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HomeMy WebLinkAboutECF_NEPA_Documents_190315_v1.pdf U.S. Department of Housing and Urban Development 451 Seventh Street, SW Washington, DC 20410 www.hud.gov espanol.hud.gov Page 1 of 4 Environmental Review for Activity/Project that is Exempt or Categorically Excluded Not Subject to Section 58.5 Pursuant to 24 CFR Part 58.34(a) and 58.35(b) Project Information Project Name: Homestead Willow Crest Townhomes Responsible Entity: City of Renton Grant Recipient (if different than Responsible Entity): Community Frameworks State/Local Identifier: Preparer: Lisa Grueter, AICP, Principal, BERK Consulting, Inc. Certifying Officer Name and Title: Mayor Denis Law and designee, Greg Zimmerman, chair of the Environmental Review Committee Responsible Entity Contact: Matt Herrera, AICP Senior Planner Community & Economic Development Department City of Renton 1055 South Grady Way Renton, WA 98057 MHerrera@Rentonwa.gov 425.430.6593 Consultant (if applicable): BERK Consulting, Inc. Project Location: 1132 Edmonds Ave NE Description of the Proposed Project [24 CFR 58.32; 40 CFR 1508.25]: Twelve Townhomes called Homestead Willow Crest are proposed on a vacant parcel at 1132 Edmonds Ave NE (site 18 within the Sunset Master Site Plan). Project Name Project Locality and State HEROS Number Page 2 of 4 Level of Environmental Review Determination: Activity/Project is Exempt per 24 CFR 58.34(a): ________________________________ Activity/Project is Categorically Excluded Not Subject To §58.5 per 24 CFR 58.35(b) (7) Funding Information Grant Number HUD Program Funding Amount # SH16-021 Self-Help Homeownership Opportunity Program (SHOP) $180,000 Estimated Total HUD Funded Amount: $180,000 This project anticipates the use of funds or assistance from another Federal agency in addition to HUD in the form of (if applicable): Estimated Total Project Cost (HUD and non-HUD funds) [24 CFR 58.32(d)]: $5.1 million Compliance with 24 CFR §50.4 and §58.6 Laws and Authorities Record below the compliance or conformance determinations for each statute, executive order, or regulation. Provide credible, traceable, and supportive source documentation for each authority. Where applicable, complete the necessary reviews or consultations and obtain or note applicable permits of approvals. Clearly note citations, dates/names/titles of contacts, and page references. Attach additional documentation as appropriate. Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR 50.4 and 58.6 Are formal compliance steps or mitigation required? Compliance determinations STATUTES, EXECUTIVE ORDERS, AND REGULATIONS LISTED AT 24 CFR §58.6 Airport Runway Clear Zones and Accident Potential Zones 24 CFR Part 51 Subpart D Yes No The site is not within 2,500 feet of a civil airport or 15,000 feet of a military airport. Project Name Project Locality and State HEROS Number Page 3 of 4 Compliance Factors: Statutes, Executive Orders, and Regulations listed at 24 CFR 50.4 and 58.6 Are formal compliance steps or mitigation required? Compliance determinations Coastal Barrier Resources Coastal Barrier Resources Act, as amended by the Coastal Barrier Improvement Act of 1990 [16 USC 3501] Yes No Washington is not a state within units of the Coastal Barrier Resources System (CBRS). Flood Insurance Flood Disaster Protection Act of 1973 and National Flood Insurance Reform Act of 1994 [42 USC 4001-4128 and 42 USC 5154a] Yes No The site is not within a mapped floodplain, nor are there abutting waterbodies. Mitigation Measures and Conditions [40 CFR 1505.2(c)] Summarize below all mitigation measures adopted by the Responsible Entity to reduce, avoid, or eliminate adverse environmental impacts and to avoid non-compliance or non-conformance with the above-listed authorities and factors. These measures/conditions must be incorporated into project contracts, development agreements, and other relevant documents. The staff responsible for implementing and monitoring mitigation measures should be clearly identified in the mitigation plan. See Attachment: Categorically Excluded Not Subject to (CENST) Section 58.5 Documentation, Planned Action Concurrence Review Preparer Signature: ________________________________________Date:__2/12/2019______ Name/Title/Organization: ___________ Lisa Grueter, AICP, Principal, BERK Consulting, Inc. Project Name Project Locality and State HEROS Number Page 4 of 4 City of Renton Environmental Review Committee (ERC) Date: Signature: Chair Signature: Signature: Signature: This original, signed document and related supporting material must be retained on file by the Responsible Entity in an Environmental Review Record (ERR) for the activity/project (ref: 24 CFR Part 58.38) and in accordance with recordkeeping requirements for the HUD program(s). 