In conclusion, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, does not conflict with the applicable plans and regulatory programs that are discussed above and therefore with respect to this particular threshold, impacts would be less than significant, and no measures would be required.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.9 Hazards and Hazardous Materials
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Create a significant hazard to the public or the
environment through the routine transport, use, or
disposal of hazardous materials?
X
b) Create a significant hazard to the public or the
environment through reasonably foreseeable upset
and accident conditions involving the release of
hazardous materials into the environment?
X
c) Emit hazardous emissions or handle hazardous or
acutely hazardous materials, substances, or waste
within one-quarter mile of an existing or proposed
school?
X
d) Be located on a site which is included on a list of
hazardous materials sites compiled pursuant to
Government Code Section 65962.5 and, as a result,
would it create a significant hazard to the public or the environment?
X
e) For a project located within an airport land use plan or, where such a plan has not been adopted, within two
miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area?
X
f) Impair implementation of or physically interfere with an adopted emergency response plan or emergency
evacuation plan?
X
g) Expose people or structures, either directly or
indirectly, to a significant risk of loss, injury or death involving wildland fires?
X
Impact Analysis
4.9a Would the project create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials? Less Than Significant Impact.
Construction
The Project involves the demolition of building and pavement material of a portion of the ground floor of the existing parking garage on-site and the construction of retail spaces and landscaping as well as the relocation of three ADA parking spaces. Typical of many construction projects, construction of the Project would involve the temporary use of hazardous substances in the form of paint, adhesives, surface coatings and other finishing materials, and cleaning agents, fuels, and Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
oils. Truck trips to deliver hazardous materials would reach the Project Site via designated truck routes such as SR-2, Santa Monica Boulevard, Roxbury Drive, Wilshire Boulevard, and possibly other local streets which connect the Project Site to nearby highways. All potentially hazardous materials used on the Project Site would be contained, stored, and used in accordance with manufacturer’s instructions and handled in compliance with applicable standards and regulations, including, but not limited to the Resource Conservation and Recovery Act, California Hazardous Waste Control Law, federal and State Occupational Safety and Health Acts (OSHA), SCAQMD rules, and permits and associated conditions issued by the City’s Building and Safety Division. In accordance with federal and State law, the Project would be required to disclose hazardous materials handled at reportable amounts.
Additionally, due to the age of the existing parking garage that the Project Site is a part of (constructed in 1970), there is a potential that asbestos-containing materials (ACM) and leadbased paint (LBP) are present on-site. Therefore, in compliance with existing federal and State OSHA standards, comprehensive asbestos and lead surveys would be completed to determine the presence, condition, friability and likely future condition of suspect or confirmed ACM or LBP.
All suspect materials would be handled as ACM and/or containing LBP according to local, State, and federal regulations until the results of sampling and analysis indicate the material is a nonACM or does not contain LBP.
Similarly, regarding the ZTA and GPA associated with the Project, the construction of other development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would also be required to comply with the same regulations regarding the transport, use, or disposal of hazardous materials, and regulations regarding the testing for and removal of ACM and/or LBP.
Therefore, for the reasons substantiated above, impacts related to the routine transport, use, or disposal of hazardous materials during construction would be less than significant.
Operation
Operation of the Project would involve the use and storage of small quantities of potentially hazardous materials in the form of common hazardous substances typical of those used in commercial developments, including paints, solvents, custodial products (e.g., cleaning supplies), pesticides and other landscaping supplies.
The use of these materials would be in small quantities and in accordance with the manufacturers’ instructions for use, storage, and disposal of such products. Moreover, as with Project construction, all hazardous materials used on the Project Site during operation would be used, stored, and disposed of in accordance with manufacturer’s standards and all applicable federal, State, and local requirements, such as the California Hazardous Waste Control Law, federal and State OSHA, the emergency Planning and Community Right-to-Know Act (Superfund Amendments and Reauthorization Act, Title III), and Safe Drinking Water and Toxic Enforcement Act, and Uniform Fire Code. Additionally, regarding the ZTA and GPA associated with the Project, the operation of similar development within the Business Triangle would also be required to comply with the same regulations regarding the transport, use, or disposal of hazardous materials. Therefore, with compliance with manufacturer’s standards and all applicable federal, Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
State, and local laws and regulations relating to environmental protection and the management of hazardous materials, operation of the Project would not create a significant hazard to the public or the environment through the routine transport, use, or disposal of hazardous materials.
Therefore, impacts related to the routine transport, use, or disposal of hazardous materials during operations would be less than significant.
4.9b Would the project create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment?
Less Than Significant Impact.
Construction
Project construction would require demolition of building and pavement materials that could result in the accidental release of hazardous materials. According to the California Department of Toxic Substances Control’s (DTSC’s) EnviroStor and State Water Resource Control Board’s (SWRCB’s) GeoTracker databases, there are no historic or active hazardous waste sites within or in the vicinity of the Project Site.23,24 However, as mentioned in Threshold 4.9a above, due to the age of the existing parking garage that the Project Site is a part of, there is a potential that ACM and LBP are present on-site. Therefore, in compliance with existing federal and State OSHA standards, comprehensive asbestos and lead surveys would be completed to determine the presence, condition, friability and likely future condition of suspect or confirmed ACM or LBP. All suspect materials would be handled as ACM and/or containing LBP according to local, State, and federal regulations until the results of sampling and analysis indicate the material is a non-ACM or does not contain LBP. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which also does not contain any open hazardous waste sites per the EnviroStor and GeoTracker databases. The construction of proposed development within the Business Triangle would also be required to be tested for ACM and/or LBP and comply with pertinent regulations regarding the removal of ACM and/or LBP. Therefore, the Project would not exacerbate environmental hazards related to risk of upset or accident conditions associated with the exposure of ACM or LBP to the public or environment. Impacts during construction would be less than significant.
Operation
As previously discussed, the use of minor amounts of hazardous materials during operation of the Project would be limited to those similar to any other commercial development. Such hazardous materials typical of commercial developments are not considered environmental concerns. Moreover, the use of such materials would be subject to compliance with existing regulations, standards, and guidelines established by the federal, State, and local agencies related to storage, use, and disposal of hazardous materials. Additionally, regarding the ZTA and GPA associated with the Project, the operation of proposed development within the Business Triangle would include similarretail development, which would use similar amounts of hazardous 23 California Department of Toxic Substances Control, EnviroStor, https://www.envirostor.dtsc.ca.gov/public/map/?myaddress.
Accessed July 1, 2024.
24 State Water Resources Control Board, GeoTracker,
https://geotracker.waterboards.ca.gov/map/?CMD=runreport&myaddress. Accessed July 1, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
materials and be required to comply with the same regulations regarding the storage, use and disposal of hazardous materials. As such, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment. Therefore, impacts during operation would be less than significant.
4.9c Would the project emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The nearest school to the Project Site is the Good Shepherd Catholic School located approximately 0.17-mile southwest of the Project Site. All potentially hazardous materials used on the Project Site during Project construction and operations would be contained, stored, and used in accordance with manufacturer’s instructions and handled in compliance with applicable federal and State standards and regulations. As discussed in Thresholds 4.9a and 4.9b, construction of the Project would involve the temporary use of hazardous substances in the form of paint, adhesives, surface coatings and other finishing materials, and cleaning agents, fuels, and oils typically used in construction. However, all such substances and materials would be used, stored, and disposed of in accordance with applicable laws and regulations and manufacturers’ instructions and are not expected to cause risk to the public or nearby schools. In addition, all construction work would be performed consistent with applicable federal and State OSHA requirements to ensure the safety and well-being of construction workers. Additionally, the ZTA and GPA associated with the Project would only affect development within the Business Triangle.
Such development projects within the Business Triangle that are also located within one-quarter mile of an existing or proposed school would similarly be required to comply with pertinent federal and State regulations pertaining to the containment, storage, and use of potentially hazardous materials. Thus, with compliance with applicable laws, regulations, and manufacturers’ instructions, the potential risks of exposure to hazardous materials for the public or the environment, including schools, due to Project construction would be less than significant.
4.9d Would the project be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or the environment? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Government Code Section 65962.5 refers to the Hazardous Waste and Substances Site List, commonly known as the Cortese List, maintained by the DTSC. The Cortese list contains hazardous waste and substance sites including public drinking water wells with detectable levels Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
of contamination, sites with known underground storage tanks having a reportable release, solid waste disposal facilities from which there is a known migration, hazardous substance sites selected for remedial action, historic Cortese sites, and sites with known toxic material identified through the abandoned site assessment program. The DTSC EnviroStor database provides DTSC’s component of the Cortese List data. As mentioned in Threshold 4.9b above, the Project Site is not identified on the EnviroStor databases. Additionally, no sites within the City, including the Business Triangle that would be affected by the associated ZTA and GPA for the Business Triangle, are noted on the Cortese List. Therefore, no impact from the Project, including the adoption of the associated ZTA and GPA, would occur.
4.9e For a project located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing or working in the project area? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Project Site is not located within or near the boundaries of an airport land use plan. The nearest airport is the Santa Monica Airport located approximately 3.9 miles southwest of the Project Site in the City of Santa Monica. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which is also not located within or near the boundaries of an airport land use plan or an airport. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not result in an airportrelated safety hazard or excessive noise for people working in the Project area. There would be no impact.
4.9f Would the project impair implementation of or physically interfere with an emergency response plan or emergency evacuation plan?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Project Site is located in an established urban area that is well-served by an existing roadway network. According to the Los Angeles County Department of Public Works, Santa Monica Boulevard, located approximately 90 feet southeast of the Project Site, is designated as a disaster route. This disaster route would not be subject to any lane closures as a result of the Project, as construction activities would be contained entirely within the Project Site and adjacent sidewalk.
Therefore, the Project would not be expected to substantially interfere with or impair emergency response or evacuation plans, including the City’s or County’s Emergency Operations Plans.
Furthermore, the Project would be designed according to applicable fire code standards. The Project would not involve any changes to the existing internal circulation and access routes for the existing parking garage on-site in such a way that the Project Site would continue to provide adequate circulation and access to facilitate emergency response. Project design and access Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
would be reviewed by the Beverly Hills Fire Department (BHFD) to ensure that emergency access would be maintained within the parking garage that the Project Site is a part of.
Additionally, the associated ZTA and GPA would only affect development within the Business Triangle. Such development projects would be similar in nature and scale to the Project and would therefore also unlikely require lane closures of disaster routes or substantially interfere with or impair emergency response or evacuation plans. Such development projects would also be required to be designed in accordance with applicable fire code standards.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not conflict with the City’s adopted emergency response plan or emergency evacuation plan. There would be no impact.
4.9g Would the project expose people or structures, either directly or indirectly, to a significant risk of loss, injury or death involving wildland fires? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Project Site is in a fully urbanized area and is not adjacent to any wildland. Additionally, according to the California Department of Forestry and Fire Protection (CAL FIRE), the Project Site is not within a State Responsibility Area (SRA) or a very high fire hazard severity zone (VHFHSZ); see Section 4.20: Wildfire. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which is also developed with commercial and office uses and is not located within a SRA or VHSHZ. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not expose people or structures to a significant risk involving wildland fires. There would be no impact.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.10 Hydrology and Water Quality
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Violate any water quality standards or waste
discharge requirements or otherwise substantially
degrade surface or groundwater quality?
X
b) Substantially decrease groundwater supplies or
interfere substantially with groundwater recharge
such that the projects may impede sustainable
groundwater management of the basin?
X
c) Substantially alter the existing drainage pattern of the site or area, including through the alteration of
the course of a stream or river or through the
addition of impervious surfaces, in a manner which
would:
(i) Result in substantial erosion or siltation on- or
off-site. X
(ii) Substantially increase the rate or amount of
surface runoff in a manner which would result
in flooding on- or off-site;
X
(iii) Create or contribute runoff water which
would exceed the capacity of existing or
planned stormwater drainage systems or
provide substantial additional sources of
polluted runoff; or
X
iv) Impede or redirect flood flows? X
d) In flood hazard, tsunami, or seiche zones, risk
release of pollutants due to project inundation? X
e) Conflict with or obstruct implementation of a water
quality control plan or sustainable groundwater
management plan?
X
Impact Analysis
4.10a Would the project violate water quality or waste discharge requirements or otherwise substantially degrade surface or groundwater quality?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria. ■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Construction
The Project’s construction-related activities would only include demolition and would not include excavation or grading. The Project would not expose soils and thereby would not increase the potential for soils to be subject to wind and water erosion and for eroded soils and other pollutants to enter the soil drain system. Nevertheless, the Project would be required to prepare and Erosion and Sediment Control Plan (ESCP), which requires the implementation of BMPs during construction activities as best practice to reduce, prevent, minimize, and/or treat pollutants and prevent degradation of downstream receiving waters. Typical construction BMPs include, but are not limited to, gravel bags and fiber rolls. Implementation of construction BMPs would reduce or avoid contamination of stormwater with sediment and other pollutants such as trash and debris; oil, grease, fuels, and other toxic chemicals; paint, concrete asphalt, etc.; and nutrients. Similarly, the ZTA and GPA associated with the Project would only affect development within the Business Triangle. Such development projects also be required to prepare an ESCP and implement construction BMPs to minimize impacts to water quality. Therefore, water quality and waste discharge impacts from Project demolition, grading, and construction activities and the adoption of the associated ZTA and GPA for the Business Triangle would be less than significant.
Operation
Operation-related activities of the Project would generate pollutants that could adversely affect the water quality of downstream receiving waters if effective measures are not used to keep pollutants out of and remove pollutants from urban runoff. Requirements for waste discharges to stormwater from operation of developed land uses within the coastal watersheds of Los Angeles and Ventura Counties are in the Regional Phase I Municipal Separate Storm Sewer System National Pollutant Discharge Elimination System (NPDES) Permit (MS4 Permit), Order No.
R4-2021-0105, issued by the Los Angeles Regional Water Quality Control Board (LARWQCB) in 2021. As the Project would result in the alteration of less than 50 percent of the impervious surface of the existing parking garage on-site (7,030 square feet including the proposed retail uses and relocation of three ADA parking spaces versus 96,850 square feet for the entire parking garage), the Project Site would be subject to the regulations regarding low impact development (LID) practices and standards in BHMC Section 9-4-508. Particularly, the Project would be required to implement a stormwater mitigation plan that incorporates postconstruction structural or treatment control LID BMPs. The LID BMPs would be required to be designed in accordance with the City’s LID Standards Manual, which includes urban and stormwater runoff quantity and quality control development principles and technologies for achieving compliance with the provisions of BHMC Section 9-4-508. To meet the local MS4 permit and LID requirements consistent with the City’s LID regulations and standards, stormwater management strategies would be implemented throughout the Project Site.
BHMC Section 9-4-508 states that new development and redevelopment projects are required to control pollutants and runoff volume from the Project Site by minimizing the impervious surface area and controlling runoff through infiltration, bioretention, and/or rainfall harvest and use in that preferred order. Infiltration is not considered geotechnically feasible given that the Project Site contains a portion of the ground floor of an existing parking garage with two subterranean levels and three above-ground levels. The Project would therefore implement the next BMP strategy, bioretention BMPs, in the form of approximately 300 square feet of planter Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
boxes. As the Project would include a greater square footage of planter boxes than existing conditions (approximately 250 square feet), implementation of the proposed LID features would improve surface water quality runoff compared to existing conditions. The proposed stormwater mitigation plan for the Project which includes the proposed bioretention BMPs would be subject to approval by the City. Additionally, operation of the Project itself would not result in discharges that would cause regulatory standards to be violated in the Los Angeles River Watershed.
Additionally, the associated ZTA and GPA would only affect development within the Business Triangle. Such development projects would also be required to comply with relevant regulations pertaining to water quality, including the regional MS4 Permit and the City’s requirements regarding the implementation of a stormwater mitigation plan that incorporates postconstruction LID BMPs.
Therefore, water quality and waste discharge impacts from Project operation and the adoption of the associated ZTA and GPA for the Business Triangle would be less than significant.
For the reasons expounded above, impacts to water quality and waste discharge as a result of Project development, including the adoption of the associated ZTA and GPA for the Business Triangle, would be less than significant.
4.10b Would the project substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin?
No Impact. The City is located within the Coastal Plain of the Los Angeles Groundwater Basin which is divided into multiple groundwater subbasins. The City overlies three of these subbasins, specifically the Hollywood Groundwater Basin, the La Brea Subarea of the Central Groundwater Basin, and the Crestal Subarea of the Santa Monica Groundwater Basin. Most of the City overlies the Hollywood Groundwater Basin, with smaller portions overlying the other two basins.25 The Project Site lies entirely within the Hollywood Groundwater Basin.
The Project Site is developed with existing paved parking spaces within the parking garage onsite and a ten-story office building, and the Project Site is surrounded by commercial and office uses. Construction and operation of the Project would occur entirely within the ground floor of the parking garage on-site. The Project would not include any groundwater pumping and would instead rely on the local water purveyor for water (Beverly Hills Department of Public Works).
Additionally, no water supply wells are located at or within one thousand feet of the Project Site.
The Project would not include the construction of any water supply wells, nor would the Project impact any existing water supply wells. The Project Site is also not within a groundwater recharge area or facility, nor does it represent a source of groundwater recharge.
Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which also does not contain any water supply wells or is within a groundwater recharge area or facility. Additionally, similar development projects that may take advantage of the ZTA and GPA would also convert the ground floor of an existing parking structure to retail businesses 25 City of Beverly Hills, 2020 Urban Water Management Plan, 2021, page 6-7, https://www.beverlyhills.org/DocumentCenter/View/5432/2020-UWMP---Final-PDF. Accessed July 16, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
and would therefore also not involve groundwater pumping or the construction of groundwater wells.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not substantially deplete groundwater supplies nor interfere substantially with groundwater recharge such that the Project would impede the basins’ substantial groundwater management. There would be no impact.
4.10c Would the project substantially alter the existing drainage pattern of the site or area, including through the alterations of the course of stream or river or through the addition of impervious surfaces, in a manner which would:
(i) Result in substantial erosion or siltation on- or off-site? No Impact. See Threshold 4.10a, above. The Project Site consists of a portion of the ground floor of the existing parking garage and office building on-site and is entirely impervious. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses.
