347 Highland Development

3/17/25 Letter to Monrovia Planning, Developmental Review Committee,

Dear City of Monrovia Leaders,

Grow Monrovia, along with the undersigned residents, strongly opposes the proposed development at 347 Highland Place. This project presents serious concerns regarding environmental sustainability, public safety, non-compliance with the Madison Specific Plan, and long-term community impact. We urge the City of Monrovia to reject this project in its current form and conduct a more thorough review of its implications.

1. Environmental and Wildlife Concerns

The project site is located at the urban-wildland interface and serves as a crucial habitat for native species, including special-status wildlife and protected trees. While not formally designated as a wildlife corridor, the site plays a significant role in regional biodiversity and wildlife movement.

Oak Woodlands and Protected Trees: The proposed removal of 14 mature oak trees, disturbance of 45 trees total—including 23 additional oaks and a rare Southern California Black Walnut—violates the principles of the California Oak Woodlands Conservation Act (AB 242, 2001) and undermines local conservation efforts.

Wildlife Corridor Disruption: The development will block movement between three distinct oak woodland segments, severing a critical pathway for wildlife, including deer, bobcats, and mountain lions (labeled 1, 2, and 3 in the below image). Game trails (red dots) used by wildlife, including deer and mountain lions, cross the project site and connect these woodland areas. The proposed development would directly impact wildlife moving from segment 1 and block access to segments 2 and 3, severing a critical pathway for animal movement. This fragmentation threatens biodiversity and disrupts the ecological balance of the area.
Special-Status Wildlife: The biological assessment of the site found habitat for nesting birds, special-status bats, and eight specal-status species. The California Fish and Game Code (FGC §2074.2 and §2085) now protects four native bumblebee species observed in the area.
Seasonal Stream & Riparian Habitat: The project site contains 0.28 acres of state jurisdictional waters, requiring permits from the California Department of Fish and Wildlife (CDFW) and the Regional Water Quality Control Board (RWQCB). The stream provides a vital water source for wildlife and supports local hydrology.
A portion of the site, referred to as the "southern extension," was added to the project in 2021 after surveys had already been conducted. The assessment for this area relied primarily on aerial photography rather than field studies, which is not a reliable method for determining ecological impact.

Requested Actions:

Redefine the site as a wildlife corridor and conduct a full wildlife movement study.
Require a new botanical study—the only study to date was conducted in 2021 during a drought year, potentially missing important species. Survey limitations due to COVID-19 restrictions and 2020 Bobcat wildfire impacts prevented access to key habitats for species such as Braunton’s Milk Vetch and the Crotch’s Bumblebee. These constraints raise doubts about the validity of the findings, making additional field studies essential before proceeding.
Deny tree removal permits that fail to meet responsible conservation standards.
Conduct an independent environmental impact study to accurately assess the project’s consequences.
Prioritize preservation over short-term development gains by exploring conservation funding opportunities.
Implement an oak woodland mitigation plan, including preserving existing trees and replanting at a 4:1 ratio for any removed oaks.
Ensure full compliance with CDFW and RWQCB permitting before approval.

2. Geotechnical and Slope Stability Concerns

The Geotechnical Report indicates that the project's existing slopes are highly unstable:

Seismic Instability: The analyzed slope fails to meet the required minimum seismic safety factor (FS=1.10), with reported values as low as FS=0.89.
Vegetation Loss & Erosion Risk: The removal of mature trees and established root systems will further destabilize slopes, increasing landslide and erosion risks.
Lack of Mitigation Measures: The project fails to incorporate adequate slope stabilization strategies such as earth berms, concrete interceptor drains, or retaining walls.

Requested Actions:

Require additional geotechnical studies on landslide risks before approval.
Deny any development plans that do not meet seismic safety standards.

3. Hydrology, Flooding, and Drainage Concerns

Unclear Hydrology Mitigation Plan: The Hydrology Report references stormwater mitigation through a future Grading Plan, but no timeline is provided for implementation. Without clear safeguards, this could lead to erosion and inadequate drainage.
History of Flooding: Adjacent properties, such as 351 Highland Place, have experienced flooding issues due to poor site drainage.
Stream Disruption Risks: The project’s impact on local hydrology could lead to increased sedimentation, higher water temperatures, and degraded water quality, affecting both wildlife and downstream properties.

Requested Actions:

Require a detailed, finalized Grading Plan before approval.
Ensure full compliance with CDFW and RWQCB stormwater regulations.

4. Madison Specific Plan and Zoning Compliance

The proposed development does not comply with the Madison Specific Plan, which was designed to balance development with environmental preservation.

Density Violations: The Madison Specific Plan designates the 347 Highland property as "1 DU/2.5 Acres." Given the lot’s verified size of 6.56 acres, only one additional dwelling unit should be allowed—not the number proposed in the project.
Misrepresentation of Lot Size: The project falsely describes the lot as 7.8 acres, including a flag-shaped property extension that does not align with zoning calculations.
Setback, Height, and Road Width Variances:

* Houses are three stories, exceeding the two-story limit in the Madison Specific Plan.

* The road width at a key choke point is 24 feet, below the required 26 feet for fire safety and emergency access.

* The plan proposes reduced setbacks and smaller garages, increasing wildfire and parking risks.

Failure to Mitigate Fire Risk: The site’s wildfire-prone nature requires ember-resistant zones and additional fire hydrants, neither of which are adequately addressed in the current plan.

Requested Actions:

Reject zoning variances that conflict with the Madison Specific Plan.
Ensure road and setback requirements meet emergency access and fire safety codes.
Require wildfire mitigation measures, such as undergrounding utility lines and installing ember-resistant zones.

5. Public Safety and Infrastructure Costs

Utility Infrastructure Concerns: Overhead power lines on the site have shorted out during windstorms, posing a fire hazard. All lines should be undergrounded.
Firefighting Resources: The closest hydrant is more than 600 feet from the development. An additional hydrant near the emergency turnaround area is necessary.
Insurance Viability: Homes in high-risk wildfire zones already struggle to obtain insurance. Increasing density in this location raises future liability risks.
Costs to the City: The Initial Study states the developer will pay impact fees for fire, police, and infrastructure. However, the dollar amount of these fees remains undisclosed.

Requested Actions:

Require full disclosure of developer-paid impact fees.
Ensure fire safety measures are implemented before approval.

6. Special Protections for Nesting Wildlife

Bird Nesting Season Protections: Project activities, including tree removal and grading, must be prohibited between February 1 and September 15 to protect nesting birds.
Bat Maternity Roosting Protections: Disturbance to potential bat roosts should be avoided between March 1 and September 30.

7. Mountain Lion Habitat

Security footage from nearby properties confirms the presence of mountain lions. The development plan should account for ongoing wildlife activity and avoid further habitat fragmentation. Pictured below is a mountain lion caught on the camera of 249 Highland Place and 351 Highland Pl.

Given the extensive environmental, public safety, and zoning concerns outlined above, we urge the City of Monrovia to reject the proposed development at 347 Highland Place in its current form. The project fails to meet essential geotechnical, hydrological, fire safety, and conservation requirements and should undergo a comprehensive reevaluation to align with Monrovia’s long-term sustainability and public safety goals.