1 Categorically Excluded Not Subject to (CENST) Section 58.5 Documentation, Planned Action Concurrence Review Renton Sunset Terrace Redevelopment | Homestead Willow Crest Townhomes Prepared by: BERK Consulting, Inc. on behalf of Homestead Community Land Trust | February 2019 1 Background 1.1 SUNSET AREA COMMUNITY AND SUNSET TERRACE REDEVELOPMENT The City of Renton, along with the Renton Housing Authority (RHA ), and other public, private, and nonprofit agencies and developers, is redeveloping the Sunset Terrace public housing community plus some peripheral sites that have been master planned for redevelopment along with Sunset Terrace for a total of about 12.7 acres. See Exhibit 1. The master plan envisions a mixed-use, mixed-income community with park and library and other civic and commercial uses. Mixed-use sites will have both market rate and affordable rental housing in multi-story, multi-family townhomes and apartments, along with commercial and retail space. In order to meet National Environmental Policy Act (NEPA) and State Environmental Policy Act (SEPA) requirements, the City of Renton issued the Draft Environmental Impact Statement (DEIS) for the City of Renton Sunset Area Community Planned Action on December 17, 2010 and the Final Environmental Impact Statement (FEIS) for the City of Renton Sunset Area Community Planned Action on April 1, 2011.1 The City served as the Responsible Entity (RE) for NEPA compliance, and the lead agency for SEPA compliance. The Sunset Terrace Master Site Plan Area was also the subject of subsequent revaluations/addenda in 2014 and 2016 when additional dwellings, alternative building locations, height, and street reclassifications were considered in the Sunset Terrace area. The Master Site Plan is illustrated below. 1.2 HOMESTEAD WILLOW CREST PROPOSAL Twelve Townhomes called Homestead Willow Crest are proposed on a vacant parcel at 1132 Edmonds Ave NE (site 18 within the Master Site Plan). It has been studied in the above environmental documents for a variety of densities, most recently in 2016 for 68 apartment units. Homestead Community Land Trust is seeking SHOP federal funds and wishes to initiate NEPA review for a 12-unit townhome development. See Exhibit 2 and Exhibit 3. 1 CH2MHill and ICF International. 2011. Sunset Area Community Planned Action NEPA/SEPA Environmental Impact Statement. Final. April. (ICF 00593.10.) Bellevue and Seattle, WA. Prepared for City of Renton and the Renton Housing Authority, Renton, WA. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 2 Exhibit 1. Sunset Terrace Master Site Plan 2016 Source: Mithun, City of Renton 2016 Exhibit 2. Homestead Willow Crest Townhomes Plan Source: Third Place Design 2019. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 3 Exhibit 3. Homestead Willow Crest Site Plan Source: Third Place Design 2018. Per the City’s request to the applicant, the site plan illustrates that a multi-family development west of the townhomes on the balance of the vacant site is feasible conceptually. See Exhibit 4. This document does not evaluate the multifamily housing to the west, focusing on the townhomes proposal. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 4 Exhibit 4. Homestead Willow Crest Site Plan Phase I (under review) Conceptual Future Multifamily Phase II (not part of review) Source: Third Place Design 2019. This CENST Documentation, Planned Action Concurrence Review addresses the Homestead Willow Crest proposal, demonstrating it is in the range of the prior alternatives and environmental documents identified above. Information provided to BERK Consulting, Inc. included: ▪ Homestead Willow Crest Townhomes, Site Plan, Third Place Design, January 7, 2019 ▪ Homestead Willow Crest Townhomes Plans and Elevations, Third Place Design, November 7, 2018 ▪ Sunset Crest Townhomes (now Homestead Willow Crest) Trip Generation Study, November 30, 2018 ▪ Personal Communication, December 13, 2018; Brent Chastain, Third Place Design, to Lisa Grueter, BERK Consulting, Inc. regarding impervious surface calculations for Homestead Willow Crest Townhomes ▪ Personal Communication, December 14, 2018, Philippa Nye, Ally Community Development, to Lisa Grueter, regarding Homestead Willow Crest Townhomes proposal and adjacent property