Construction of the Project would be entirely contained within the Project Site and adjacent sidewalk and would not encroach on other levels of the parking garage. Construction activities would involve only minimal ground-disturbing activities within the existing utility right-of-way adjacent to the Project Site for connection to utility infrastructure that would involve minimal exposure of soils and would not involve excavation or grading. Additionally, development of the Project would maintain the imperviousness of the ground floor of the parking garage. The Project would also a greater square footage of planter boxes (300 square feet) than existing conditions (250 square feet), which would improve surface water quality runoff compared to existing conditions. Therefore, development of the Project would not alter the existing drainage pattern of the Project Site and would not result in substantial erosion or siltation on- or off-site.
The proposed ZTA and GPA would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle that would also convert the ground floor of existing parking structures to retail businesses. Such other potential development projects would therefore also likely involve similar construction activities involving minimal ground disturbance and soil exposure. The sites of such projects would likely also be entirely impervious, and the development of such projects would therefore also likely maintain the imperviousness of their respective sites. As such, the adoption of the ZTA and GPA would also not result in substantial erosion or siltation on- or off-site.
For the reasons expounded above, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not result in substantial erosion or siltation on- or off-site.
There would be no impact.
(ii) Substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or off-site?
No Impact. See Threshold 4.10c.i, above. As mentioned above, the Project Site is completely impervious, and Project development would maintain the level of imperviousness of the Project Site. Additionally, the Project would also a greater square footage of planter boxes (300 square Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
feet) than existing conditions (250 square feet), which would improve surface water quality runoff compared to existing conditions.
Similarly, as also mentioned above, the associated ZTA and GPA would only affect development within the Business Triangle that would also convert the ground floor of existing parking structures to retail businesses. The sites of such projects would therefore likely also be entirely impervious, and the development of such projects would also likely maintain the imperviousness of their respective sites. As such, the adoption of the ZTA and GPA would also not result in a substantial increase in the rate or amount of surface runoff in a manner that would result in flooding on- or off-site.
Therefore, development of the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not substantially increase the rate or amount of surface runoff in a manner that would result in flooding on- or off-site. There would be no impact. (iii) Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or
No Impact. As described above in Thresholds 4.10a and 4.10c.i, there would be no impact on the capacity of storm drainage systems and stormwater pollution. (iv) Impede or redirect flood flows?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
According to the Federal Emergency Management Agency (FEMA), the Project Site is located in Zone X, which is defined as an area of minimal flood hazard. The Business Triangle that would be affected by the ZTA and GPA is also located in Zone X. However, according to the California Department of Water Resources’ (DWR) Dam Breach Inundation Map Web Publisher, the Project Site and the Business Triangle are located within the dam inundation area of the Lower Franklin Reservoir.26 The Lower Franklin Reservoir is a reservoir located approximately 1.75 miles north of the Project Site.
Lower Franklin Reservoir (No. 6-14) is classified by the DWR, Division of Safety of Dams (DSOD) as an extremely high downstream hazard. However, as of September 2023, the dam was given a Satisfactory Condition Assessment by the DWR DSOD, and no existing or potential dam safety deficiencies were recognized.27 Acceptable performance is expected under all types of loading conditions (static, hydrologic, seismic) in accordance with the minimum applicable State or 26 California Department of Water Resources (DWR), Dam Breach Inundation Map Web Publisher, https://fmds.water.ca.gov/webgis/?appid=dam_prototype_v2. Accessed July 17, 2024. 27 DWR Division of Safety of Dams, Dams Within Jurisdiction of the State of California, 2023, page 58, https://water.ca.gov/- /media/DWR-Website/Web-Pages/Programs/All-Programs/Division-of-Safety-of-Dams/Files/Publications/DAMS-WITHINJURISDICTION-OF-THE-STATE-OF-CALIFORNIA-LISTED-ALPHABETICALLY-BY-DAM-NAME-SEPTEMBER-2023.pdf. Accessed July 17, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
federal regulatory criteria or tolerable risk guidelines. FEMA requires that all dam owners develop Emergency Action Plans (EAPs) for warning, evacuation, and post-flood actions. An EAP identifies potential emergency conditions at a dam and specifies actions to be followed to help minimize loss of life and property damage should those conditions occur. EAPs include procedures dam owners will follow to issue early warning and notification messages to responsible downstream emergency management authorities. EAPs also include inundation maps to help dam owners and emergency management authorities identify critical infrastructure and population-at-risk sites that may require protective measures, warning, and evacuation planning. Thus, the potential for dam flooding at the Project Site is considered low. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not impede or redirect flood flows. Impacts would be less than significant.
4.10d In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As noted in Threshold 4.10c.iv, the Project Site and the Business Triangle are in areas of minimal flood hazard. Although the Project Site and Business Triangle are within the dam inundation area of the Lower Franklin Reservoir, as of September 2023, no existing or potential dam safety deficiencies were recognized, and acceptable performance is expected under all types of loading conditions. Thus, the potential for dam flooding at the Project Site and the Business Triangle are considered low.
Tsunamis are sea waves that are generated in response to large-magnitude earthquakes. When these waves reach shorelines, they sometimes produce coastal flooding. The Project Site and the Business Triangle are located approximately 6.6 miles inland from Pacific Ocean and is therefore not at risk of tsunami.
Seiches are large waves generated in enclosed bodies of water in response to ground shaking.
There are no enclosed bodies of water within or near the Project Site and the Business Triangle.
Therefore, there would be no impact regarding seiches.
Based on the reasons above, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not risk release of pollutants due to floods, tsunami, or seiche.
Therefore, impacts would be less than significant.
4.10e Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan?
No Impact. The Project Site is within the jurisdiction of the LARWQCB Basin Plan, which identifies beneficial uses for surface water and groundwater and establishes water quality objectives to attain those beneficial uses, together known as water quality standards. The Project would not degrade water quality in a manner that would interfere with the beneficial uses of local surface water as established by the Basin Plan. As substantiated in Threshold 4.10a, implementation of Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
construction and post-construction BMPs as required by the County and City would reduce pollutants in stormwater runoff; therefore, the Project would not violate any water quality standards and therefore would not obstruct the implementation of the LARWQCB Basin Plan.
Furthermore, as described in Threshold 4.10b, the Project Site is within the Hollywood Groundwater Basin, which is identified by the Sustainable Groundwater Management Act (SGMA) as a very low priority basin.28 The SGMA requires only medium- and high-priority basins to form groundwater sustainability agencies, develop groundwater sustainability plans, and manage groundwater for long-term sustainability. Therefore, the Hollywood Groundwater Basin does not require a sustainable groundwater management plan. Additionally, as further detailed in Threshold 4.10b, the Project would not decrease groundwater supplies or interfere substantially with groundwater recharge.
Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which is also located within the jurisdiction of and would be subject to the LARWQCB Basin Plan. The Business Triangle is also within the Hollywood Groundwater Basin, and other potential development within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would also not decrease groundwater supplies or interfere substantially with groundwater recharge.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not conflict with or obstruction implementation of a water quality control plan or sustainable groundwater management plan. There would be no impact. 28 Sustainable Groundwater Management Agency, SGMA Data Viewer, https://sgma.water.ca.gov/webgis/?appid=SGMADataViewer#boundaries. Accessed July 16, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.11 Land Use and Planning
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Physically divide an established community? X
b) Cause a significant environmental impact due to a
conflict with any land use plan, policy, or regulation
adopted for the purpose of avoiding or mitigating
an environmental effect?
X
Impact Analysis
4.11a Would the project physically divide an established community? No Impact. The Project Site consists of a portion of the ground floor of an existing parking garage and is surrounded by commercial office and retail uses. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
No new streets or other physical barriers which could physically divide an established community are proposed. Although established residential neighborhoods lie to the north and west of the Project Site across North Santa Monica Boulevard, Project development would not physically divide these neighborhoods in any way because the Project would be developed within the Project Site, and all off-site infrastructure improvements would be contained within the sidewalk adjacent to the Project Site such that they would not transect those neighborhoods. Access to the existing residential neighborhoods would not be impeded or cut off as a result of Project development.
Additionally, the associated ZTA and GPA would only affect similar development within the Business Triangle that would redevelop the ground floor of existing parking structures to retail businesses. As the ZTA and GPA would only allow for this specific type of increase in maximum allowable floor area within parcels that are already developed, other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would also not propose physical barriers that could physically divide an established community.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not physically divide an established community, and no impact would occur.
4.11b Would the project cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which ■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Project Site has a General Plan land use designation of Commercial (Low Density General).
The maximum allowable density in this land use designation is a FAR of 2.0, and the maximum allowable height is 45 feet. Additionally, the Project Site is zoned C-3 Commercial. According to BHMC Section 10-3-1601, principal uses permitted in this Zone include various commercial uses such as café, office, parking garage, store, shop for the conducting of wholesale or retail business, and store. Per BHMC Section 10-3-2745, the maximum FAR on any site area shall not exceed 2.0.
The Project proposes to convert a portion of the ground floor of the existing parking garage onsite to include new tenant spaces for retail businesses, which would be consistent with the permitted uses of the C-3 Commercial zone. The Project would increase the floor area of the Project parcel from 96,850 square feet to 103,647 square feet and increase the FAR from 2.65 to
2.84. The Applicant is requesting a ZTA and GPA to allow for additional floor area not to exceed 10 percent of the maximum allowable floor area for the Project Site. The Project would be designed in accordance with the land use and zoning development standards outlined in the City’s General Plan Land Use Element and municipal code. Upon City approval of the proposed ZTA and GPA and the City’s development review of the proposed site plans, no land use conflict related to General Plan or zoning consistency would occur. Furthermore, upon City approval of the ZTA and GPA, other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would be required to comply with the provisions of the ZTA and GPA and other applicable City development regulations.
Additionally, per BHMC Section 10-3-2730, the Project would be required to provide one parking space per 350 square feet of commercial floor area, for a total of 20 additional spaces. However, AB 2097 (2022) (Government Code Section 65863.2) prohibits public agencies or cities from imposing a minimum automobile parking requirement on most development projects located within a half-mile radius of an existing or planned major transit stop. Pursuant to AB 2097, as the Project Site is approximately 0.31-mile northwest of the future Metro D Line Wilshire/Rodeo Station, the Project is eligible for automobile parking reduction. The Project would eliminate 29 existing parking spaces and relocate 3 ADA parking spaces within the ground floor of the existing parking garage on-site. Therefore, the Project’s proposed parking would not conflict with the BHMC’s parking standards.
Overall, for the reasons substantiated above, the Project would be consistent with the land use and zoning of the Project Site. Additionally, other potential development within the Business Triangle that may take advantage of the associated ZTA and GPA, for purposes of converting existing street level parking into retail use, would be consistent with the land use and zoning of the Business Triangle. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not conflict with any land use plan, policies, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Impacts would be less than significant.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.12 Mineral Resources
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Result in the loss of availability of a known mineral resource that would be of value to the region and the
residents of the state?
X
b) Result in the loss of availability of a locally-important mineral resource recovery site delineated on a local
general plan, specific plan, or other land use plan?
X
Impact Analysis
4.12a Would the project result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state?
4.12b Would the project result in the loss of availability of a locally-important mineral resource recovery site delineated on a local general plan, specific plan, or other land use plan? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
According to the City’s General Plan Conservation Element, the Project Site is located within Mineral Resource Zones (MRZ) 1 and 3.29 MRZ 1 is defined by the California Geological Survey as areas of no mineral resource significance, and MRZ 3 is defined as areas that have undetermined mineral resource significance.30 Additionally, the Project Site is in the vicinity of the Beverly Hills and San Vicente oil fields.31 However, the Project Site is in an urbanized area of the City, and the Project Site is entirely developed with paved parking spaces within an existing parking garage, which preclude the accommodation of mining or drilling activities within or in the vicinity of the Project Site. Furthermore, the Project does not propose any mining or drilling activities.
Additionally, there are no active mining or drilling activities within or near the Project Site.32,33 No known resource appears to be present within or near the Project Site that would be valuable to the region or State residents and that would be lost due to the Project.
Additionally, the associated ZTA and GPA would only affect development within the Business Triangle, which is also within MRZ 1 and MRZ 3 and is developed with commercial and office uses that preclude the accommodation of mining or drilling activities within or in the vicinity of the 29 City of Beverly Hills, General Plan Conservation Element, 2010, page 137, https://beverlyhills.org/DocumentCenter/View/5512/07-Conservation-PDF. Accessed July 12, 2024. 30 California Geologic Survey, Guidelines for Classification and Designation of Mineral Lands, page 3, https://www.conservation.ca.gov/smgb/Guidelines/Documents/ClassDesig.pdf. Accessed July 26, 2024. 31 City of Beverly Hills, General Plan Conservation Element, page 139. 32 DOC, Well Finder, https://maps.conservation.ca.gov/doggr/wellfinder/. Accessed July 12, 2024. 33 DOC, Mines Online, 2016, https://maps.conservation.ca.gov/mol/index.html. Accessed July 12, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Business Triangle. As with the proposed development for the Project, no known resource also appears to be present within or near the Business Triangle that would be valuable to the region or State residents and that would be lost due to other potential development within the Business Triangle.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not result in the loss of availability of a known mineral resource or a locally important mineral resource recovery site. No impacts would occur.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.13 Noise
This Section is based on the Noise and Vibration Analysis Memorandum prepared by KimleyHorn, which is included in its entirety in Appendix F: Noise and Vibration Analysis.
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Generate a substantial temporary or permanent
increase in ambient noise levels in the vicinity of
the project in excess of standards established in the
local general plan or noise ordinance, or applicable
standards of other agencies?
X
b) Generate excessive groundborne vibration or
groundborne noise levels? X
c) For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a
plan has not been adopted, within two miles of a
public airport or public use airport, would the
project expose people residing or working in the
project area to excessive noise levels?
X
Existing Conditions
Existing Noise Levels
Mobile noise sources, especially cars, trucks motorcycles, and aircrafts, are the City’s most common and substantial noise sources. The existing mobile noise sources in the Project area are the motor vehicles traveling on Santa Monica Boulevard, Bram Goldsmith Way, North Roxbury Drive, and SR-2. The primary stationary noise sources in the Project vicinity are those associated with the surrounding residential uses. Such stationary noise sources include mechanical equipment (e.g., HVAC equipment), moving vehicles, music playing, dogs barking, and people talking. The noise associated with these sources may represent a single-event noise occurrence or short-term noise.
Existing Ambient Noise Levels
To quantify existing ambient noise levels in the Project area, Kimley-Horn conducted one longterm noise measurement on July 9, 2024; see Appendix F. The noise measurement site (see Figure 4.13-1: Noise Measurement Location) was representative of typical existing noise exposure within and immediately adjacent to the Project Site. The 24-hour measurement was taken between 8:04 A.M. on July 9, 2024 to 8:04 A.M. the following day. Measurements of the equivalent sound level (Leq) are considered representative of the noise levels throughout the day and are summarized in Table 4.13-1: Existing Noise Measurement, below. ■■■■
Kimley»)Horn
SOURCE: Google Earth, 2024
FIGURE 4: Noise Measurement Location
450 NORTH ROXBURY DRIVE PROJECT
1000 ft
Willshire Blvd
Bedford Dr
S Santa Monica Blvd
N Roxbury Dr
Project Site
Noise Meaurement Location
State Route 2
Brighton Way
Bram Goldsmith Way
FIGURE 4.13-1: Noise Measurement Location FIGURE 4.13-1: Noise Measurement Location .3
- $.7 4 X <y
K0 $
p/ 0 . G
0- Cos Larrev’e < 1
4 06 . * t
• Ye". e. 52 > 1 a 200 e $* ?. 1
X y .2”
6. 4
0 - 4 e
7 A e". ye
s 4
V 7. a.3
>
% 2. ?. s% 0% salt. )• — , . * o2 ;
As, . •
3 V % ’ 2
s5 ..
/ K<
$
2 9 v
ce. nfy. 2.
-
r
700 %
$ ; P£
t. B e l. As \ • g
3 8
J« , t > d
6 *, >1
t
?
4 13, T
1 st , .2 [I mA i] — (“A
2 iilII
»wOCB T om— —
tel ... 2, IlIIII .1 I
him jf 1 ' 177
anyp d-uh i
Y S ■' B tal
a, mas ' "lbwos ; g .
Iu C m T
- e aa
nr ff1 MAV । i .99 awnsm
S.9933888 83 s m I
: n 5 ' 3
s? 5P... □ 9, BET uj I
ns I
*
*1
C) , ! 1 E I
KimleyHorn
Wre
2 X.
dPsl
a
13 1118
Des
fl l
. “A
“e
S0Y
ie ■.
, 35.
32 HA
ELEW. 7
wSy
1 W ___
"5■ y
X
20%
1 2 - 2
■■
—
Eal
‘ 4 s ..
94 Y
S
ACR
Pl «7 th
IE-)) A.es
o
0 •.
s
9 Ss
X
d‘]
‘s
0 (•)
.N
10919199.5 1
si WG
s*e
".0) ,23; 3. 5o
(
l
i 1 | e"s
AeAr •X..P
*'4
”3
"Ay
edri
si
1 —> l “We, 3
. ” ,3
I
Aooc
:3
—
7 NAP) 07
-d ■ IK
I ■ 4—5 1 5
<A Y
ya-
■ X)
X D-v
I ® s
s
-
7 m
_ 51 = 2 A
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Table 4.13-1: Existing Noise Measurement
Site Location Day
(dBA Leq)
Night
(dBA Leq) Time
1 Along North Roxbury Drive, at
the Project Site 64.1 59.7
July 9, 2024 8:04 A.M.
–
July 10, 2024 8:04
A.M.
Source: Noise measurement taken by Kimley-Horn, July 9, 2024. See Appendix F for noise measurement results.
Noise Sensitive Receptors
Noise exposure standards and guidelines for various types of land uses reflect varying noise sensitivities associated with uses. Land uses considered sensitive receptors include residences, schools, playgrounds, childcare centers, long-term health facilities, rehabilitation centers, convalescent centers, and retirement homes. The nearest sensitive receptors to the Project Site consist mostly of a church and residential communities located approximately 350 northwest of the Project Site.
Impact Analysis
4.13a Would the project result in generation a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Construction Noise
Construction noise typically occurs intermittently and varies depending on the nature or phase of construction. Noise generated by construction equipment can reach high levels. During construction, exterior noise levels could affect the noise-sensitive receptors near the construction site.
