jurisdictional Wetlands and Waters – Amendment 1 (2018) prepared by Althouse and Meade for

the project We would also review other biological reports completed for projects in the immediate

project area, and query the California Natural Diversity Data Base (CNDDB) maintained by the

California Department of Fish and Wildlife (CDFW) to ensure all special status biological resources

potentially occurring on the project site were identified and evaluated A field reconnaissance level

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Beechwood Specific Plan EIR

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landscape architecture • planning • environmental studies • ecological restoration

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survey would then be conducted to ground truth the data presented in the reports and evaluate

the conclusions and impact and mitigation analysis

Low Impact Development and Stormwater

The City’s adopted SWMP (2010) defines strategies and guidelines for the protection of water

quality and reduction of pollutant discharges within the city The Central Coast Regional Water

Quality Control Board (RWQCB) has created a “Vision of Healthy Watersheds” to focus its

implementation of state and federal water quality laws to best protect and enhance county

watersheds This vision is currently being realized with the Regional Joint Effort for the

Development of Hydromodification Control Criteria and the requirement for all Small Municipal

Separate Storm Sewer Systems in its jurisdiction to implement Best Management Practices

(BMPs) for long-term watershed protection The City has adopted a Stormwater Technical Guide

consistent with the RWQCB Post-construction Storm Water Management Requirements

The SWMP requires that projects include BMPs that reduce pollutants in a storm water runoff to

the technology-based standard of “maximum extent practical” (MEP) to protect water quality

These standards establish the level of pollutant reductions that dischargers must achieve

The EIR would benefit from inclusion of more detailed engineering data from the applicant on the

techniques identified in the Specific Plan, especially the adequacy of stormwater quality basins

and their relation to larger storm events

The Specific Plan would be expected to identify sustainable stormwater management principles

that would guide the design of the development These contain a variety of measures and BMPs to

implement the SWMP within the Specific Plan area MEP is generally a result of emphasizing

pollution prevention and source control BMPs as the first lines of defense in combination with

structural and treatment methods serving as additional lines of defense, and the Specific Plan

seems to point in that direction However, for the purposes of the EIR analysis it would be

valuable to have the Specific Plan preparers explain the connection between the stormdrain

conveyances and water quality basins and the implementation of the first line of defense

• Describe, using applicant supplied analyses, quantification of potential storm water

volumes and stormwater pollutant loads,

• Describe how well the proposed measures achieve MEP reductions in pollutant loads in

consultation with the RWQCB,

• Formulate an analytical framework to discuss how well identified sustainable stormwater

management principles in the Specific Plan can be implemented, and

Attachment 2

Beechwood Specific Plan EIR

• If necessary, develop additional mitigation measures that can be readily used by City staff

in evaluating subsequent entitlement applications

Visual Resources

The EIR section will identify all applicable City policies related to visual resources from the

General Plan and use these as impact significance criteria Based on these policies and

discussions to date, it understood that the change from open land to urban use may be

considered a less than significant impact with mitigation

Photos of the Specific Plan area from four public views will be depicted It is not likely that the

final ground elevation plus or minus a few feet will substantially change the overall impact

because the potential for ridgeline silhouetting and view blockage that might otherwise cause

impacts is not present in this case As a result, we do not propose to create a precisely accurate

representation of scale that uses vertical pylon poles referenced to horizontal ground datum

Rather, the graphics will show pre- and post-development conditions that simulate the basic

scale of the residences, perimeter landscape and wall treatments and the general change in

topographic elevation We will use the applicant’s grading plan to approximate finished landform

elevations within each view The purpose of the simulations will be more on architecture

character, perimeter treatment, massing and scale rather than a precise modeled representation

The Specific Plan design guidelines and principles will be evaluated for adequacy to avoid or

minimize potentially significant visual impacts The discussion will include glare considerations

Mitigation measures will be formulated to be readily be added to the Specific Plan, or

implemented at subsequent project level actions such as Tract Maps as conditions of approval

Alternatives to the Proposed Project

The discussion will include the reasons the General Plan identified this site for the land uses it

did and tie the range of possible alternatives to how well they meet the project objectives It is

likely that several conceivable alternatives may be rejected as infeasible, and these reasons will

be carefully explained

The first consideration for selecting alternatives to the proposed project for analysis is to select

alternatives that avoid of reduce one or more significant impact, especially Class 1 impacts

Since air quality is a likely Class 1 impact, the alternative discussion should address VMT The

discussion could explain whether the Specific Plan area, which is on the low-density edge of the

city, could be less dense with density increases directed to the core of the city We believe this

discussion is needed in light of the current regulatory objectives state and countywide for

high-density infill and reducing vehicle miles traveled

For the purpose of scoping the cost of analysis is it assumed there will be, in addition to the No

Project Alternative, two other land use scenarios:

Attachment 2

Beechwood Specific Plan EIR

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landscape architecture • planning • environmental studies • ecological restoration

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• Development under the current General Plan land use density (674 residential units

and 4.6 acres of commercial retail land use)

• A to be determined land use scenario crafted in coordination with the City and applicant

The TIA does not include any alternatives discussion in its scope When this is the case, we

typically derive a qualitative, order-of-magnitude comparative analysis of traffic impacts from the

traffic analysis for the Alternative section of the EIR

Because the TIA does not provide quantified data on the alternatives, the noise and air quality

discussion in the alternatives section of the EIR will be similarly derived and be more qualitative

and order-of magnitude oriented

At this early point in the process, it cannot be determined that the level of Alternatives analysis

will be sufficient for the City to approve one of the Alternatives, unless the Alternative is

manifestly less impact

Topics from Olsen Beechwood Specific Plan ADEIR Needing Updating

In reviewing the previous ADEIR and current regulatory and environmental settings, we have

identified population and housing as needing updating in the EIR to reflect the current adopted

Housing Element population setting, housing inventory and characteristics and policies

Other capacity related topics might require updating including wastewater, water supply and

public services In particular, the discussion of the groundwater basin will need to be updated to

reflect the current “conversation” about overdraft It is our understanding that the Water Supply

Assessment will be completed by Todd Engineering for our use in the EIR

Based on USFWS comments on the City’s Circulation Element EIR, it appears a more robust

discussion of kit fox issues should be included in this EIR As discussed the City and applicant

will engage the USFWS on the mitigation strategy for Kit Fox and we will use this information in

the biological resources section of the EIR

Usability for Subsequent Actions

One consideration is how well mitigation measures can be used by City staff over the years in

subsequent actions Likewise the way impacts are stated can either aid or hinder staff in

subsequent CEQA review for tentative tract map applications We have discovered this principle

in performing mitigation monitoring using agency EIRs

Both impacts and mitigation measures tend to get disembodied existences over time, so the

language in them must be intelligible over many years and various staff One method we propose

to help this matter is to provide a mitigation measure table that breaks the measures out by

Specific Plan area parcel

Attachment 2