February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 5 2 CENST Documentation, Planned Action Concurrence Review Analysis 2.1 LAND USE AND AESTHETICS The 2016 Reevaluation included the subject site (#18) as part of a Master Site Plan, and the concept assumed an “Edmonds Apartments” development with a greater number of dwelling units, higher density, greater height, and more extensive impervious footprint. Homestead Willow Crest proposes less residential development with 12 townhomes and a lower height than previously studied; it does not exceed development levels studied during 2011-2016. Design standards would apply. The City of Renton has requested the applicant provide a concept for the remaining undeveloped site to ensure it is feasible to develop; this CENST Documentation, Planned Action Concurrence Review for Homestead Willow Crest does not address that portion of the site. It is possible that the balance of the site will develop and would undergo its own review for NEPA/SEPA purposes. Exhibit 5. Edmonds Apartment Assumptions 2016 Reevaluation and Homestead Willow Crest Townhomes Proposal FEATURE Edmonds Apartment Concept 2016 Reevaluation Homestead Willow Crest Townhomes 2018 CENST Documentation, Planned Action Concurrence Review Share Of 2016 Development Assumptions Zone CV CV Same zone Acres 1.73 0.59 34% of site acres Assumed Units 68 12 18% of assumed units Proposed Units Per Net Acre 40 20.45 Less density per net acre Minimum Density Units Per Net Acre 20 20 Achieves more than minimum density Maximum Density Units Per Net Acre 80 80 Less than maximum zoning Height in feet 50 37.5 Lesser in height Parking Spaces 112 21 19% of assumed spaces Conceptual Plan – Share of Impervious Area square feet 39,200 18,882 48% of prior conceptual plan impervious area; cumulatively with other development, results are in range of EIS alternatives. See Attachment A. Assumed Pollutant Generating Impervious Surfaces for Site 3,200 9,601 For this site, the PGIS is greater than prior site assumptions but cumulatively with other development is still in range of EIS alternatives. See Attachment A. Source: Third Place Design; BERK 2018. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 6 2.2 WATER RESOURCES / IMPERVIOUS SURFACES Water resources was a key topic in the EIS; an accounting of effective impervious area was tracked particularly for the NEPA analysis. As shown in Exhibit 5, the proposal would generate less total impervious surface assumed for the site; cumulatively with other Master Site Plan development, it would not exceed the prior range of impervious area calculated for the EIS Alternatives. Homestead Willow Crest would also contribute PGIS area, but cumulative results would be in the range of the prior EIS alternatives per Attachment A. On the adjacent Glenwood Townhomes site to the east, approximately 900 square feet of the existing pervious paving in parking lot will be removed and replaced with pervious paving or planting area to allow the shared access drive to cut through that area to the Homestead Willow Crest development. The Homestead Willow Crest development is not proposed to include pervious paving. However, Homestead Willow Crest does not exceed the total impervious surface assumptions for the Edmonds Apartment concept and cumulatively results are within the range of impervious surface assumption for the Master Site Plan area. City stormwater standards and plans would apply per ROD mitigation measures. See Attachment C. If there is a future proposal on the western portion of the site, the City would review its compliance with water resources requirements including the impervious analysis. 2.3 NATURAL ENVIRONMENT AND RESOURCES (EARTH, AIR QUALITY/ENERGY, PLANTS AND ANIMALS) The Homestead Willow Crest Townhomes site does not appear to have mapped critical areas. It would contribute an incremental amount of greenhouse gas emissions and energy use but not exceed assumptions in the 2011 EIS and subsequent Reevaluations. See Attachment C for ROD mitigation measures. 2.4 CULTURAL RESOURCES Through the 2011 NEPA process, a cultural resources survey was conducted on Site 18 (the proposal site) and no archaeological resources or historic resources were found on the property. Agency notifications and procedures were addressed at that time as documented in the 2011 Record of Decision and 2014/2016 Revised Records of Decision. Inadvertent discovery mitigation measures would apply. 