The proposed construction activities would require tractors, concrete saws, and dozers during demolition; cranes, forklifts, and tractors during building construction; and air compressors during architectural coatings. Typical operating cycles for these types of construction equipment may involve 1 or 2 minutes of full power operation followed by 3 to 4 minutes at lower power settings. Other primary sources of acoustical disturbance would be random incidents, which would last less than one minute (such as dropping large pieces of equipment or the hydraulic movement of machinery lifts). Noise generated by construction equipment, including dozers, excavators, loaders, forklifts, and air compressors, can reach high levels. Lmax is the maximum level of a noise source environment and is often used as a threshold value for typical noise levels of construction activities. Typical noise levels associated with individual construction equipment are listed in Table 4.13-2: Typical Construction Noise Levels.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Table 4.13-2: Typical Construction Noise Levels
Equipment Typical Noise Level (dBA Lmax) at 50 feet from Source Air Compressor 80
Backhoe 80
Compactor 82
Concrete Mixer 85
Concrete Pump 82
Concrete Vibrator 76
Crane, Mobile 83
Dozer 85
Generator 82
Grader 85
Jack Hammer 88
Loader 80
Paver 85
Pneumatic Tool 85
Pump 77
Roller 85
Saw 76
Shovel 82
Truck 84
1. Calculated using the inverse square law formula for sound attenuation: dBA2 = dBA1+20Log(d1/d2) Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, September 2018.
Daytime construction noise is not typically a concern for human health and is a common occurrence within the urban environment. The impact analysis is based on the potential temporary increase in ambient noise and the construction time limits in the BHMC Section 5-1- 205 including the allowable hours of hours of construction. Construction activity would occur within the allowable hours of construction including Mondays through Fridays 8:00 A.M. to 6:00 P.M. Construction is prohibited outside of these hours and on holidays.
The FHWA Roadway Construction Noise Model (RCNM) was used to calculate the worst-case construction noise levels at nearby sensitive receptors surrounding the Project Site during construction. All construction equipment was assumed to operate simultaneously and at the center of the Project Site to represent a worst-case noise scenario, as construction activities would routinely be spread throughout the construction site and would operate at different intervals. The modeled receptor locations represent the closest existing receiving land uses to Project construction activities. Noise levels at other sensitive receptors surrounding the Project Site would be located further away and would experience lower construction noise levels than the closest receptors modeled. Table 4.13-3: Project Construction Noise Levels shows estimated exterior daytime noise levels for each construction phase at the closest receptors without accounting for attenuation from intervening barriers, structures, or topography.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Although the noise generated by Project construction would be higher than ambient noise levels, which may result in a temporary increase in ambient noise levels, construction would be temporary and cease once Project construction is completed. Construction activities would comply with BHMC Section 5-1-205 and would be prohibited outside the hours of Mondays through Fridays 8:00 A.M. to 6:00 P.M, and on Saturdays only if an after hours construction permit is issued pursuant to BHMC 5-1-205.C. While construction may cause short-term annoyance to adjacent uses, it would be temporary and restricted to the hours permitted by the City’s noise ordinance. In addition, BHMC Section 5-1-205 states that construction work is prohibited any time on Saturdays within a residential zone or within five hundred feet of a residential zone unless issued an after hours construction permit. Therefore, construction noise impacts would be less than significant.
Construction Traffic Noise
In addition to on-site construction noise, the Project would generate mobile-source noise from delivery/haul trucks and construction workers traveling to and from the Project Site during the project’s construction. In general, a 3‐dBA increase in traffic noise is barely perceptible to people, while a 5‐dBA increase is readily noticeable. Traffic volumes on Project area roadways would have to approximately double for the resulting traffic noise levels to generate a barely perceptible 3‐ dBA increase.
Haul trucks would travel to and from the Project Site using North Roxbury Drive. Haul and delivery trucks and construction workers are expected to arrive at the Project Site before construction starts and leave when construction ends, and thus, would not overlap with the noise generated by the Project’s construction equipment. It is reasonable to assume that workers would already have arrived at the Project Site to begin demolition activities prior to the arrival of haul trucks.
The greatest contributor to on-road traffic noise during construction would be haul trucks arriving from SR-2 to the Project Site along North Roxbury Drive. Therefore, this analysis only considers noise generated by haul trucks. According to modeling assumptions included in the air quality assessment prepared by Kimley-Horn in September 2024, the construction phase with the highest assumed number of haul trucks would be demolition, when it is assumed there would be up to 1 daily haul truck trip accessing the Project Site. Assuming that 1 haul truck would pass through the roadway segment along North Roxbury Drive within a 15-minute period, the estimated noise level from the demolition phase haul truck trips would be 48.5 dBA Leq at 50 feet Table 4.13-3: Project Construction Noise Levels
Construction Phase Land Use
Receptor Location
Direction
Distance
(feet)1
Exterior Noise
Level
(dBA Leq)
Demolition Residential/ Church Northwest 410 68.2
Building Construction Residential/ Church Northwest 410 67.7 Architectural Coating Residential/ Church Northwest 410 55.4
1. Per the methodology described in the FTA Transit Noise and Vibration Impact Assessment Manual (September 2018), distances are measured from the nearby buildings to the center of the Project construction site.
Source: Federal Highway Administration, Roadway Construction Noise Model, 2006. Refer to Appendix F for noise modeling results.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
from the roadway centerline. The estimated worst-case noise level would not result in increases of 5 dBA Leq over ambient conditions or increases above the barely perceivable (3-dBA) criteria.
In addition, 1 daily haul truck trip would not double existing traffic volumes along North Roxbury Drive and thus would not increase noise levels compared to existing conditions. Therefore, noise impacts from construction traffic would be less than significant.
Operational Noise
Project implementation would introduce new noise sources in the Project vicinity. The Project’s primary noise sources that could potentially impact nearby noise-sensitive land uses include mechanical equipment (e.g., HVAC, etc.) and trash/recycling truck pickup noise.
Mechanical Equipment
Potential stationary noise sources related to long-term Project operations include mechanical equipment (e.g., HVAC equipment). Mechanical equipment typically generates noise levels of approximately 52 A-weighted decibels (dBA) at 50 feet. Noise has a decay rate due to distance attenuation, which is calculated based on the Inverse Square Law of sound propagation. Based upon the Inverse Square Law, sound levels decrease by 6 dBA for each doubling of distance from the noise source. Typically, a 5 dBA change in noise levels is required before any noticeable change in community response would be expected. HVAC equipment would be installed on the roof the Project Site south of an existing HVAC unit. The nearest sensitive receptors would be located 250 feet northwest from the HVAC equipment. As indicated in Table 4.13-4: On-Site Composite Noise Levels, noise levels from mechanical equipment at the Project Site would be
38.0 dBA Leq at the nearest residential uses to the northwest and would not result in increases of 5 dBA Leq over ambient conditions. Furthermore, HVAC equipment operations currently occur under existing conditions and would not be a new noise source. Therefore, the Project would result in a less than significant impact concerning mechanical equipment noise levels.
Trash/Recycling Truck Pickups
During loading and unloading activities of trash and recycling pickups, noise would be generated by the trucks’ diesel engines, exhaust systems, and brakes during low gear shifting’ braking activities, as well as the opening and closing of the trash/recycling bins. Trash/recycling truck pickup noise is typically 41.4 dBA Leq at 50 feet. The trash room is located on the ground level. It is conservatively assumed that trash/recycling would occur along North Roxbury Drive, approximately 250 feet southeast of the nearest sensitive receptor (when measured from the trash room location rather than the parking lot boundary). Trash/recycling truck pickup noise would attenuate to approximately 27.4 dBA at the nearest noise receptors. As indicated in Table
4.13-4, noise levels from trash/recycling truck pickup at the Project Site would not result in increases of 5 dBA Leq over ambient conditions at the nearest affected sensitive receptors. In addition, trash/recycling truck pickup activity servicing the Project area currently occurs under existing conditions and would not be a new noise source. The hours of trash/recycling pick up activity would be dependent on the service provider and not be regulated by the Project.
Therefore, the Project would result in less than significant impacts concerning trash/recycling truck pickup noise levels.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Composite On-Site Noise Levels
An evaluation of the combined noise levels from the Project’s various operational noise sources (i.e., composite noise level) was conducted to conservatively ascertain the potential maximum Project-related noise level increase that may occur at the nearest noise-sensitive receptors. In general, an increase of 3 dBA is considered to be barely perceptible, and a 5 dBA change in noise levels is required before any noticeable change in community response would be expected. Table
4.13-4 details the on-site noise levels from the Project Site at the nearest residential uses located approximately 250 feet away from mechanical and trash/recycling activities. As shown in Table
4.13-4, the composite on-site operational noise attributable to the Project would not increase ambient conditions at the residential uses. Composite noise levels would not exceed the Federal Transit Administration’s (FTA’s) (3 dBA) annoyance criteria or the City’s (65 dBA Community Noise Equivalent Level [CNEL]) standard for exterior noise. Therefore, the Project would not result in a significant permanent increase in ambient noise levels.
Table 4.13-4: On-Site Composite Noise Levels
Receptor
Maximum On-Site
Noise Levels by Source
(dBA Leq)
Combined
Noise
Level at
Receptor
(dBA Leq)
Ambient
Noise
Level
(dBA
Leq)
1 Ambient
+
Combined
Project
Noise
(dBA Leq)
Incremental
Increase
over
Ambient
(dBA Leq)
Mechanical
Equipment
Trash/
Recycling
Residential Community 38.0 27.4 38.4 64.1 64.1 0.0
1. See Table 4.13-1 for measured ambient noise level.
Mobile Traffic Noise
The Project is anticipated to generate 370 net daily trips. In general, a 3‐dBA increase in traffic noise is barely perceptible to people, while a 5‐dBA increase is readily noticeable. Traffic volumes on Project area roadways would have to approximately double for the resulting traffic noise levels to generate a barely perceptible 3‐dBA increase. Roxbury Drive (the primary access roadway to the Project Site) has an average daily traffic (ADT) volume of approximately 6,286 vehicles. The Project would result in approximately 370 net daily trips, which would not double the existing traffic volumes on North Roxbury Drive. Therefore, the Project would not result in increases of 5 dBA Leq over ambient conditions or increases above the barely perceivable (3-dBA) criteria. Noise impacts from Project-related traffic noise would be less than significant.
Proposed ZTA and GPA Noise Impacts
Regarding the associated ZTA and GPA for the Project, given that the nature of other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use and should they meet the criteria, would be similar in nature and scale to the proposed development for this Project in that they would also involve the conversion of the ground floor of an existing parking structure to retail businesses, the construction and operational noise generated by the other potential development projects would be similar in nature and scale to that for this Project. As with the Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Project, these other potential development projects would also be required to comply with regional and City regulations pertaining to noise, and mitigate impacts to a less than significant level, where applicable. As such, noise impacts from adoption of the associated ZTA and GPA would be less than significant.
For the reasons substantiated above, Project noise impacts would be less than significant.
4.13b Generate excessive groundborne vibration or groundborne noise levels? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Increases in groundborne vibration levels attributable to the Project would be primarily associated with short-term construction-related activities. Project construction could result in varying degrees of temporary groundborne vibration, depending on the specific construction equipment used and the operations involved.
The types of construction vibration impacts include human annoyance and building damage.
Human annoyance occurs when construction vibration rises significantly above the threshold of human perception for extended periods of time. Building damage can be cosmetic or structural.
The City has not adopted specific standards for vibration impacts during construction. Therefore, the Caltrans Transportation and Construction Vibration Guidance Manual (2020) is used to evaluate construction vibration impacts related to potential building damage. As the closest structure is a commercial building, this evaluation uses the Caltrans architectural damage criterion for continuous vibrations at commercial buildings of 0.5 inches per second (in/sec) peak particle velocity (PPV) and the severe human annoyance criterion of 0.4 in/sec PPV.
Table 4.13-5: Typical Construction Equipment Vibration Levels identifies vibration velocity levels at 25 feet and at the nearest receptor for the type of equipment likely to operate at the Project Site during construction. As the Project would redevelop an attached parking garage into a commercial space, grading, excavation, and paving would not occur. Furthermore, construction activities would occur as close as one foot from an adjacent building. Due to existing site restrictions, a large bulldozer would not be utilized during construction.
Table 4.13-5: Typical Construction Equipment Vibration Levels Equipment
Peak Particle Velocity
at 25 feet (in/sec)
Peak Particle Velocity
at 1 foot (in/sec)1
Small Bulldozer/Tractors 0.003 0.375
Structure Damage Threshold 0.5 0.5
Exceeds Threshold? No No
1. Calculated using the following formula: PPVequip = PPVref x (25/D)1.5, where: PPVequip = the peak particle velocity in in/sec of the equipment adjusted for the distance; PPVref = the reference vibration level in in/sec from Table 7-4 of the Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, 2018; D = the distance from the equipment to the receiver.
Source: Federal Transit Administration, Transit Noise and Vibration Impact Assessment Manual, 2018.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
As shown in Table 4.13-5, the vibration velocities from construction would not exceed the Caltrans’s architectural damage criterion (0.5 in/sec PPV) or human annoyance criterion (0.4 in/sec PPV) at 1 foot from the Project Site. Construction activities would occur throughout the Project Site and would not be concentrated at the point closest to the nearest building/structure.
Therefore, the frequency of vibration events would be intermittent and temporary. The vibration impact from the construction equipment would be less than significant.
The Project would develop four retail spaces. Upon operation, there would be no sources of vibration on the Project Site. Therefore, vibration impacts during operation would be less than significant.
Proposed ZTA and GPA Vibration Impacts
Regarding the associated ZTA and GPA for the Project, given that the nature of other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would be similar in nature and scale to the proposed development for this Project in that they would also involve the conversion of the ground floor of an existing parking structure to retail businesses, construction and operational vibration generated by the other potential development projects would be similar in nature and scale to that for this Project. As with the Project, these other potential development projects would also be required to comply with regional and City regulations pertaining to vibration, and mitigate impacts to a less than significant level, where applicable. As such, vibration impacts from adoption of the associated ZTA and GPA would be less than significant.
For the reasons expounded above, the Project would not generate excessive groundborne vibration or groundborne noise levels. Impacts would be less than significant.
4.13c Would the project be located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project expose people residing or working in the project area to excessive noise levels?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. Refer to Threshold 4.9e. The Project is not within two miles of the nearest airport and would not be impacted by airport noise. The nearest airport is the Santa Monica Airport located approximately 3.9 miles southwest of the Project Site in the City of Santa Monica.
Additionally, there are no private airstrips located within the Project vicinity. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which is also not located within or near the boundaries of an airport land use plan or an airport. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not expose people residing or working in the Project area to excessive airport- or airstriprelated noise levels. No impact would occur.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.14 Population and Housing
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Induce substantial unplanned population growth in
an area, either directly (for example, by proposing
new homes and businesses) or indirectly (for
example, through extension of roads or other
infrastructure)?
X
b) Displace substantial numbers of existing people or
housing, necessitating the construction of
replacement housing elsewhere?
X
Impact Analysis
4.14a Would the project induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure)?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Project construction would temporarily increase the number of persons present at the Project Site. However, these construction workers would only be present at the Project Site during Project construction. Once operational, the proposed retail uses would include full-time and/or part-time positions, which are anticipated to be hired from the local population and generally would not require households to relocate for such employment opportunities. As such, the Project would be unlikely to create new households in the area or generate an indirect demand for additional housing. Therefore, potential growth impacts would not be substantial.
Additionally, the Project Site is in an urbanized area of the City with an established network of roads and other urban infrastructure; therefore, the Project would not require the extension of such infrastructure in a manner that would indirectly induce substantial population growth.
Additionally, the associated ZTA and GPA would only allow an increase in FAR for other potential development within the Business Triangle that would also convert the ground floor of existing parking structures to retail businesses. Similar to the proposed development for the Project, such other potential developments would require construction workers that would also be present during construction activities, and would include full-time and/or part-time positions that would also likely be hired from the local population during operation. As such, the associated ZTA and GPA would also be unlikely to create new households in the area or generate an indirect demand for additional housing. Additionally, the Business Triangle is developed and is also served by the established network of roads and other urban infrastructure within the area. Therefore, these Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
other potential developments would also not require the extension of such infrastructure in such a manner that would indirectly induce substantial population growth.
Therefore, for the reasons expounded above, impacts as a result of the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would be less than significant.
4.14b Would the project displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
There is no housing on the Project Site. Additionally, the associated ZTA and GPA would only affect development within the Business Triangle, which is developed with commercial and office uses and also does not contain housing. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not displace existing people or housing, or require construction of replacement housing elsewhere. No impact would occur, and no mitigation measures would be required.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.15 Public Services
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physical altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
a) Fire protection? X
b) Police protection? X
c) Schools? X
d) Parks? X
e) Other public facilities? X
Impact Analysis
4.15a Fire Protection?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The BHFD provides fire, rescue, and emergency services to the City. The closest fire station to the Project Site is BHFD Station 1 located approximately 0.45-mile northwest of the Project Site at 445 North Rexford Drive. The Project would not modify the two existing driveways on North Roxbury Drive that currently provide access to the parking garage that the Project Site is within, but would slightly modify internal circulation patterns by replacing a number of parking spaces on the ground floor of the parking garage with retail uses and relocating three ADA parking spaces.
Project construction may require temporary closure of the ground level of the parking garage where the retail spaces would be developed, as well as the adjacent sidewalk along North Roxbury Drive for utility relocation. However, Project construction would not require the closure of any public streets during construction, and temporary construction activities would not impede the use of streets for emergencies or access for emergency vehicles. Once operational, the Project would include a range of full-time and/or part-time positions for the proposed retail uses. Because the Project would not include housing or other uses that would induce substantial population growth in the area, the Project would not increase demand on fire protection providers such that new facilities are required. The Project would be designed according to applicable fire code standards and would provide adequate circulation and access to facilitate emergency response during Project operation in accordance with BHFD standards.
Additionally, the associated ZTA and GPA would only affect similar development within the Business Triangle that would also convert the ground floor of existing parking structures abutting ■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
public streets to retail businesses. As such, similar to the proposed development for the Project, these other potential development projects within the Business Triangle would also likely not require the closure of any public streets during construction activities or impede the use of streets for emergencies or access for emergency vehicles. The Project would temporarily increase the number of persons present at the sites that would only be present during construction. Once operational, these other potential development projects would also include full-time and/or part-time positions for potential retail uses and therefore not induce substantial population growth in the area and increase demand on fire protection providers such that new facilities are required. These other potential development projects would also be designed according to applicable fire code standards.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would result in a less than significant impact concerning fire protection services.
4.15b Police Protection?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Beverly Hills Police Department (BHPD) provides police protection services to the City. The BHPD is approximately 0.5-mile northeast of the Project Site at 464 North Rexford Drive. As discussed in Threshold 4.15a, the Project construction may require the temporary closure of the entire parking garage and the adjacent sidewalk along North Roxbury Drive. However, Project construction would not encroach on adjacent roadways and would not impact street access and traffic flow and therefore would not impede the use of streets for police services or access for such services.
During operations, both driveways of the parking garage that the Project Site is within would continue to be secured by existing parking barriers that require visitors to press a button for a ticket to enter the parking garage. The Project would also include security measures such as security lighting and a surveillance camera system. The Project would temporarily increase the number of persons present at the Project Site that would only be present during construction activities, and a range of full-time and/or part-time employees during operation. Because the Project would not include housing or other uses that would induce substantial population growth in the area, the Project would not increase demand on police protection providers such that new facilities are required. The City’s Public Works Department has verified that the Project would not be required to pay development impact fees to reduce potential impacts to public services, pursuant to BHMC Section 3-1-904.
Additionally, the associated ZTA and GPA would only affect similar development within the Business Triangle that would also convert the ground floor of existing parking structures abutting public streets to retail businesses. As such, similar to the proposed development for the Project, these other potential development projects within the Business Triangle would also likely not require the closure of any public streets during construction activities or impede the use of streets for police services or access to such services. The Project would temporarily increase the Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
number of persons present at the sites that would only be present during construction. Once operational, these other potential development projects would also include full-time and/or part-time positions for potential retail uses and therefore not induce substantial population growth in the area and increase demand on police protection providers such that new facilities are required. These other potential development projects would also likely include security measures. As such, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would result in a less than significant impact concerning police protection services.
4.15c Schools?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project would not include any residential uses. As mentioned, the Project would not induce population growth and thus would not increase the demand for school services. Additionally, as also mentioned, other potential development within the Business Triangle that may take advantage of the associated ZTA and GPA, for purposes of converting existing street level parking into retail use, would also not induce population growth and thus would also not increase the demand for school services. The Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not require new or physically altered school facilities and therefore would not result in adverse physical impacts in this regard. No impact concerning school facilities would occur.
4.15d Parks?
No Impact. See Section 4.16, Recreation, below.
4.15e Other public facilities?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Other public facilities such as libraries and community centers are typically provided to serve residents within the City. Given the Project has no residential component, Project implementation would not increase demand for other public facilities such as libraries and community centers. Similarly, given that other potential development within the Business Triangle that may take advantage of the associated ZTA and GPA, for purposes of converting existing street level parking into retail use, would also not include residential components, implementation of the ZTA and GPA would also not increase the demand for other public facilities such as libraries and community centers. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not require new or physically altered public facilities such as libraries and community centers and therefore would not result in adverse physical impacts in this regard. No impact concerning public facilities would occur.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.16 Recreation
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Increase the use of existing neighborhood and
regional parks or other recreational facilities such
that substantial physical deterioration of the facility would occur or be accelerated?
X
b) Does the project include recreational facilities or
require the construction or expansion of recreational
facilities which might have an adverse physical effect
on the environment?
X
Impact Analysis
4.16a Would the project increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated?
4.16b Does the project include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. The recreational facility nearest the Project Site is Beverly Hills Park located approximately 350 feet northeast of the Project Site. Because the Project would not include housing or other uses that would induce substantial population growth in the area, the Project is not anticipated to increase the demand for existing recreational facilities or generate a demand for new ones. Further, Project implementation is not anticipated to increase the use of existing recreational facilities such that substantial physical deterioration of a facility would occur or be accelerated. Similarly, regarding the associated ZTA and GPA, because other potential development within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would also not include housing or other uses that would induce substantial population growth, these other potential developments are also not anticipated to increase the demand for existing recreational facilities or generate a demand for new ones, or increase the use of existing recreational facilities such that substantial physical deterioration of a facility would occur or be accelerated. The Project does not propose or require new or physically altered recreational facilities and therefore would not result in adverse physical impacts in this regard. No impacts would occur.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.17 Transportation
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Conflict with a program plan, ordinance, or policy
addressing the circulation system, including transit,
roadway, bicycles, and pedestrian facilities?
X
b) Conflict or be inconsistent with CEQA Guidelines
Section 15064.3, subdivision (b)? X
c) Substantially increase hazards due to a geometric
design feature (e.g., sharp curves or dangerous
intersections) or incompatible uses (for example,
farm equipment)?
X
d) Result in inadequate emergency access? X
Impact Analysis
4.17a Would the project conflict with a program plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. Regional access to the Project Site is provided via SR-2 located approximately 175 feet northwest of the Project Site. Local access to the Project Site is provided via North Roxbury Drive and Bram Goldsmith Way (an alley) to the southwest and northeast of the Project Site, respectively.
Pedestrian access is provided via the existing sidewalk along North Roxbury Drive. A Class 3 bicycle route is located along North Roxbury Drive, which is defined by the City’s Complete Streets Plan as a designated preferred route for bicyclists on streets shared with motor vehicles.
Public transit access in proximity to the Project Site includes the Wilshire/Linden bus stop, which is located approximately 400 feet southwest of the Project Site and serves Metro Line 20; the Santa Monica/Camden bus stop, which is located approximately 600 feet northeast of the Project Site and serves Metro Line 4; and the Wilshire/Santa Monica bus stop, which is located approximately 740 feet southwest of the Project Site and serves Metro Lines 20 and 720. The Project Site is also approximately 0.31-mile northwest of the future Wilshire/Rodeo Station, which is a subway station currently under construction as part of Metro’s D Line Extension project and is slated to open in 2026.
Construction activities for the Project may require temporary closure of the sidewalk fronting the Project Site along North Roxbury Drive for utility relocation and delivery of materials. However, such closures would be temporary. During temporary sidewalk closure, construction fencing would be erected around the Project Site and pedestrian access would be directed around the Project Site. These measures would be established in coordination with the City and would conform to City standards. The Project would not preclude enhancements to sidewalks or other policies, programs, or projects identified in the City’s General Plan Circulation Element or the ■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
City’s Complete Streets Plan. The temporary sidewalk closure would also not hinder transit, roadway, or bicycle facilities or other plans, ordinances, or policies addressing the circulation system. Similarly, the associated ZTA and GPA would only affect similar development within the Business Triangle. These other potential development projects would therefore also likely require only temporary closures of sidewalks, which would also be coordinated with the City and conform to City standards.
Therefore, impacts as a result of development of the Project, including the adoption of the associated ZTA and GPA, would be less than significant.
4.17b Would the project conflict or be inconsistent with CEQA Guidelines Section 15064.3, subdivision (b)?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
CEQA Guidelines Section 15064.3 codifies the change from level of service to VMT as a metric for transportation impact analysis. Pursuant to SB 743, VMT analysis is the primary method for determining CEQA impacts. According to CEQA Guidelines Section 15064.3(a), VMT refers to the amount and distance of automobile travel attributable to a project. The City’s adopted CEQA Transportation Thresholds of Significance may be applied to screen projects from VMT analysis requirements if they will not have an impact under CEQA Guidelines Section 15064.3. Based on the OPR Technical Advisory, the City adopted three screening criteria that the City may use to identify whether a proposed project is expected to cause a less-than-significant impact without conducting a detailed study:
• Project type screening: Presumed less than significant impact for local serving retail projects (defined as less than 50,000 square feet per OPR’s Technical Advisory) and projects that generate less than 110 average daily trips. • Low VMT area screening: Presumed less than significant VMT impact for residential projects located in low VMT generating traffic analysis zones (TAZs). These TAZs generate total daily VMT per capita that is 15 percent less than the baseline level for the region. • Transit Priority Area (TPA) screening: Presumed less than significant VMT impact for projects located in the commercial zones of TPAs (defined as within ½ mile of a Metro Rapid bus stop) and does not have the following characteristics:
o FAR < 0.75
o More parking than required by City, unless additional parking is being provided for design feasibility, such as completing the floor of a subterranean of structured parking facility, or if additional parking is located within the project site to serve adjacent uses
o Inconsistent with the applicable SCAG RTP/SCS (as determined by the City) Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
The Project Site is in a TPA designated by SCAG, as the Project Site is located within 0.5-mile of the future Metro Line D Wilshire/Rodeo Station. Additionally, the Project would increase the FAR from 2.65 to 2.84. Upon Project development, the Project Site (inclusive of both the parking garage and office building and new retail spaces) would have a FAR greater than the TPA screening FAR threshold of 0.75. Additionally, as expounded in Threshold 4.8b, above, the Project is consistent with the 2020-2045 SCAG RTP/SCS. Therefore, the Project Site would satisfy the criterion for TPA screening and is presumed to have a less than significant VMT impact.
Similarly, given that the entire Business Triangle is also within 0.5-mile of major transit stops, and that other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would be similar in nature and scale to the proposed development for the Project, these projects would also likely be screened from VMT analysis. Nevertheless, these projects would be required to conduct their own VMT screening analysis and comply with VMT measures, as applicable. As such, VMT impacts from these projects would also be less than significant.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not result in any significant effects relating to traffic pursuant to CEQA Guidelines Section 15064.3, and a detailed VMT analysis is not required. Impacts would be less than significant.
4.17c Would the project substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment)?
No Impact. The Project Site is currently developed with a five-level parking garage consisting of two subterranean levels and three above-grade levels (including rooftop parking) and a ten-story office building. Vehicular access is currently provided via two in/out driveways along North Roxbury Drive. The Project proposes to eliminate 29 existing parking spaces and relocate three ADA parking spaces on the ground level of the parking garage to accommodate proposed retail spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Construction and operation of the Project would occur within the area currently occupied by the existing parking spaces to be removed or relocated. The Project would not encroach on the existing driveways or the existing internal drive aisle on the ground level and would maintain the existing general circulation and fire access lanes. The Project would be designed to comply with the City’s current design requirements. Similarly, regarding the associated ZTA and GPA, other potential development within the Business Triangle that may also take advantage of the ZTA and GPA would also be required to be designed in accordance with the City’s current design requirements. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not have the potential to increase hazards due to geometric design, and there would be no impact.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.17d Would the project result in inadequate emergency access? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses. As expounded in Threshold 4.9f, the Project Site is located in an established urban area that is well-served by an existing roadway network. Santa Monica Boulevard, located approximately 90 feet southeast of the Project Site, is designated as a disaster route. This disaster route would not be subject to any lane closures as a result of the Project, as construction activities would be contained entirely within the Project Site boundaries. Furthermore, the Project would be designed according to applicable fire code standards. The Project would not encroach on the existing internal circulation and access routes of the rest of the parking garage not within the Project Site and would not interfere with emergency response. Project design and access would be reviewed by BHFD to ensure that emergency access would be maintained. Additionally, as also expounded in Threshold 4.9f, the associated ZTA and GPA would only affect development within the Business Triangle. Such other development projects would be similar in nature and scale to the Project and would therefore also unlikely require lane closures of disaster routes. Such development projects would also be required to be designed in accordance with applicable fire code standards to ensure that emergency access would be maintained. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not result in inadequate emergency access. There would be no impact.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.18 Tribal Cultural Resources
This Section is based on AB 52 and SB 18 Communications initiated by the City; see Appendix G:
Assembly Bill 52 and Senate Bill 18 Communications.
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Cause a substantial adverse change in the
significance of a tribal cultural resource, defined in
Public Resources Code Section 21074 as either a
site, feature, place, cultural landscape that is
geographically defined in terms of the size and
scope of the landscape, sacred place, or object with
cultural value to a California Native American tribe,
and that is
i) Listed or eligible for listing in the California Register of Historical Resources, or in a local register of
historical resources as defined in Public Resources
Code Section 5020.1(k); or
X
ii) A resource determined by the lead agency, in its
discretion and supported by substantial evidence,
to be significant pursuant to criteria set forth in
subdivision (c) of Public Resources Code Section
5024.1. In applying the criteria set forth in
subdivision (c) of Public Resource Code Section
5024.1, the lead agency shall consider the
significance of the resource to a California Native
American tribe.
X
Impact Analysis
4.18ai Would the project cause a substantial adverse change in the significance of a tribal cultural resource, listed or eligible for listing in the California Register of Historical Resources, or in a local register of historical resources as defined in Public Resources Code Section 5020.1(k); or
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As concluded in Threshold 4.5a, the Project Site is developed with an existing parking garage that is attached to a commercial office building within the same parcel. According to the Historical Resources Assessment prepared for the Project, the parking garage and office building are not individually eligible for listing in the National Register, California Register, or Beverly Hills ■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Register. However, given that a Beverly Hills Architectural Commission Report prepared by City staff in 2019 cited the subject property is a potential contributor to an eligible postwar commercial historic district, ARG is conservatively treating the district as a historical resource under CEQA. ARG found that the Project would not have a significant impact on historical resources, nor would the Project impact the subject property’s potential eligibility as a district contributor.
Additionally, as also mentioned in Threshold 4.5a, the associated ZTA and GPA would only affect development within the Business Triangle. Other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, would be subject to the same CEQA requirements as the Project, and potential impacts to historic resources would be evaluated as part of those projects’ environmental analysis. As such, the adoption of the ZTA and GPA would have a less than significant impact on historical resources.
Therefore, for the reasons expounded above, impacts as a result of Project development, including the adoption of the associated ZTA and GPA for the Business Triangle, would be less than significant.
4.18aii Would the project cause a substantial adverse change in the significance of a tribal cultural resource- a resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe? Less Than Significant Impact. As stated in Threshold 4.5b, a SLF search conducted with the NAHC resulted in positive findings within the vicinity of the Project area, and the NAHC recommended further consultation with the Gabrieleño/Tongva San Gabriel Band of Mission Indians in accordance with AB 52. A list was provided by NAHC of Native American tribes who may have knowledge of cultural resources in the area. On July 10, 2024, the City mailed notification pursuant to AB 52 and SB 18 to the following tribes:
• Soboba Band of Luiseno Indians
• Santa Rosa Band of Cahuilla Indians
• Gabrielino-Tongva Tribe
• Gabrielino/Tongva Nation
• Gabrielino Tongva Indians of California Tribal Council • Gabrieleno/Tongva San Gabriel Band of Mission Indians • Gabrieleno Band of Mission Indians – Kizh Nation
• Cahuilla Band of Indians
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
As described in Threshold 4.5b, the City received a response from the Gabrieleño Band of Mission Indians - Kizh Nation Tribe on July 13, 2024, indicating they had an interest in the Project at the time. A tribal consultation call was scheduled between the City and the Gabrieleño Band of Mission Indians - Kizh Nation Tribe on August 16, 2024. During the call after learning that the Project would involve no ground disturbance, the Gabrieleño Band of Mission Indians - Kizh Nation Tribe expressed no concerns with the Project. The Gabrieleño Band of Mission Indians - Kizh Nation Tribe requested that the City reach out to the Tribe for further assessment should there be a change to the Project. AB 52 and SB 18 consultation with the Gabrieleño Band of Mission Indians - Kizh Nation Tribe was concluded afterwards. The City also received a response from the Gabrielino Tongva Indians of California Tribal Council on July 24, 2024, indicating interest in the Project at the time. However, after City staff confirmed via email that the Project would involve no ground disturbance, the Gabrielino Tongva Indians of California Tribal Council expressed no concerns with the Project via email on July 24, 2024, and AB 52 and SB 18 tribal consultation efforts with the Gabrielino Tongva Indians of California Tribal Council concluded afterwards. To date, no other responses from the Native American community have been received as part of the AB 52 and SB 18 tribal consultation effort.
As discussed in the in Threshold 4.5b above, since no archaeological resources were identified within the Project Site as a result of the records search and associated research, it is unlikely that undisturbed archaeological resources are present within the Project Site given the extent of prior development. Additionally, the Project would involve only minimal ground-disturbing activities within the existing utility right-of-way adjacent to the Project Site for connection to utility infrastructure, and would not involve excavation or grading. As such, there is little potential for archaeological resources that meet the definition of “Historical Resources” or “Unique Archaeological Resources”, as defined by CEQA, to be identified within the Project area as a result of the Archaeological Resources Assessment. Regarding the associated ZTA and GPA, the ZTA and GPA would only affect development within the Business Triangle, which also has been heavily disturbed and is entirely developed with commercial and office uses.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.19 Utilities and Service Systems
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Would the project:
a) Require or result in the relocation or construction
of new or expanded facilities concerning the following, the construction or relocation of which could cause
significant environmental effects?
i. Water,
ii. Wastewater,
iii. Wastewater Treatment,
iv. Stormwater Drainage,
v. Electric Power, Natural Gas, and
Telecommunications.
X
b) Have sufficient water supplies available to serve
the project and reasonably foreseeable future
development during normal, dry and multiple dry
years?
X
c) Result in a determination by the wastewater
treatment provider which serves or may serve the
project that it has adequate capacity to serve the
project projected demand in addition to the
provider’s existing commitments?
X
d) Generate solid waste in excess of State or local
standards, or in excess of the capacity of local
infrastructure, or otherwise impair the attainment
of solid waste reduction goals?
X
e) Comply with federal, state, and local management
and reduction statutes and regulations related to
solid waste?
X
Impact Analysis
4.19a Require or result in the relocation or construction of new or expanded facilities concerning the following, the construction or relocation of which could cause significant environmental effects?
i. Water?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
■■■■
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
The Beverly Hills Department of Public Works owns and maintains the water infrastructure within the City. The nearest fire hydrants are located approximately 80 feet northwest and 349 feet southeast of the Project Site, both of which are publicly owned by the City.
During construction, water will be required intermittently for dust control and equipment. Since water usage during construction is typically less demanding than the water usage for the proposed Project, it is anticipated that existing water infrastructure would meet the limited, temporary water demand associated with construction of the Project, and that the water purveyor is able to provide water during construction.
The Project would require construction of new lateral connections to existing water lines.
Construction impacts associated with the installation of water services would primarily involve trenching in order to place the lines sufficiently below the ground surface. When considering impacts resulting from the installation of any required water infrastructure, all impacts are of a relatively short-term duration (i.e., weeks to months) and would cease to occur once the installation is complete. Installation of new or relocation of existing water infrastructure will be limited to on-site water distribution, and minor off-site work associated with connections to the public main. No upgrades to public water mains, other than on-site infrastructure, are anticipated. Prior to ground disturbance, Project contractors would coordinate with the City to identify the locations and depth of all lines.