2.5 TRANSPORTATION It is estimated that 12 townhome units would generate approximately 88 vehicle trips over the course of a typical weekday including 5 trips during the weekday AM peak hour and 7 trips during the weekday PM peak hour. See Attachment B. The larger Edmonds Apartment development would have generated greater trips, which were already addressed in the 2011 EIS and 2014 Reevaluation. No impacts beyond the prior analysis is anticipated. The development would be required to meet City access standards and provide for transportation impact fees. The small number of trips would be deducted from the City’s traffic trip bank in the SEPA Planned Action Ordinance. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 7 2.6 NOISE AND ENVIRONMENTAL HEALTH The site is located away from SR 900 where there is more traffic related noise. Environmental health hazards were not identified in the 2011 EIS for the property, and standard protocols for development would apply per Attachment C. 2.7 PARKS AND RECREATION, PUBLIC SERVICES, AND UTILITIES The development levels on the Homestead Willow Crest would not exceed prior development levels for the Edmonds Apartments concept. There would be some demand for parks and recreation, public services, and utilities, and ROD mitigation measures would apply. See Attachment C. 2.8 SOCIOECONOMICS AND ENVIRONMENTAL JUSTICE The Homestead Willow Crest Townhomes offer affordable ownership housing on a site planned and considered for residential uses. No impacts are anticipated. 2.9 SUMMARY Based on this CENST Documentation, Planned Action Concurrence Review, the Homestead Willow Crest Townhomes fits in the range of the prior environmental review conducted for the Sunset Area and Sunset Terrace Redevelopment. Upon the City of Renton’s Responsible Entity determination, this document supports a CENST under 24 CFR 58.35(b) (7): Approval of supplemental assistance (including insurance or guarantee) to a project previously approved under this part, if the approval is made by the same responsible entity that conducted the environmental review on the original project and re-evaluation of the environmental findings is not required under § 58.47. Pending the City or Renton’s Responsible Official determination, this document could support a Planned Action SEPA review under WAC 197-11 and the City’s SEPA rules, demonstrating the proposal was addressed in the cumulative analysis of the EIS and subsequent addenda issued in 2014 and 2016. Preparer ________________________________ Lisa Grueter, AICP, Principal, BERK Consulting, Inc. Date: February 11, 2019 February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 8 Attachments Attachment A: Impervious Analysis – Revised with Homestead Willow Crest Development The CENST Documentation, Planned Action Concurrence Review 2019 analysis demonstrates impervious surface results that are less than 2011 EIS Alternatives and similar to Reevaluation 2016 results, and there is no change to the range or scope of effects previously considered. *Note: This 2019 Review updates assumptions for Homestead Willow Crest Townhomes as part of Site 18; the analysis assumes some impervious area would be added on the remaining vacant portion of Site 18 similar to the conceptual site plan for Phase II; however Phase II is subject to future NEPA review as appropriate by the Responsible Entity. FEIS Alternative 3 Land Cover Analysis Location Total Area (acres) Total Impervious Area (acres) Total Pervious Area (acres) Total PGIS (acres) Total Untreated PGIS (acres) Effective Impervious (acres) Potential Replacement Sites 3.06 2.28 0.78 0.62 0.26 2.14 Potential Sunset Terrace Redevelopment Subarea 12.64 7.04 6.02 2.43 0 4.22 Total 15.70 9.32 6.8 3.05 0.26 6.36 FEIS Preferred Alternative Land Cover Analysis Location Total Area (acres) Total Impervious Area (acres) Total Pervious Area (acres) Total PGIS (acres) Total Untreated PGIS (acres) Effective Impervious (acres) Potential Replacement Sites 3.06 2.57 0.49 0.41 0 2.39 Potential Sunset Terrace Redevelopment Subarea 12.64 6.1 6.54 1.7 0 3.66 Total 15.70 8.67 7.03 2.11 0 6.15 Preliminary Land Cover Analysis Master Plan and Related Sites – Reevaluation 2015-16 Land Cover Analysis Location Total Area (acres) Total Impervious Area (acres) Total Pervious Area (acres) Total PGIS (acres) Total Untreated PGIS (acres) Effective Impervious (acres) Potential Replacement Sites 4.14 1.14 3.00 0.29 0.26 0.68 Potential Sunset Terrace Redevelopment Subarea 12.73 7.03 5.70 1.27 0 4.22 Total 16.87 8.17 8.71 1.57 0.26 4.90 Preliminary Land Cover Analysis Master Plan and Related Sites – 2019 CENST Review Land Cover Analysis Location Total Area (acres) Total Impervious Area (acres) Total Pervious Area (acres) Total PGIS (acres) Total Untreated PGIS (acres) Effective Impervious (acres)* Potential Replacement Sites 4.14 1.14 3.00 0.29 0.26 0.68 Potential Sunset Terrace Redevelopment Subarea 12.73 7.03 5.70 1.38 0 4.22 Total 16.87 8.17 8.71 1.67 0.26 4.90 *Includes rest of Edmonds Apartment site. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 9 CENST Documentation Impervious Area Comparison: 2019 Comparison of Homestead Willow Crest Townhomes to: Total Area (acres) Total Impervious Area (acres) Total Pervious Area (acres) Total PGIS (acres) Total Untreated PGIS (acres) Effective Impervious (acres) 2015-16 Evaluation - - - 0.10 - - 2011 Final EIS Preferred 1.17 -0.50 1.68 -0.44 0.26 -1.25 2011 Final EIS Alternative 3 1.17 -1.15 1.91 -1.38 0.00 -1.46 As shown in Exhibit 5, the proposal would generate less total impervious surface assumed for the site; cumulatively with other Master Site Plan development, it would not exceed the prior range of impervious area calculated for the EIS Alternatives. Homestead Willow Crest would also contribute PGIS area, but cumulative results would be substantially less than the Final EIS alternatives and would not be outside the range or scope studied. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 10 Attachment B: Transportation Evaluation February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 11 February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 12 Attachment C: Record of Decision – Excerpt of Mitigation Measures The Record of Decision (ROD) under NEPA and the Planned Action Ordinance under SEPA apply identical mitigation measures. References to “planned actions” apply to Proposals under NEPA. Earth On the Homestead Willow Crest Portion of Site 18, there are no mapped geologic hazards. The need to address City critical areas ordinances will be determined by the City in permit review. The following mitigation measures included in the Record of Decision (ROD) appear applicable to the development. ▪ Apply erosion-control best management practices (BMPs), as described in Appendix D of the City of Renton Amendments to the King County Surface Water Design Manual. ▪ Planned Action applicants shall identify in their applications the source of earth material to be used in construction and shall consider earth material reuse and provide information to the City regarding why earth material reuse is not feasible if it is not proposed. The City may condition the planned action application to provide for earth material reuse where feasible. Air Quality As part of the cumulative development studied in the 2011 EIS and subsequent reevaluations, the Homestead Willow Crest Townhomes would be subject to Air Quality/Greenhouse Gas (GHG) mitigation measures listed in the ROD and the SEPA Planned Action Ordinance. These include: ▪ Construction contractors will be required to implement air quality control plans and BMPs listed in the ROD. ▪ Planned Action applicants for residential developments shall provide information regarding the feasibility and applicability of indoor air quality measures. The City may condition Planned Action applications to incorporate feasible indoor air quality measures. ▪ The City shall require development applicants to consider the reduction measures shown in [ROD] Exhibit B, Section 2, Table 62 for their projects, and as part of their application explain what reduction measures are included and why other measures found in the table are not included or are not applicable. The City may condition Planned Action applications to incorporate feasible GHG reduction measures. Water Resources The primary mitigation measure is to comply with the City’s surface water standards and Sunset Area Surface Water Master Plan (CH2M HILL, 2011). The Sunset Area Surface Water Master Plan identifies that Edmonds Ave NE to the west would be a “Green Collector Arterial,” which would include green infrastructure design and presumably less impervious surfaces (e.g. rain gardens and pervious sidewalks). 2 Exhibit B has been amended in 2014 and 2016 with additional tables in the Land Capacity section and description of alternatives, but subsequent tables were not properly renumbered. Table 6 is referenced in Exhibit B Section 2 applicable to Air Quality. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 13 Plants and Animals With implementation of proposed stormwater features or standards, no mitigation is required. Energy Energy conditions require consideration of trip-reduction measures and energy conservation measures, similar to and related to Air Quality mitigation measures. The development contributes relatively few trips and does not require a traffic impact analysis; applicable traffic impact fees would apply. Compliance with Air Quality mitigation above would also address Energy. ▪ The City shall require development applicants to consider trip-reduction measures and energy conservation, and as part of their application explain what reduction measures are included and which ones are not included (based on [ROD] Exhibit B Tables 6 or Table 10). The City may condition Planned Action applications to incorporate feasible trip reduction and energy conservation measures. Noise Construction noise requirements identified in the ROD apply and can be made conditions of approval. These include: ▪ Locate stationary equipment away from receiving properties. ▪ Erect portable noise barriers around loud stationary equipment located near sensitive receivers. ▪ Limit construction activities to between 7:00 a.m. and 10:00 p.m. to avoid sensitive nighttime hours. ▪ Turn off idling construction equipment. ▪ Require contractors to rigorously maintain all equipment. ▪ Train construction crews to avoid unnecessarily loud actions (e.g., dropping bundles of rebar onto the ground or dragging steel plates across pavement) near noise-sensitive areas. ROD mitigation gives the City authority to condition use of double-paned windows or other treatments per the Energy Code to reduce traffic noise. However, the site is located away from SR-900. ▪ Although traffic noise is exempt from City noise ordinance, based on site-specific considerations, the City may at its discretion require the new development to install double-pane glass windows or other building insulation measures using its authority under the Washington State Energy Code (RMC 4-5- 040). Environmental Health The proposal is required to provide hazardous materials awareness training, implement a contingency plan to meet state laws, implement stormwater pollution prevention plan, etc. per the ROD. ▪ Since encountering unreported spills or unreported underground fuel tanks is a risk when performing construction, contractors shall be required to provide hazardous materials awareness training to all grading and excavation crews on how to identify any suspected contaminated soil or groundwater, and how to alert supervisors in the event of suspected contaminated material. Signs of potential contaminated soil include stained soil, odors, oily sheen, or the presence of debris. February 2019 | Homestead Willow Crest Townhomes CENST Documentation, Planned Action Concurrence Review 14 Land Use Dust control and construction traffic management will be required and could be applied as conditions of approval. ▪ Under all alternatives, the City shall require planned action applicants to implement appropriate construction mitigation measures, including but not limited to dust control and construction traffic management. Socioeconomics The proposal does not involve changes to SR 900 by WSDOT. The proposal does not involve public housing tenant relocation. Thus, no measures apply. Housing Relocation assistance is not needed; the site is vacant. Other sites are available for Sunset Terrace housing relocation assistance. The proposed development will offer affordable ownership housing opportunities. Environmental Justice No measures apply. Aesthetics Per the ROD, future development occurring under any of the alternatives shall conform to the Renton Municipal Code design standards, including but not limited to the following: ▪ Urban design standards contained in RMC 4-3-100, ▪ Residential Design and Open Space Standards contained in RMC 4-2-115, and ▪ Lighting Standards contained in RMC 4-4-075. Historic/Cultural The City must require compliance with inadvertent discovery per ROD Attachment B, page 62: Attachment 1: Draft EIS, Cultural Resources Appendix J, Plan and Procedures for Dealing with the Unanticipated Discovery. Transportation The development would be required to pay its fair share of transportation impact fees to address system improvements needed for its contribution to growth in trips. Construction mitigation measures would apply. Parks and Recreation City staff will confirm compliance with City open space standards and consistency with Park Impact Fee requirements. Utilities The development will be required to implement water system and sewer system improvements per City plans, codes, and specifications.