As the Project Site currently consists of a portion of the ground floor of an existing parking garage, it was conservatively assumed that the Project Site currently does not use any water. Upon Project development, the Project would develop approximately 6,797 square feet of retail spaces and relocate three ADA parking spaces. The Project’s proposed water demand was estimated using 120 percent of the Los Angeles County Sanitation District’s (LACSD) sewage generation factor of 100 gallons per day (gpd) per 1000 square feet for stores to account for any additional water demand for possible minor losses on-site, such as waste use due to human consumption (drinking, watering indoor plants, evaporation).34 As such, the Project’s proposed water demand is approximately 816 gpd.
To accommodate potential Project impacts to surrounding water infrastructure, the Project would construct new connections to the existing waterlines in the Project Site vicinity. The Project would also be required to pay a water supply fee pursuant to BHMC Sections 6-1-270 through 6-1-276 to mitigate potential impacts to the City’s water infrastructure.
Additionally, similar to the Project, the associated ZTA and GPA would only affect other development projects within the Business Triangle that would be similar in nature and scale to the Project, which is also served by existing water infrastructure owned by the City. As these other potential development projects would also involve the conversion of the ground level of existing parking structures to retail businesses, the sites for these projects would also likely not have existing water use. Due to the increase of the proposed water use from the potential retail uses, these other potential development projects would also be required to pay a water supply 34 Los Angeles County Sanitation District, Table 1: Loadings for Each Class of Land Use, https://www.lacsd.org/home/showpublisheddocument/3644/637644575489800000. Accessed June 28, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
fee pursuant to BHMC Sections 6-1-270 through 6-1-276 to mitigate potential impacts to the City’s water infrastructure.
For the reasons listed above, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not require in the relocation or construction of new or expanded water facilities. Impacts would be less than significant. ii. Wastewater?
iii. Wastewater Treatment?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The Beverly Hills Department of Public Works maintains the wastewater collection and distribution system throughout the City. All wastewater generated by the City is collected and treated at Los Angeles Hyperion Water Reclamation Plant located in the City of Los Angeles. The Hyperion Water Reclamation Plant, owned and operated by Los Angeles City Sanitation (LASAN), has a design capacity of 450 million gallons per day (mgd) and an average flow of 272 mgd.35 Construction activities for the Project could result in temporary wastewater generation on-site.
However, such generation would be temporary when compared with the wastewater generated by the proposed Project. In addition, construction workers would typically utilize portable restrooms and hand wash areas, which would not contribute to direct wastewater flows to the City’s wastewater system. Thus, wastewater generation from Project construction activities is not anticipated to cause any measurable increase in wastewater flows.
Construction impacts associated with wastewater infrastructure would primarily be confined to trenching for miscellaneous utility lines and connections to public infrastructure. Installation of wastewater infrastructure will be limited to on-site wastewater distribution and minor off-site work associated with lateral connections to the existing City sewer main. Any work that may affect services to the existing sewer lines or impacts to LASAN facilities or plant will be coordinated with the City’s Public Works Department. Furthermore, construction management and access plans would ensure safe pedestrian access as well as emergency vehicle access and safe vehicle travel. Moreover, when considering impacts resulting from the installation of any required wastewater infrastructure, all impacts are of a relatively short-term duration and would cease to occur once the installation is complete.
As the Project Site currently consists of a portion of the ground floor of an existing parking garage, it was assumed that the Project Site currently does not generate wastewater. Upon Project development, the Project would develop approximately 6,797 square feet of retail spaces and 35 Los Angeles City Sanitation, Hyperion Water Reclamation Plant Hyperion 2035 Program, https://www.ladwp.com/sites/default/files/documents/LASAN_Hyperion_2035_Program_Fact_Sheet.pdf. Accessed June 28, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
relocate three ADA parking spaces. The Project’s proposed wastewater generation was estimated using LACSD’s sewage generation factor of 100 gpd per 1000 square feet for stores. As such, the Project’s proposed wastewater generation is approximately 680 gpd. Therefore, the Project would contribute an estimated additional 680 gpd to the City’s wastewater system. To mitigate the Project’s potential impacts to the City’s wastewater system, the Project would be required to apply for a permit to connect to the City’s wastewater system, pursuant to BHMC Section 6-1- 309 of the BHMC; the permit would be subject to City approval. Furthermore, the estimated wastewater generation during Project operations would comprise less than 0.000003 percent of the wastewater that is treated on an average daily basis by the Hyperion Water Reclamation Plant.
Additionally, similar to the Project, the associated ZTA and GPA would only affect other development projects within the Business Triangle that would be similar in nature and scale to the Project, which is also served by existing wastewater infrastructure owned by the City. As these other potential development projects would also involve the conversion of the ground level of existing parking structures to retail businesses, the sites for these projects would also likely not have existing wastewater generation. Due to the increase of the proposed wastewater use from the potential retail uses, these other potential development projects would also be required to pay a apply for a permit to connect to the City’s wastewater system pursuant to BHMC Section 6-1-309 to mitigate potential impacts to the City’s wastewater infrastructure. Given the nature of these other potential development projects, the estimated wastewater generation of these projects is not anticipated to be substantial such that it would require the relocation or construction of new or expanded wastewater treatment facilities including the Hyperion Water Reclamation Plant.
For the reasons substantiated above, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not require or result in the relocation or construction of new or expanded wastewater and wastewater treatment facilities. Impacts would be less than significant.
iv. Stormwater Drainage?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Refer to Threshold 4.10c concerning drainage patterns and stormwater drainage systems. As discussed in Threshold 4.10c, the Project would not change the drainage of the Project Site, and the Project would install a greater square footage of planter boxes compared to existing conditions (300 square feet versus 250 square feet) which would improve the quality of the stormwater runoff.
Similarly, as also mentioned in Threshold 4.10c, the associated ZTA and GPA would only affect development within the Business Triangle that would also convert the ground floor of existing parking structures to retail businesses. The sites of such projects would therefore likely also be Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
entirely impervious, and the development of such projects would also likely maintain the imperviousness or change the drainage of their respective sites.
The Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would therefore not require or result in the relocation or construction of new or expanded offsite stormwater facilities, the construction or relocation of which could cause significant environmental effects. Therefore, impacts would be less than significant. v. Electric Power, Natural Gas, and Telecommunications? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The City’s electrical power is provided by SCE, and natural gas is provided by SoCalGas. The City’s telecommunications are provided by various companies. SCE, SoCalGas, and local telecommunications companies operate and maintain transmission and distribution infrastructure throughout the City. Refer to Thresholds 4.6a and 4.6b for further discussions concerning electricity. The Project would not include any natural gas usage; therefore, the Project would not result in an impact on natural gas. The Project would include on-site connections to existing telecommunication services. The Project would not require or result in the relocation or construction of new or expanded off-site electric power, natural gas, or telecommunications facilities, the construction or relocation of which could cause significant environmental effects.
Additionally, the associated ZTA and GPA would only affect development within the Business Triangle, which is also served by SCE, SoCalGas, and local telecommunication companies. Given that the ZTA and GPA would only apply to other potential development projects similar to the Project that would also involve the conversion of the ground level of parking structures to retail uses, it is anticipated that such potential projects would have similar impacts on energy and would also not require or result in the relocation or construction of new or expanded off-site electric power, natural gas, or telecommunications facilities.
Therefore, Project impacts would be less than significant.
4.19b Would the project have sufficient water supplies available to serve the Project and reasonably foreseeable future development during normal, dry and multiple dry years? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
The City receives approximately 92 percent of its water supply from the Metropolitan Water District (MWD). The remainder of the City’s water supply is pumped from the local Hollywood Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
Groundwater Basin, and with the construction of a new well by 2022, the La Brea Subarea of the Central Groundwater Basin.
The City of Beverly Hills 2020 Urban Water Management Plan (UWMP) provides a framework for long-term water planning for the City’s water service area, which is approximately 6.35 square miles. The plan states that due to water conservation measures, water use has decreased in the service area since 2010, even with increases in population. Tables 4.19-1 through 4.19-3 show the expected supply and demand during each hydrologic year type with a 20-year projection from 2025 to 2045. The MWD provided the model output of the reliability forecast for the City which was used in the City’s UWMP. The normal year was defined as the average of hydrologies for the years 1922 to 2017, as shown in Table 4.19-1: Normal Year Supply and Demand Comparison. A single dry year was considered as being equivalent to the supply and demand for the single driest year hydrology of 1977 for the MWD, as shown in Table 4.19-2: Single Dry Year Supply and Demand Comparison. A five consecutive year drought was based on a repeat of the hydrology of the years 1988 to 1992, which represents the driest five-year historical sequence in the MWD’s water supply, as shown on Table 4.19-3: Multiple Dry Years Supply and Demand Comparison. 36 36 City of Beverly Hills, 2020 Urban Water Management Plan, pages 7-4 and 7-5.
Table 4.19-1: Normal Year Supply and Demand Comparison
Normal Year 2025 (AFY) 2030 (AFY) 2035 (AFY) 2040 (AFY) 2045 (AFY) Supply Totals 11,933 12,131 12,340 12,582 12,768
Demand Totals 11,933 12,131 12,340 12,582 12,768
Difference 0 0 0 0 0
AFY = acre-foot per year
Source: City of Beverly Hills, 2020 Urban Water Management Plan, 2021.
Table 4.19-2: Single Dry Year Supply and Demand Comparison Single Dry Year 2025 (AFY) 2030 (AFY) 2035 (AFY) 2040 (AFY) 2045 (AFY) Supply Totals 11,933 12,131 12,340 12,582 12,768
Demand Totals 11,933 12,131 12,340 12,582 12,768
Difference 0 0 0 0 0
AFY = acre-foot per year
Source: City of Beverly Hills, 2020 Urban Water Management Plan, 2021.
Table 4.19-3: Multiple Dry Years Supply and Demand Comparison Multiple Dry Years 2025 (AFY) 2030 (AFY) 2035 (AFY) 2040 (AFY) 2045 (AFY) First Year
Supply Totals 12,064 12,264 12,476 12,720 12,908
Demand Totals 12,064 12,264 12,476 12,720 12,908
Difference 0 0 0 0 0
Second Year
Supply Totals 12,219 12,422 12,636 12,884 13,074
Demand Totals 12,219 12,422 12,636 12,884 13,074
Difference 0 0 0 0 0
Third Year Supply Totals 12,255 12,459 12,673 12,922 13,113 Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
As shown in Tables 4.19-1 through 4.19-3, the City’s water demands during normal year, single dry-year, and multiple dry year supply scenarios are projected to be met through 2045.
Additionally, the associated ZTA and GPA would only affect development within the Business Triangle, which is also entirely included within the City. As such, other potential development projects within the Business Triangle that may take advantage of the ZTA and GPA, for purposes of converting existing street level parking into retail use, are also accounted for in the City’s UWMP. Therefore, the City would have sufficient water supplies available to serve the Project.
Impacts would be less than significant.
4.19c Would the project result in a determination by the wastewater treatment provider which serves or may serve the project that it has adequate capacity to serve the project projected demand in addition to the provider’s existing commitments? Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As demonstrated in Thresholds 4.19a.ii and 4.19a.iii, there is existing treatment capacity in the region for estimated Project wastewater generation. Project development, including the adoption of the associated ZTA and GPA, would not impact the Hyperion Water Reclamation Plant’s treatment capacity. The Project, including the adoption of the associated ZTA and GPA, would not require or result in the relocation or construction of new or expanded off-site sewer facilities, the construction or relocation of which could cause significant environmental effects.
Therefore, Project impacts would be less than significant.
4.19d Would the project generate solid waste in excess of State or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals?
4.19e Would the project comply with federal, state, and local management and reduction statutes and regulations related to solid waste?
Less Than Significant Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project Demand Totals 12,255 12,459 12,673 12,922 13,113
Difference 0 0 0 0 0
Fourth Year
Supply Totals 11,826 12,022 12,229 12,469 12,653
Demand Totals 11,826 12,022 12,229 12,469 12,653
Difference 0 0 0 0 0
Fifth Year
Supply Totals 11,969 12,167 12,377 12,620 12,806
Demand Totals 11,969 12,167 12,377 12,620 12,806
Difference 0 0 0 0 0
AFY = acre-foot per year
Source: City of Beverly Hills, 2020 Urban Water Management Plan, 2021.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
Solid waste in the City is collected by the City of Beverly Hills Department of Public Works, which contracts with Athens Services. Solid waste from the City is disposed at various landfills throughout Los Angeles County at Class III landfills.
Project construction would result in generation of construction and demolition (C&D) debris such as metal scrap and concrete which would be collected and diverted to a C&D debris facility for materials to be recycled and/or discarded. As shown in Table 4.19-4: Estimated Solid Waste Generation, C&D of the Project is estimated to generate approximately 459 tons of C&D debris.
This estimation is a conservative estimate as it assumes that no reductions in waste generation would occur due to recycling.
Residual wastes such as trash packing materials, and plastics could require disposal at landfill.
Disposal and recycling of the construction debris would be required to comply with all federal, State, and local regulations. All construction activities would be subject to conformance with relevant federal, State, and local requirements related to solid waste disposal. The Project would be required to comply with the California Integrated Waste Management Act of 1989 (AB 939), which requires that at least 50 percent of waste produced is recycled, reduced, or composted and is included in BHMC Section 9-1-1001, which would achieve compliance with State law.
As detailed in Table 4.19-4, Project operations would generate approximately 0.017 tons per day (tpd). The estimated amount of solid waste is conservative because the waste generation factors do not account for recycling or other diversion measures. The annual amount of solid waste generated by the Project would represent a minor amount of the estimated 137 million tons of Table 4.19-4: Estimated Solid Waste Generation
Land Use Size Waste Generation Rate Waste Generated
(tons)
Waste Generated
(lbs)
Demolition1
Parking
2 9.650 ksf 46 tons/ksf 443.90 tons 887,800 lbs
Construction3
Commercial 6.797 ksf 4,020 lb/ksf 13.67 tons 27,324 lbs Parking 0.703 ksf 4,020 lb/ksf 1.41 tons 2,826 lbs
Total Demolition and Construction Waste 459 tons 917,950 lbs Operations3
Commercial 6.797 ksf 5 lb/ksf/day 0.017 tons/day 33.99 lbs/day Total Operational Waste 0.017 tons/day 33.99 lbs/day
ksf = thousand square feet; lbs = pounds; tpd = tons per day
1. The demolition waste generation rate of 46 tons/ksf is based on the CalEEMod User Guide Appendix A, page 13.
2. Parking includes building components (i.e., concrete and metal façade, existing planters, flooring, etc.) associated with removal of parking spaces within the Project Site.
3. The construction waste generation rate of 4,020 lb/ksf is based on the U.S.EPA, Characterization of Building-Related Construction and Demolition Debris in the United States, Table A-2, June 1998.
4. Generation factors provided by the CalRecycle website, refer to Estimated Solid Waste Generation Rates, https://www2.calrecycle.ca.gov/WasteCharacterization/General/Rates. Accessed June 28, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
remaining disposal capacity at the County’s Class III landfills.37 As such, the solid waste generated by the Project would be accommodated by the landfills that serve the Project Site.
During operation, the Project would be required to comply with CalRecycle’s waste diversion rate target of 50 percent of the waste stream. The Project would also be subject to AB 1826, which requires businesses to provide separate recycling bins for organic waste. Therefore, the Project would be subject to compliance with the CALGreen Code, State regulations, and City regulations regarding solid waste management and reduction. Similarly, development within the Business Triangle that may take advantage of the associated ZTA and GPA, for purposes of converting existing street level parking into retail use, would also be subject to the same State and City regulations regarding solid waste management and reduction. As such, impacts would be less than significant.
37 Los Angeles County Department of Public Works, Countywide Integrated Waste Management Plan: 2021 Annual Report, December 2022, https://dpw.lacounty.gov/epd/swims/ShowDoc.aspx?id=17450&hp=yes&type=PDF. Accessed June 27, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.20 Wildfire
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project:
a) Substantially impair an adopted emergency
response plan or emergency evacuation plan? X
b) Due to slope, prevailing winds, and other factors,
exacerbate wildfire risks, and thereby expose
project occupants to, pollutant concentrations from
a wildfire or the uncontrolled spread of a wildfire?
X
c) Require the installation or maintenance of
associated infrastructure (such as roads, fuel breaks,
emergency water sources, power lines or other
utilities) that may exacerbate fire risk or that may
result in temporary or ongoing impacts to the
environment?
X
d) Expose people or structures to significant risks,
including downslope or downstream flooding or
landslides, as a result of runoff, post-fire slope
instability, or drainage changes?
X
Impact Analysis
4.20a If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project substantially impair an adopted emergency response plan or emergency evacuation plan?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
According to CAL FIRE, the Project Site is not within an SRA. The nearest SRA is located approximately 9.4 miles west of the Project Site in the Santa Monica Mountains. Additionally, the Project Site is not within an VHFHSZ. However, the nearest VHFHSZ is a Local Responsibility Area (LRA) located approximately 0.9-mile northwest of the Project Site. 38 As detailed in Threshold 4.9f, the Project Site is in an established urban area that is well-served by an existing roadway network. According to the Los Angeles County Department of Public Works, Santa Monica Boulevard, located approximately 90 feet southeast of the Project Site, is designated as a disaster route.39 This disaster route would not be subject to any lane closures as 38 California Department of Fire and Forestry Protection, Fire Hazard Severity Zone Viewer, 2024, https://experience.arcgis.com/experience/03beab8511814e79a0e4eabf0d3e7247/. Accessed June 12, 2024. 39 Los Angeles County Department of Public Works, City of Beverly Hills, 2009, https://dpw.lacounty.gov/dsg/DisasterRoutes/map/beverly%20hills.pdf. Accessed June 12, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
a result of the Project, as construction activities would be contained entirely within the Project Site boundaries and adjacent sidewalk. Therefore, the Project would not be expected to substantially interfere with or impair emergency response or evacuation plans, including the City’s or County’s Emergency Operations Plans.40,41 Furthermore, the Project would be designed according to applicable fire code standards. The Project would not involve any changes to the existing internal circulation and access routes for the existing parking garage that the Project Site is a part of in such a way that the Project Site would continue to provide adequate circulation and access to facilitate emergency response. Project design and access would be reviewed by BHFD to ensure that emergency access would be maintained within the parking garage that the Project Site is a part of.
Additionally, as also detailed in Threshold 4.9f, the associated ZTA and GPA would only affect development within the Business Triangle, which is also not located within an SRA or VHFHSZ.
Such other development projects would be similar in nature and scale to the Project and would therefore also unlikely require lane closures of disaster routes or substantially interfere with or impair emergency response or evacuation plans. Such development projects would also be required to be designed in accordance with applicable fire code standards.
Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not conflict with the City’s adopted emergency response plan or emergency evacuation plan, and there would be no impact.
4.20b If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project, due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to, pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire? No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As mentioned above in Threshold 4.20a, the Project Site is not within or near a SRA. Additionally, the Project Site is not within a VHFHSZ but is located approximately 0.9-mile northwest of a LRA designated as a VHFHSZ. The Project Site is relatively flat and entirely developed within the ground floor of an existing parking garage, which precludes factors such as slopes or strong winds from exacerbating fire risk. Similarly, the entire Business Triangle that would be affected by the associated ZTA and GPA is also relatively flat and entirely developed, which also precludes these factors. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not expose occupants to pollutant concentrations from a wildfire or the uncontrolled spread of a wildfire, and there would be no impact.
4.20c If located in or near state responsibility areas or lands classified as very high fire hazard 40 Los Angeles County, Operational Area Emergency Operations Plan, 2023, https://ceo.lacounty.gov/wpcontent/uploads/2023/11/County-of-Los-Angeles-OAEOP-2023-Final-for-Website.pdf. Accessed June 12, 2024. 41 City of Beverly Hills, 2013 Emergency Operations Plan (EOP), 2023, https://www.beverlyhills.org/183/Emergency-OperationsPlan. Accessed June 12, 2024.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
severity zones, would the project require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As mentioned above in Threshold 4.20a, the Project Site is not within or near a SRA. Additionally, the Project Site is not within a VHFHSZ but is located approximately 0.9-mile northwest of a LRA designated as a VHFHSZ. The entire City is served by existing public utilities. The Project proposes to convert a portion of the ground floor of an existing parking garage to retail spaces, which would require the installation of new private water, wastewater, electrical, and HVAC infrastructure on-site. New and improved infrastructure within the Project Site would connect to existing public utilities and would not require the installation or maintenance of infrastructure that may exacerbate fire risk. Similarly, given that other potential developments within the Business Triangle that may take advantage of the associated ZTA and GPA, for purposes of converting existing street level parking into retail use, would be similar in nature and scale to the proposed development for the Project, such projects would also likely connect to existing public utilities that serve the City and would also not require the installation or maintenance of infrastructure that may exacerbate fire risk. Therefore, impacts would be less than significant.
4.20d If located in or near state responsibility areas or lands classified as very high fire hazard severity zones, would the project expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes?
No Impact. The Project would convert a portion of the ground floor of the existing parking garage on-site to retail uses and relocate three ADA parking spaces. The Project also proposes a ZTA and GPA which would be applicable to the Project Site for the proposed Project and to other potential sites within the Business Triangle that meet the ZTA and GPA criteria.
As mentioned above in Threshold 4.20a, the Project Site is not within or near a SRA. Additionally, the Project Site is not within a VHFHSZ but is located approximately 0.9-mile northwest of a LRA designated as a VHFHSZ. The Project Site is relatively flat and developed within the ground floor of an existing parking garage. Post-fire impacts such as drainage changes and landslides would not occur as the Project Site and its surroundings are highly urbanized and mostly flat and not have any steep slopes or hillsides that would be susceptible to landslides or flooding. Similarly, the associated ZTA and GPA would only affect development within the Business Triangle, which is also relatively flat and not susceptible to landslides or flooding. Therefore, the Project, including the adoption of the associated ZTA and GPA for the Business Triangle, would not expose people or structure to significant risks including downslope or downstream flooding or landslides, and there would be no impact.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
4.21 Mandatory Findings of Significance
Environmental Issue
Potentially
Significant
Impact
Less Than
Significant With
Mitigation
Incorporated
Less Than
Significant
Impact
No
Impact
Does the Project:
a) Have the potential to substantially 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, substantially 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?
X
b) Have impacts that are individually limited, but
cumulatively considerable? ("Cumulatively
considerable" means that the incremental effects of
a project are considerable when viewed in
connection with the effects of the past projects, the
effects of other current projects, and the effects of
probable future projects.)
X
c) Have environmental effects which will cause
substantial adverse effects on human beings, either
directly or indirectly?
X
Impact Analysis
4.21a Does the project have the potential to substantially 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, substantially 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?
Less Than Significant Impact. As discussed throughout this IS/ND, the Project does not have the potential to degrade the environment’s quality or result in significant environmental impacts that cannot be reduced to less than significant following compliance with the established regulatory framework (i.e., federal, State, and local regulations) and the conditions of approval for the Project.
As concluded in Section 4.4: Biological Resources, the Project would not 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, or reduce the number or restrict the range of a rare or endangered plant or animal.
As concluded in Section 4.5: Cultural Resources, the Project would not eliminate important examples of the major periods of California history. The Project would not impact the parking Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
garage’s potential eligibility as a contributor to an eligible postwar historic district identified by City staff in 2019. Due to extensive disturbance within the Project Site, the potential to encounter in-situ archaeological resources and human remains is low. Following compliance with the City’s conditions of approval addressing protocol for inadvertent discovery of archaeological resources, potential impacts to archaeological resources would be less than significant.
As concluded in Section 4.18: Tribal Cultural Resources, the Project could cause an adverse change in the significance of a tribal cultural resource.
4.21b Does the project have impacts that are individually limited, but cumulatively considerable? ("Cumulatively considerable" means that the incremental effects of a project are considerable when viewed in connection with the effects of the past projects, the effects of other current projects, and the effects of probable future projects.) Less Than Significant Impact. CEQA requires that the analysis of potential project impacts include cumulative impacts. CEQA defines cumulative impacts as “two or more individual effects which, when considered together are considerable or which compound or increase other environmental impacts.” This analysis of cumulative impacts need not be as in-depth as the analysis of the Project’s impacts, but instead is to “be guided by the standards of practicality and reasonableness.”
As listed in Table 4.21-1, Related Projects, the City identified 20 projects within an approximately
0.5-mile radius of the Project Site. As shown therein, the nearest related projects are Related Project No. 2, a cosmetic spa project located at 425 North Bedford Drive approximately 260 feet east of the Project Site; Related Project No. 1, a cosmetic spa project located at 414 North Bedford Drive approximately 390 feet east of the Project Site; and Related Project No. 7, an automobile dealership project located at 9737 Wilshire Boulevard approximately 442 feet southwest of the Project Site.
Table 4.21-1: Related Projects
No. Address Project Description
1 414 N. Bedford Drive Request to establish a ground floor for cosmetic spa 2 425 N. Bedford Drive Request to establish a ground floor cosmetic spa 3 414 N. Beverly Drive Request to construct a new three-story commercial building with rooftop outdoor; continue operating 22 square feet of open air dining on private property and 165 square feet on the public right-of-way.
4 499 N. Canon Drive Request to allow rooftop dining
5 370 N. Rodeo Drive Request to construct a three-story commercial building 6 9600 Wilshire Boulevard Request for a new Specific Plan to allow a new 6-story office building; a new 7-story office building; two new 6-story multifamily residential buildings with a combined total of up to 70 units; rehabilitation of the historic Saks Fifth Avenue building for use as a private social club with 40 hospitality suites and spa uses; and various public right-of-way improvements. 7 9737 Wilshire Boulevard Request to establish an automobile dealership 8 9800 Wilshire Boulevard &
121 Spalding Drive
A review of Spring Place’s operations, pursuant to Condition 16 of Resolution No. 2027.
Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
9 265 N. Beverly Drive Request to establish open air dining on public property 10 475 N. Beverly Drive Request to establish open air dining on public property 11 414 N. Camden Drive Request to establish an overnight stay facility in an existing medical suite
12 140 S. Camden Drive1 Preliminary Application to construct a 15-story, 26-unit multifamily residential building. 13 145 S. Rodeo Drive Request to construct a 15-story, 30-unit mixed use building. 14 9850, 9876, 9900, 9988
Wilshire Boulevard
(One Beverly Hills)
To Demolish 3,521 SF of service station and 166,834 SF of Beverly Hilton floor area:
340 Condominium units (net increase of 340 units)
619 Hotel rooms (net decrease of 120 rooms)
Public Park (4.5 acres); Aman Hotel- 225,597 SF and 79 hotel rooms (included in 619 total); Promenade and Park Pavilion - 109,852 SF; Conference Center - 31,536 SF; Hilton
Enhancement - 83,370 SF and 18 hotel rooms (included in 619 total); Hilton Hotel - 350,789 SF and 352 hotel rooms (included in 619 total); Waldorf Astoria - 207,026 SF and 170 hotel rooms (included in 619 total)
15 140 S. Lasky Drive Four-story hotel with 66 rooms, 1,845 SF restaurant (898 SF indoor, and 947 SF outdoor), rooftop uses (roof deck and pool deck), and three levels of subterranean parking with 94 parking spaces.
16 125-129 S. Linden Drive 19-story mixed use development with 165 residential units and a 73-room hotel
17 317 N. Beverly Drive To construct three-story, 14,343 SF commercial/office building with 13 on-site parking spaces (12 within alternative parking facility, one accessible); 28 parking spaces provided through participation in City's in-lieu parking program
18 250 N. Crescent Drive To construct eight-unit MFR building with 14 parking spaces 19 313-323 N. Rodeo Drive To construct new 30,000 SF commercial building with rooftop uses and one level of subterranean parking (alternative parking facility)
20 9900-9908 S. Santa Monica
Blvd.
To construct mixed-use multi-family and commercial:
12,560 SF of commercial, 17 condo units
1. Proposed per Government Code Section 65589.5.
Source: City of Beverly Hills, August 2024.
Aesthetics – All of the related projects are at a distance such that they would not share the same viewshed and would not have a potential to combine with the Project to create a cumulative aesthetics impact. As provided in Section 4.1, Aesthetics, no scenic vistas are available from the Project Site, and the Project would not result in any cumulative impacts related to scenic vistas.
There are no State-designated scenic highways within the City, and the Project would not result in any cumulative impacts related to scenic highways. As with the Project, the related projects would be reviewed on a case-by-case basis by the City to comply with BHMC requirements regarding building heights, setbacks, massing, and lighting for those projects that require discretionary actions, to undergo site-specific review regarding building density and design, glare, Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
and light. Lastly, the Project would result in less-than-significant aesthetics impacts and thus would not contribute considerably to cumulative aesthetics impacts. For all these reasons, cumulative aesthetics impacts would be less than significant.
Agriculture and Forestry Resources – As expounded in Section 4.2, Agriculture and Forestry Resources, of this IS/ND, the Project Site is entirely developed and consists of a portion of the ground floor of an existing parking garage. No agricultural or forestry uses exist within or in the vicinity of the Project Site. Therefore, the Project would not convert agricultural or forestry uses to other uses. Additionally, the Project Site and adjacent properties are not designated or zoned for agricultural or forestry use, nor are the Project Site and adjacent parcels subject to Williamson Act contracts. Furthermore, none of the related projects converting agricultural or forestry uses to other uses. Therefore, the Project would not contribute considerably to cumulative agriculture and forestry resources impacts, and cumulative agriculture and forestry resources impacts would be less than significant.
Air Quality – According to SCAQMD, a project’s potential contribution to cumulative impacts should be assessed utilizing the same significance criteria as those for project-specific impacts (i.e., if an individual project exceeds the SCAQMD’s recommended daily thresholds for projectspecific impacts, then the project would also result in a cumulatively considerable net increase).
As indicated in Section 4.3, Air Quality, of this IS/ND, the Project’s construction- and operationsrelated air quality impacts would be less than significant. Therefore, the Project would not contribute considerably to cumulative air quality impacts, and cumulative air quality impacts would be less than significant.
Biological Resources – As provided in Section 4.4, Biological Resources, of this IS/ND, there is no native habitat within or near the Project Site to support sensitive plant or animal community or special status species. The Project Site is either out of range for such species or would not provide suitable habitat due to its highly disturbed nature and the fact that the Project Site is in a highly urbanized area of the City. The Project Site does not serve as habitat for fish or wildlife species.
The Project would not remove protected trees, and the Project would not conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other such plan. Additionally, related projects would be required to comply with the City’s tree ordinance provided in BHMC Sections 10-3-2900 through 10-3-2906, Migratory Bird Treaty Act regulations, and other applicable biological resources regulations, as well as with CEQA for those projects subject to CEQA review. Furthermore, to the extent that the related projects would result in significant impacts to biological resources, they would be required to implement mitigation to reduce or avoid the impacts. Thus, as the Project would not result in significant impacts to biological resources, the Project would not contribute considerably to cumulative biological resources impacts, and cumulative biological resources impacts would be less than significant.
Cultural Resources – Cumulative impacts to historical resources would occur if the Project and related projects affect local resources with the same level or type of designation or evaluation, affect other structures located within the same historic district, or involve resources that are significant within the same context. As detailed in Section 4.5, Cultural Resources, of this IS/ND, in a Beverly Hills Architectural Commission Report prepared by the City in 2019, the parking garage that contains the Project Site and the attached office building are noted as potential Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
contributors to an eligible postwar commercial historic district. However, the Project Site is not individually eligible for listing in the National Register, California Register, or the Beverly Hills Register. Furthermore, because the Project would preserve the vast majority of the parking garage’s extant historic materials and features, the parking garage and attached office building would retain the physical characteristics that account for their potential eligibility as a contributor to the eligible postwar commercial historic district. Therefore, the Project would not cause a substantial adverse impact in the significance of a historical resource. Additionally, the other potential development projects would be subject to the same CEQA requirements as the Project and potential impacts to historic resources would be evaluated as part of those projects’ environmental analysis. The determinations regarding impacts to historical resources from other development projects would be made on a case-by-case basis, and the impacts of cumulative development on historical resources would be mitigated to the extent feasible. As such, cumulative historical resources impacts would be less than significant.
For archaeological resources, all related projects are subject to applicable regulations formulated to avoid significant archaeological resource impacts. In addition, as applicable, related projects would be required to conduct site-specific SLF or records searches with the SCCIC to determine if any applicable results would affect the related projects. Additionally, the other potential development projects would be subject to the same CEQA requirements as the Project and potential impacts to archaeological resources would be evaluated as part of those projects’ environmental analysis. Thus, as the Project would not result in significant impacts to archaeological resources, the Project would not contribute considerably to cumulative archaeological resources impacts, and cumulative archaeological resources impacts would be less than significant.
Regarding impacts related to human remains, if human remains are discovered during construction of any related projects, work in the immediate vicinity would be halted, the County Coroner, construction manager, and other entities would be notified per California State HSC Sections 7050.5-7055, and disposition of the human remains and any associated grave goods would occur in accordance with PRC Section 5097, et seq. Therefore, with the implementation of regulatory requirements, cumulative impacts related to human remains would be less than significant.
Energy – As discussed in Section 4.6, Energy, of this IS/ND, the Project would result in a less-thansignificant impact on energy resources and would adhere to all applicable energy conservation requirements. As with the Project, the related projects would be expected to adhere to applicable energy conservation requirements and implement energy conservation features, as needed, to minimize the inefficient use of energy in accordance with applicable regulations. Therefore, the Project and the related projects would not result in the wasteful, inefficient, or unnecessary consumption of energy resources or conflict with or obstruct a state or local plan for renewable energy or energy efficiency. As such, the Project would not contribute considerably to cumulative energy impacts, cumulative energy impacts would be less than significant.
Geology and Soils – Due to their site-specific nature, geology and soils impacts are typically assessed on a project-by-project basis or for a particular localized area. As provided under Section 4.7, Geology and Soils, of this IS/ND, the Project’s impacts would be less than significant.
As with the Project, the related projects would address site-specific geologic hazards through the Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
implementation of site-specific geotechnical recommendations and/or mitigation measures.
Cumulative development would expose a greater number of people to seismic hazards. However, as with the Project, related projects would be subject to local, State, and federal regulations and standards for seismic safety.
Regarding paleontological resources, the Project would not involve any excavation. Although the Project would include minor ground-disturbing activities within the existing utility right-of-way adjacent to the Project Site for connections to existing utility infrastructure, the soils within the utility right-of-way have previously been disturbed. As such, the likelihood for paleontological resources to exist is low. As part of the environmental review processes for the related projects, it is expected that mitigation measures or City conditions of approval would be required to address the potential for uncovering of paleontological resources. Therefore, the Project would not contribute considerably to cumulative geology and soils impacts, and cumulative geology and soils impacts would be less than significant.
Greenhouse Gas Emissions – As analyzed in Section 4.8, Greenhouse Gas Emissions, of this IS/ND, the analysis of a project’s GHG emissions is inherently a cumulative impacts analysis because climate change is a global problem and the emissions from any single project alone would be negligible. Accordingly, the Project-level analysis in Section 4.8, Greenhouse Gas Emissions, of this IS/ND assessed the potential for the Project to contribute to the cumulative impact of global climate change. As analyzed above, the Project’s impacts regarding GHG emissions would be less than significant. As such, the Project would not contribute considerably to cumulative GHG impacts, and cumulative GHG impacts would be less than significant.
Hazards and Hazardous Materials – Like the Project, many of the related projects would use, handle, store, and/or transport hazardous materials, such as ACM and/or LBP, or require demolition of structures containing such materials. Such related projects would be required to use, store, remove and/or transport all potentially hazardous materials in accordance with the manufacturers’ instructions and handle materials in accordance with federal, State, and local health and safety standards and regulations. Compliance with existing standards and regulations would ensure that the related projects would not result in significant impacts to the public or the environment through the routine transport, storage, use, or handling of hazardous materials, and that their development would not result in the release of existing hazardous materials. Some of the related projects may be on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. However, each related project would be required to comply with existing federal, State, and local regulations related to hazardous materials sites, including cleanup sites, and hazardous materials generators.
As with the Project, some of the related projects may include the use of hazardous materials within 0.25-mile of a school. However, related projects would be subject to environmental review to evaluate potential impacts from hazardous materials releases within 0.25-mile of a school, thereby reducing impacts to less than significant. None of the related projects are within two miles of an airport land use plan, thereby reducing impacts to less than significant.
Some of the related projects may involve temporary construction encroachments into adjacent sidewalks or roadways. However, any changes to access and building configurations would comply with applicable fire code requirements for emergency evacuation, including proper emergency exits for patrons, employees, and potential residents. All access and circulation plans Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
would be subject to review and approval by the BHFD and would be developed to meet City standards for emergency access. The related projects would be developed within the existing urban grid and would not require alterations to emergency access routes and would not contribute to cumulative effects in concert with the Project.
Related projects are all located in highly urbanized areas, would not contain wildland features, and are not located adjacent to any wildland areas. Therefore, development of related projects would not expose people or structures to a significant risk of loss, injury, or death involving wildland fires.
Therefore, the Project would not contribute considerably to cumulative hazards and hazardous materials impacts, and cumulative hazards and hazardous materials impacts would be less than significant.
Hydrology and Water Quality – Related projects would potentially result in an increase in surface water runoff and contribute point and non-point source pollutants to nearby water bodies.
However, as with the Project, related projects would be subject to the City’s LID requirements.
Additionally, construction projects greater than one acre would be subject to NPDES permit requirements, including development of a Stormwater Pollution Prevention Plan, Standard Urban Stormwater Mitigation Plan requirements during operation, and other local requirements pertaining to hydrology and surface water quality, and all construction projects would be required to prepare and implement an ESCP. As noted in Section 4.10, Hydrology and Water Quality, of this IS/ND, as the Project would include a greater square footage of planter boxes than existing conditions, development of the Project would improve surface water quality runoff compared to existing conditions. It is anticipated that related projects would also be evaluated on an individual basis by the City of Beverly Hills Department of Public Works to determine appropriate BMPs and treatment measures to avoid significant impacts to hydrology and surface water quality. Thus, with implementation of standard regulatory requirements, Project impacts related to hydrology and water quality would not be cumulatively considerable, and cumulative impacts would be less than significant.
The Project is not proposed in a floodplain, would not impede or redirect flood flows, and would not be subject to inundation by 100-year flood flows, seiches or tsunamis. Therefore, the Project would not contribute considerably to cumulative hydrology and water quality impacts, and cumulative hydrology and water quality impacts would be less than significant.
Additionally, regarding groundwater quality, no water supply wells, groundwater recharge areas, or groundwater recharge facilities are located within or in the vicinity of the Project Site. Future growth in the Hollywood Groundwater Basin would be subject to requirements relating to groundwater quality. In addition, since the Project Site is located in a highly urbanized area, future land use changes or development are not likely to cause substantial changes in regional groundwater quality. As noted above, the Project does not have an adverse impact on groundwater quality. Also, it is anticipated that, like the Project, other future development projects would comply with all applicable laws, rules, and regulations, therefore cumulative impacts to groundwater quality would be less than significant.
Land Use and Planning – As discussed in Section 4.11, Land Use and Planning, of this IS/ND, upon approval of the proposed ZTA and GPA by the City, the Project would be substantially consistent with applicable land use plans, policies, and regulations, and would result in less than significant Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
land use and planning impacts. Specifically, the Project would not physically divide an established community, and would not cause a significant environmental impact due to a conflict with a land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. As with the Project, related projects would be reviewed on a case-by-case basis to ensure consistency with existing land use policies and regulations. Where inconsistencies occur for the related projects, it is anticipated that appropriate actions would be undertaken to ensure that land use impacts would be less than significant. Thus, cumulative land use impacts would be less than significant.
Mineral Resources – As substantiated in Section 4.12, Mineral Resources, of this IS/ND, the Project Site is not located in a MRZ or a mineral producing area such that the Project would not result in the loss of a locally significant mineral resource recovery site. Furthermore, no mineral resources or extraction operations for such resources occur within or in the vicinity of the Project Site, and the Project does not propose any mining or drilling activities. Therefore, the Project would not contribute considerably to cumulative mineral resources impacts, and cumulative mineral resources impacts would be less than significant.
Noise – As discussed in Section 4.13, Noise, of this IS/ND, potential noise impacts associated with construction and operation of the Project would be less than significant. The Project’s potential vibration impacts with respect to human annoyance and potential building damage associated with construction activities and operation would also be less than significant. Additionally, the Project’s potential groundborne noise impacts would be less than significant during construction and operation. Also, although the closest related projects are approximately 260 feet and 390 feet from the Project Site, as with the Project, all related projects would be required to comply with existing City noise regulations, and mitigate their noise impacts, if applicable. Therefore, the Project would not contribute considerably to cumulative noise impacts, and cumulative noise impacts would be less than significant.
Population and Housing – As discussed in Section 4.14, Population and Housing, of this IS/ND, the Project would not construct or displace residential units such that there would be no direct impacts to population and housing. While the Project would increase on-site employment, the Project is expected to hire employees from the local population and generally would not require relocation for such employment opportunities. As such, these increases would not be expected to cause a substantial number of new households to cause a substantial demand for new housing.
Furthermore, the Project Site is already developed with urban uses, and the Project would not extend infrastructure to currently unserved areas and would not induce substantial population growth. Thus, as concluded in Section 4.14, Population and Housing, Project population and housing impacts would be less than significant. In addition, while the related projects could cumulatively increase population in the area, such increases would be expected to be within City and SCAG growth forecasts. The Project would contribute little if any to additional population growth in the area. Thus, the Project would not contribute considerably to cumulative population and housing impacts, and cumulative population and housing impacts would be less than significant.
Public Services – As discussed in Section 4.15, Public Services, of this IS/ND, the Project would meet City fire flow and emergency access requirements and CBC requirements related to fire protection. The Project would not result in a substantial increase in demand for BHFD facilities Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
and services and would not result in substantial traffic congestion which could slow emergency response. Therefore, Project impacts to fire protection would be less than significant. Like the Project, the related projects would be required to comply with applicable City fire protection requirements and fire safety plan review. In addition, consistent with the decision in City of Hayward v. Board Trustees of California State University (2015) 242 Cal. App. 4th 833 and the requirements stated in the California Constitution Article XIII, Section 35(a)(2), it is the City’s obligation to provide adequate fire protection and emergency medical services. Through the City’s regular budgeting efforts, BHFD’s resource needs, including staffing, equipment, trucks and engines, ambulances, other special apparatuses and possibly station expansions or new station construction, would be identified and allocated according to the priorities at the time. Therefore, the Project would not contribute considerably to cumulative fire protection impacts, and cumulative fire protection impacts would be less than significant.
Regarding police protection, the Project would not introduce a direct residential population typically associated with an increased demand for such services. During operations, both driveways of the parking garage that the Project Site is within would continue to be secured by existing parking barriers that require visitors to press a button for a ticket to enter the parking garage. The Project would also include security measures such as security lighting and a surveillance camera system. In addition, consistent with the decision in City of Hayward v. Board Trustees of California State University (2015) 242 Cal. App. 4th 833 and the requirements stated in the California Constitution Article XIII, Section 35(a)(2), it is the City’s obligation to provide adequate public safety services. Through the City’s regular budgeting efforts, BHPD’s resource needs, including staffing, equipment, basic cars, and possibly station expansions or new station construction that may become necessary to achieve the required level of service. Therefore, the Project would not contribute considerably to cumulative police protection impacts, and cumulative police protection impacts would be less than significant.
As analyzed previously, the Project would not generate a direct residential population that could increase the demand for schools or libraries. In addition, any direct increase in the local residential population associated with the Project would be inconsequential. Therefore, the Project would not contribute considerably to any cumulative impacts to schools, libraries, or hospitals, and cumulative schools, libraries, and hospitals impacts would be less than significant.
Recreation – The Project does not include residential development, which typically creates a direct demand on park services. Additionally, any indirect increase in the local residential population with the Project would be inconsequential. The Project does not propose the demolition or addition of any open space. Thus, as discussed in Section 4.16, Recreation, of this IS/ND, no substantial new demand for parks and recreational facilities would occur. Moreover, related projects requiring discretionary approvals would be subject to CEQA review by the City which would address, in part, parks and recreational facilities service demand. Thus, the Project would not contribute considerably to cumulative parks and recreation impacts, and cumulative parks and recreation impacts would be less than significant.
Transportation – Similar to the Project, the related projects would be individually responsible for complying with relevant plans, programs, ordinances, or policies addressing the circulation system. In addition, similar to the Project, the related projects would be required to mitigate any conflicts with VMT reduction requirements, substantial hazards due to geometric features or Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
incompatible uses, and inadequate emergency access. Furthermore, as discussed in Section 4.17, Transportation, of this IS/ND, the Project would be consistent with existing applicable plans addressing circulation and would result in less-than-significant impacts associated with VMT, hazards due to design features or incompatible uses, and emergency access. Related projects would be required to implement transportation demand mitigation (TDM) measures, be required to comply with County’s congestion management program, or implement mitigation measures as needed. Therefore, the Project would not contribute considerably to cumulative transportation impacts, and cumulative transportation impacts would be less than significant.
Tribal Cultural Resources –The majority of the related projects are located a substantial distance from the Project Site. In addition, the Project and several of the related projects are located on sites that are currently developed or have otherwise been disturbed. An SLF search conducted with the NAHC resulted in positive findings within the vicinity of the Project area, and the NAHC recommended further consultation with the Gabrieleño/Tongva San Gabriel Band of Mission Indians in accordance with AB 52 and SB 18. Furthermore, as discussed in Section 4.18, Tribal Cultural Resources, of this IS/ND, since no archaeological resources were identified within the Project Site as a result of the records search and associated research, it is unlikely that undisturbed archaeological resources are present within the Project Site given the extent of prior development. Additionally, the Project would involve only minimal ground-disturbing activities within the existing utility right-of-way adjacent to the Project Site for connection to utility infrastructure, and would not involve excavation or grading. As such, there is little potential for archaeological resources that meet the definition of “Historical Resources” or “Unique Archaeological Resources”, as defined by CEQA, to be identified within the Project area as a result of the Archaeological Resources Assessment. Regarding the associated ZTA and GPA, the ZTA and GPA would only affect development within the Business Triangle, which also has been heavily disturbed and is entirely developed with commercial and office uses. Any related projects would similarly be subject to project-specific mitigation measures should it be determined that there be tribal cultural resources present. Furthermore, like the Project, the related projects would be required to comply with the consultation requirements of AB 52 and/or SB 18 to determine and mitigate any potential impacts to tribal cultural resources. Therefore, the Project would not contribute considerably to cumulative tribal cultural resources impacts, and cumulative tribal cultural resources impacts would be less than significant.
Utilities and Service System – Due to shared urban infrastructure, the Project and related projects would cumulatively increase water demand, wastewater generation, stormwater discharges, and energy and telecommunication service demand on the local water, sewer, stormwater drainage, and energy infrastructure. However, as discussed in Section 4.19, Utilities and Service Systems, of this IS/ND, sufficient infrastructure capacity is available to accommodate the Project. Additionally, as with the Project, related projects would be reviewed by the City to ensure that sufficient capacity is available or additional improvements are made to provide capacity prior to construction. Therefore, the Project would not contribute considerably to cumulative utilities and service system impacts, and cumulative impacts would be less than significant.
With regard to solid waste, the Project in conjunction with related projects would increase the need for solid waste disposal during their respective construction and operation periods.
However, with the implementation of solid waste policies and objectives intended to help Kimley»)Horn
450 North Roxbury Drive Project
City of Beverly Hills Final Initial Study/Negative Declaration
achieve the requirements of AB 939 and the City’s 50-percent diversion goal, it is expected that the Project and related projects would not substantially reduce the projected timeline for landfills within the region to reach capacity. Moreover, the County of Los Angeles conducts ongoing evaluations to ensure that landfill capacity is adequate to serve the forecasted disposal needs of the region. Therefore, the Project would not contribute considerably to cumulative solid waste impacts, and cumulative solid waste impacts would be less than significant.
Wildfire – As provided in Section 4.20, Wildfire, of this IS/ND, the Project is not located in or near a State Responsibility Area or lands classified as VHFHSZ. The Project would not substantially impair an adopted emergency response plan or emergency evacuation plan or expose people or structures to significant risks, including downslope or downstream flooding or landslides, after a fire. Thus, the Project would not contribute considerably to cumulative wildfire impacts, and cumulative wildfire impacts would be less than significant.
As the above analysis shows, due to the distance of most of the related projects from the Project Site and the physical conditions in the vicinity of the Project Site, the Project would not have impacts that are individually limited but cumulatively considerable. Additionally, as stated above in Section 2.3.6, Proposed ZTA and GPA, as the application of the ZTA and GPA to other potential sites within the Business Triangle is not reasonably foreseeable at this time, those projects, should it be submitted as a formal application to the City, would require a project-specific CEQA analysis at that time. Therefore, cumulative impacts would be less than significant.
4.21c Does the project have environmental effects which will cause substantial adverse effects on human beings, directly or indirectly?
Less Than Significant Impact. As discussed in the respective sections, the Project would have no potentially significant impacts that would not be reduced to less than significant following compliance with the established regulatory framework and/or conditions of approval for the Project. The Project would not cause substantial adverse effects on human beings directly or indirectly. Therefore, impacts concerning adverse effects on human beings would be less than significant.
Kimley»)Horn
Appendix A
Air Quality Analysis
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040
MEMORANDUM
To: Minjee Hahm, AICP
Associate Planner
City of Beverly Hills
From: Olivia Chan and Ciara Anderson
Date: September 6, 2024
Subject: 450 North Roxbury Drive Project – Air Quality Analysis Purpose
The purpose of this memorandum is to assess potential impacts due to air pollutant emissions associated with construction and operation of the 450 North Roxbury Drive Project (Project), proposed to be located in the City of Beverly Hills (City), California.
Project Location
The Project would redevelop a 6,797 square foot portion of the ground floor of a five-floor, partially subterranean parking garage (the upper two levels are above ground) with rooftop parking located on a 0.8-acre parcel (Assessor’s Parcel Number [APN] 4343-024-020) (Project Site);see Figure 1: Local Vicinity Map. The five-floor parking garage is attached to a 10-story, 155-foot-tall office building located on the northern portion of the same parcel, constructed in 1970. The parking garage and office building together are considered the Project Site; however, the remainder of the parking garage and the attached office building would not be redeveloped as part of this Project. The Project Site is bound by Santa Monica Boulevard to the north, Bram Goldsmith Way (an alley) to the east, an existing commercial building to the south, and North Roxbury Drive to the west. The Project Site is in the southwestern portion of the City, in Los Angeles County (County), approximately 3.0 miles north of Culver City and 8.5 miles west of downtown Los Angeles; see Figure 2: Regional Vicinity Map.
Project Description
The Project would convert a portion of the ground level of the existing parking garage to approximately 6,797 square feet of retail uses, split into four retail spaces ranging from 1,397 square feet to 1,841 square feet. The retail spaces would be accessed from the North Roxbury Drive street frontage. Storefront facades would consist of louvers, cast-in-place (CIP) concrete, and storefront glazing, with signage installed on top. Approximately 300 square feet of planter area would also be added; see Figure 3: Conceptual Site Plan.
Kimley»Horn
SOURCE: Google Earth, 2024
Bedford Dr
S Santa Monica Blvd
N Roxbury Dr
State Route 2
Brighton Way
Bram Goldsmith Way
FIGURE 1: Local Vicinty Map
450 NORTH ROXBURY DRIVE PROJECT
Business Triangle
Project Site
Wilshire Blvd
Canon Drive
N Crescent Dr
AYR% Ls.' PWee ) • W X et), 1040 • hs 0 E
83 0
if . B
••. s •, V
y
Ai L. ar
3 "T" -l s t. f Y %
s
Y
' r
1 'w
.( %
A 5
", I ? . I $ 0 ...
*
A
“Isd vei w
A
v* s %
p A .. '
*
% 5
Y 2 3 UN 5 st 5 -t e / ‘o
- Ji vx A S
*
a . t
A ? s.
dg
s. ). s
AX
* A. v‘% or Y
.7 1Z ri Aw A
1 4
4 ■
V
Me’t’
Kimley>»Horn
‘‘s V4
)
Ne
t
iro
□
□
/ .■ //
4 ■ .
S%gk 4
3 -1 e
V.
N
1st 2
e
f.%, ■ Nwe *es r
d
V / Ss
‘h -
50 2
& *
:4s
X..
a%
♦ Y e"
254
&a
1,
' -‘y
wrV, S * Xde
P
yi St
..
o
Y
«.s
%i l
5 “V
C
2 V
*. MssA
• a • )2wee ‘a “
ll
a
va
y —ly.
".Y
X. A "
s.
Fs
z-w
Pat’ Y
e’V .
e s 6:
AT. fe
V.
1 vgos
S\ *
*a- n r. A Le
Arg
, 40 ewet
te.g
C
by
0Ropr.
3M
i "*
SOURCE: Nearmap, 2024
FIGURE 2: Regional Vicinty Map
450 NORTH ROXBURY DRIVE PROJECT
Project Site
and Business
Business Triangle
Project Site
Cienega Historic
Leimert
Arlington
Heights
Harvard
Heights
Jefferson
Park
2O
%
Hollywood
Wall me
Larchmont
Fairfax
Central
Hollywood
West
Hollywood
Runyon
Park
Hollywood
Hills West
Wilshire
Country Club
Hollywood- ■
Forever
Memorial Park
Beverly
Grove
%
s
%
Jefferson
PicoUnion
Rosedale
Cemetery
Exposition
Park
University of
Southern •
California i
University
Park
/
2 f
- —T
Tropico
Atwater
G
o
LOS
%
8 0. Los Feliz )
D
C. O
Edendale
101
a
%, %4
Silver
Lake
Echo
Park
Elysian
Park
Dodger
Stadium
Silver Lake
Reservoir
East
Hollywood
9C
(D5
c9
%
Forest Lawn
Memorial
Park
%
Elysian
Va 1 (
Cs
o rel
4.“odifwy.
Sr. “orO,
4 $
Hollywood -
Sign View
Point Q
Mid City
anta Monica.EWy
McManus
Sentous
Kenneth Hahn
West
Adams
Blair
Hills
Wilshire Blvd oo
Koreatown
Carthay
Los Angeles
G
Z
Windsor
Square
Rampart
Village
Mi
Jun Park La
Brea
Hancock
Park
Nose la
MidWilshire MacArthur
Park
%
a
Bel Air
lvd
Mt wil
an Nuys Burbank ltadena
,Cal Beverlywood a lenc Ar ac? Topanga
Los Ai
Malibu
Montebello City 7 • - Huntington Pico
Park 8 Rivera Inglewood
Hawthorne (
Junction Comptor
(6 Beach
Torrance
Cy Lomita
ing
Beach
larkdale
Lower
Franklin
Reservoir
Rancho
Palos
Beverly
Glen
Westwood
Village
Culver
City
Stone Canyon
Reservoir
Santa
Monica
Los Angeles
Country Club
Fryman
Canyon
Park
University of
California-LA
Seal
Roar li Park
East
Century
City
Beverly
Crest
Bel-Air
Country
Club
Santa Monica
Mtns National
Rec Area
PicoRobertson
Beverly
Hills
6 scenta
Beverly
Hills
San Gabriel
•I
□
Kimley»Horn
(N,
o Ol
s Alameda St
S
s
O
S Western Ave N western Ave
SOURCE: HLW International LLP, 2024
FIGURE 3: Conceptual Site Plan
450 NORTH ROXBURY DRIVE PROJECT
0U
33'-9 3/4"
-25' -8" -24'
STALLS &*
A CESSIBLE PARI
CD
&&
0/////////7
Restroom Restroom
— 03B |
57 SF 57 SF
Tenant Space Tenant Space
1,397 SF 1,602 SF
Restroom
| 02B }
57 SF
Tenant Space I 03
1,602 SF 6
Restroom F
57 SF
Tenant Space I
1,841 SF
02 1'
102 SF
T I T I
9 TANDEM & 9 SINGLE PARKING STALLS
24-61/2" 1 PARKING
J 1
13' - 3 3/4" Total Area = 6,797 SF 7
Stair
05 110SF
Ql 240'-0"
25'-0" 25'-0" 25'-0" 25’-0" 25'-0" I
04B
04 DDX
3'-0" Setback
Property Line
Stair
5'-0" 9' -0"
9 1
. O' 51 - 0" 91 - 0"
27 TOTAL PARKING STALLS ON LEVEL 1
336 TOTAL PARKING STALLS IN BUILDING
Parking Garage
06 I
Not Enclosed
z*
A
■■
T
C
4 EXISTING TO REMAIN AP V
Generator 11
221 SF
Trash 12
195 SF
4 Fire Pump
13 1
391 SF
&
d &. &. &.
CD
5 ACCESSIBLE PARKING STALLS
OO
EXISTING TO REMAIN
V
1/2"- -24-61/2" -35'-7 1/2" 20'-0"7
1 -6
KIIKIIII
Existing striped access aisle from
ADA parking to Roxbury Drive.
C
LO
(E) OFFICE BUILDING
NOT IN SCOPE
01B
Kimley»Horn
y I
45'-0 3/4'
>
68‘-5"
68'-11 3/4
I
26'-5 1/4'8'-8 1/4 1 10'-7" 42'-11 1/2' 21 -7 3/4'
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 The Applicant is requesting a Zone Text Amendment (ZTA) and General Plan Amendment (GPA) to allow an increase in the maximum FAR as a result of the conversion of the ground level of an existing parking structure abutting a public street to retail business(es), as defined in Beverly Hills Municipal Code (BHMC) Section 10-3-100, up to a depth of 70 feet from the front property line, subject to approval of a Development Plan Review pursuant to BHMC Section 10-3-3100. 1 In compliance with
the proposed ZTA and GPA, the Project is proposing a conversion of 6,797 square feet of an existing parking structure, resulting in a new total of 103,647 square feet of proposed floor area. Pursuant to BHMC Section 10-3-2745, the maximum allowable floor area for the Project Site is 72,960 square feet.
Therefore, the 6,797 square feet conversion is approximately 9.3 percent of the existing building square footage (96,850 square feet) and would be less than 10 percent of the maximum allowable floor area for the site.
The Project would remove 29 existing parking spaces (including 24 single parking spaces and 5 tandem parking spaces) on the ground floor and restripe the remaining ground level of parking to replace the 3 removed ADA spaces, which would be relocated to be adjacent to the northeastern end of the proposed retail spaces. Vehicular access to the Project Site would continue to be provided via the two existing in/out driveways on North Roxbury Drive. Pedestrian access would continue to be provided via the existing sidewalk along North Roxbury Drive. The Project would not modify the existing driveways and sidewalk.
A new mechanical split heating, ventilation, and air conditioning (HVAC) system would be installed above the ceilings of the retail spaces. A new rooftop HVAC unit would be provided immediately south of an existing HVAC unit on the rooftop of the parking garage. The Project would also install four 5- ton heat pump condensers along the western edge of the rooftop. An automated sprinkler system would also be installed within the retail spaces for fire protection purposes, including a fire pump on the eastern portion of the Project Site.
Project construction would include the demolition of existing building façade, flooring, and planters, building construction, and architectural coatings. Demolition activities would require the use of haul trucks. No grading or excavation will be required to construct this Project. Project construction is anticipated to begin as early as January 2025 and would be completed as early as February 2026.
Construction of the Project is estimated to require approximately 14 months. 1 The ZTA and GPA would apply to the entire Business Triangle of the City; however, future projects that would seek to utilize the ZTA and GPA would be subject to environmental review at such time.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Air Quality Impacts
South Coast Air Quality Management District Thresholds
The South Coast Air Quality Management District (SCAQMD) is the regulatory agency responsible for improving air quality for large areas of Los Angeles, Orange, Riverside, and San Bernardino Counties.
The Project Site is located within the South Coast Air Basin, which is a distinct geographic subarea within SCAQMD’s jurisdiction. The SCAQMD CEQA Air Quality Handbook provides significance thresholds for volatile organic compounds (VOC) (also referred to as reactive organic gases [ROG]), nitrogen oxides (NOX), carbon monoxide (CO), sulfur oxides (SOX), particulate matter 10 microns or less in diameter (PM10), and particulate matter 2.5 microns or less in diameter (PM2.5). The thresholds apply to both project construction and operation within the SCAQMD jurisdictional boundaries. If the SCAQMD thresholds are exceeded, a potentially significant impact could result.
However, ultimately the City, as the Lead Agency under CEQA, determines the thresholds of significance for impacts. If a project proposes development in excess of the established thresholds, as outlined in Table 1: South Coast Air Quality Management District Significance Thresholds, a significant air quality impact may occur, and additional analysis is warranted to fully assess the significance of impacts.
Table 1: South Coast Air Quality Management District Significance Thresholds Pollutant Mass Daily Thresholds (pounds per day)
Construction Operations
Nitrogen Oxides (NOX) 100 55
Volatile Organic Compounds (VOC)1 75 55
Particulate Matter up to 10 Microns
(PM10)
150 150
Particulate Matter up to 2.5 Microns
(PM2.5)
55 55
Sulphur Oxides (SOX) 150 150
Carbon Monoxide (CO) 550 550
Notes:
1. VOCs and ROGs are subsets of organic gases that are emitted from the incomplete combustion of hydrocarbons or other carbon-based fuels. Although they represent slightly different subsets of organic gases, they are used interchangeably for the purposes of this analysis.
Source: South Coast Air Quality Management District, SCAQMD Air Quality Significance Thresholds, April 2019.
Local Air Quality
The SCAQMD maintains a network of air quality monitoring stations located throughout the South Coast Air Basin to measure ambient pollutant concentrations. The Project Site is located in SCAQMD Source Receptor Area (SRA) 2; therefore, the monitoring station most representative of the Project Site is the Northwest Coastal LA County Monitoring Station. Criteria pollutants monitored at this station include ozone, NO2, and CO (through 2021). The Central LA Monitoring Station, east of the Project Site, was used to report data for CO (after 2021), SO2, lead, PM10, and PM2.5. The most recent Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 pollutant concentration data available from the SCAQMD for these monitoring stations are from years 2021 to 2023, and are summarized in Table 2: Beverly Hills Ambient Air Quality Data.
Table 2: Beverly Hills Ambient Air Quality Data
Pollutant/Standard1,2 2021 2022 2023
O3 (1-hour)
Maximum Concentration (ppm)
Days > CAAQS (0.09 ppm)
0.095
1 0.081
0 0.109
1 O3 (8-hour)
Maximum Concentration (ppm)
4 th High 8-hour Concentration (ppm)
Days > CAAQS (0.070 ppm)
Days > NAAQS (0.070 ppm)
0.082
0.059
1 1
0.070
0.058
0 0
0.066
0.064
0 0
NO2 (1-hour)
Maximum Concentration (ppm)
98th Percentile Concentration (ppm)
NO2 (Annual)
Annual Arithmetic Mean (0.030 ppm)
0.061
0.042
0.010
0.051
0.045
0.011
0.044
0.040
0.009
CO (1-hour)
Maximum Concentration (ppm)
CO (8-hour)
Maximum Concentration (ppm)
1.5 1.0
1.7 1.5
1.4 1.2
SO2 (1-hour)
Maximum Concentration (ppm)
99th Percentile Concentration (ppm)
SO2 (24-hour)
Maximum Concentration (ppm)
0.002
0.002
--
0.007
0.002
--
0.008
0.002
--
PM10 (24-hour)
Maximum Concentration (µg/m3)
Samples > CAAQS (50 µg/m3)
Samples > NAAQS (150 µg/m3)
PM10 (Annual Average)3
Annual Arithmetic Mean (20 µg/m3)
64 3
0 25.5
60 4
0 28.9
57 2
0 24.3
PM2.5 (24-hour)
Maximum Concentration (µg/m3)
98th Percentile Concentration (µg/m3)
Samples > NAAQS (35 µg/m3)
PM2.5 (Annual)4
Annual Arithmetic Mean (12 µg/m3)
61 44.8
12 12.77
33.7 21.9
0 10.94
30.6 23.4
0 10.25
Lead
Maximum 30-day average (µg/m3) 0.012 0.008 0.007
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Table 2: Beverly Hills Ambient Air Quality Data
Pollutant/Standard1,2 2021 2022 2023
Notes:
ppm = parts per million; µg/m3 = micrograms per cubic meter
1. The monitoring station most representative of the Project Site is Station number 91 in Northwest Costal LA County, which is used to establish ambient O3, NO2, and 2021 CO, levels. Since data for 2022/2023 CO, SO2, lead, PM10 and PM2.5 are not monitored at this station, the Station in Central LA was used to report data for 2022/2023 CO, SO2, lead, PM10, and PM2.5 The most recent data available from SCAQMD for these monitoring stations are from years 2021 to 2023.
2. The California Ambient Air Quality Standards (CAAQS) are based on a not to exceed standard. The National Ambient Air Quality Standards (NAAQS) are based on a 3-year average of the annual 4th highest daily maximum 8-hour concentration for O3; 98th percentile of 1-hour daily maximum concentrations averaged over 3 years for 1-hr NO2; and not to be exceeded more than once per year on average over 3 years for 24-hr PM.
3. State annual average (AAM) PM10 standard is > 20 µg/m3. Federal annual PM10 standard (AAM > 50 µg/m3) was revoked in 2006.
4. Both Federal and State standards are annual average (AAM) > 12.0 µg/m3.
Source: SCAQMD, Historical Data by Year, www.aqmd.gov/home/air-quality/air-quality-data-studies/historical-data-byyear; CARB, Ambient Air Quality Standards, ww2.arb.ca.gov/sites/default/files/2020-07/aaqs2.pdf. Accessed July 3, 2024.
City of Beverly Hills General Plan
The City is responsible for the assessment and mitigation of air emissions resulting from its land use decisions. The City’s General Plan Land Use, Open Space, and Conservation Elements contain the following policies specific to air quality:
• Land Use Policy LU 14.1 Accommodate a balanced mix of land uses and encourage development to be located and designed to enable residents access by walking, bicycling, or taking public transit to jobs, shopping, entertainment, services, and recreation, thereby reducing automobile use, energy consumption, air pollution, and greenhouse gases. • Land Use Policy LU 16.9 Require that private and public buildings be designed to promote public health by prohibiting the use of toxic building materials and high-VOC paints, providing adequate ventilation and access to natural lighting, and using “green building” techniques as required by the City's sustainability programs such as the Green Building Ordinance. • Open Space Policy OS 7.5 Coordinate with SCAQMD to ensure that projects incorporate feasible mitigation measures if those measures are not already provided for through project design.
• Open Space Policy OS 7.7 Work with the South Coast Air Quality Management Board (SCAQMB) to meet state and federal ambient air quality standards. • Open Space Policy OS 7.8 Require new development projects that exceed the SCAQMB Reactive Organic Gases (ROG) and Nitrogen Oxides (NOX) operational thresholds to incorporate design or operational features that reduce emissions equal to 15-percent from the level that would be produced by an unmitigated project. • Open Space Policy OS 7.11 Educate the public about air quality standards, health effects, and efforts that residents can make to improve air quality and reduce greenhouse gas emissions in the Los Angeles Basin.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 • Conservation Policy C 8.3 Continue to implement, as appropriate, the requirements of the NPDES and SCAQMD regulations, including requiring the use of Best Management Practices by businesses in the City.
City of Beverly Hills Sustainable City Plan
The Beverly Hills Sustainable City Plan establishes guiding principles and goals that the City uses to develop and implement programs that focus on sustainability. The following goal and policies are applicable to the Project:
Climate Change and Air Quality Goal: Combat climate change and improve air quality • Policy 1: Minimize greenhouse gas and other emissions from City facilities and operations • Policy 2: Minimize mobile source emissions from on- and off-road (construction) vehicles. • Policy 3: Minimize stationary source air emissions
• Policy 4: Minimize particulate matter, both airborne photochemical precipitates and windborne dust.
Regional Construction Impacts
Construction associated with the proposed Project would generate short‐term emissions of criteria air pollutants. The criteria pollutants of primary concern within the Project area include ozone‐ precursor pollutants (i.e., ROG and NOX, PM10, and PM2.5). Construction‐generated emissions are short term and of temporary duration, lasting only as long as construction activities occur, but would be considered a significant air quality impact if the amount of pollutants generated exceeds the SCAQMD’s thresholds of significance. Sources of emissions during construction include motor vehicle exhaust associated with construction equipment and worker trips and the movement of construction equipment, especially on unpaved surfaces. Emissions of airborne particulate matter are largely dependent on the amount of ground disturbance associated with site preparation grading activities as well as weather conditions and the appropriate application of water. However, the Project would not include site preparation or grading activities. Sensitive land uses surrounding the Project Site consist mostly of a church and residential communities located approximately 350 feet northwest of the Project Site.
The duration of construction activities for the Project is estimated to be approximately 14 months, beginning as early as January 2025 and ending as early as February 2026. The Project would convert existing parking area on the ground floor of an existing parking structure to retail uses and relocate three existing ADA parking spaces, resulting in a total construction area of approximately 0.16 acres.
Construction‐generated emissions associated with the Project were calculated using the CARB‐ approved California Emissions Estimator Model (CalEEMod), which is designed to model emissions for land use development projects, based on typical construction requirements. See Appendix A: Air Quality Data for more information regarding the construction assumptions used in this analysis.
Predicted maximum daily construction‐generated emissions for the Project are identified in Table 3:
Project Construction Emissions. The modeling emissions include truck idling time and emissions from heavy-duty diesel equipment.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Table 3: Project Construction Emissions
Construction Year Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
2025 0.53 5.19 7.11 0.01 0.35 0.21
2026 3.27 4.86 7.04 0.01 0.23 0.18
Maximum Emissions 3.27 5.19 7.11 0.01 0.35 0.21
SCAQMD Threshold 75 100 550 150 150 55
SCAQMD Threshold
Exceeded? No No No No No No
Notes:
1. Emissions were calculated using the California Emissions Estimator Model (CalEEMod) version 2022.1, as recommended by the SCAQMD. Worst-case seasonal maximum daily emissions are reported.
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs.
The Project is subject to SCAQMD Rules 402, 403, and 1113, which prohibit nuisances, require dust mitigation, and limit VOC content in paints, respectively. It has been assumed that these rules will be followed using watering the site and low VOC paints during construction. The results of the emissions modeling, as summarized on Table 3, show that construction criteria pollutant emissions would remain below the applicable thresholds, and construction impacts on short-term regional air quality would be less than significant.
Regional Operational Impacts
Operational emissions are typically associated with mobile sources (i.e., motor vehicle use) and area sources (such as the use of landscape maintenance equipment, hearths, consumer products, and architectural coatings). Energy source emissions would be generated from electricity and natural gas (non-hearth) usage. Table 4: Project Operational Emissions summarizes the operational emissions attributable to the Project. As shown in Table 4, the Project’s regional operational emissions would not exceed applicable SCAQMD thresholds, and operational impacts on long-term regional air quality would be less than significant.
Table 4: Project Operational Emissions
Source Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
Area 0.21 <0.005 0.30 <0.005 <0.005 <0.005
Energy <0.005 0.01 0.01 <0.005 <0.005 <0.005
Mobile 1.16 0.83 8.58 0.02 1.78 0.46
Total 1.37 0.84 8.88 0.02 1.78 0.46
SCAQMD Threshold 55 55 550 150 150 55
SCAQMD Threshold
Exceeded? No No No No No No
Notes:
1. Emissions were calculated using the California Emissions Estimator Model (CalEEMod) version 2022.1, as recommended by the SCAQMD. Worst-case seasonal maximum daily emissions are reported.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Table 4: Project Operational Emissions
Source Emissions (pounds per day)1
ROG NOX CO SO2 PM10 PM2.5
2. Totals may not add up due to rounding.
Source: CalEEMod version 2022.1. Refer to Appendix A for model outputs.
Localized Construction Impacts
The nearest sensitive receptors to the Project Site are a church and community of single-family residences located approximately 350 feet (approximately 100 meters) to the northwest. To assess potential impacts to nearby sensitive receptors, the SCAQMD established Localized Significance Thresholds (LSTs). LSTs were developed in response to SCAQMD Governing Boards' Environmental Justice Enhancement Initiative (I‐4). The SCAQMD provided the Final Localized Significance Threshold Methodology (dated June 2003 [revised 2008]) to assist lead agencies in analyzing project‐specific localized impacts.
CalEEMod calculates construction emissions based on the number of equipment hours and the maximum daily soil disturbance activity possible for each piece of equipment. However, the Project would not require any site preparation or grading activities. Therefore, because the Project disturbance area is less than one acre, the LSTs for a one acre site has been used in this construction analysis.
LSTs were established for NOX, CO, PM10, and PM2.5, based on project size and local ambient air pollutant levels, as determined by SRA. For this Project, the appropriate SRA for LSTs is the Northwest Coastal LA County (SRA 2). Thus, the applicable LSTs for a 1.0 acre site in SRA 2 were used in this analysis.
SCAQMD’s methodology indicates that “off‐site mobile emissions from the project should not be included in the emissions compared to LSTs.” Therefore, for purposes of the construction LST analysis, only emissions included in the CalEEMod “on‐site” emissions outputs were considered. LST thresholds are provided for distances to sensitive receptors of 25, 50, 100, 200, and 500 meters. The LSTs for 1.0 acre site with receptors at 100 meters were used for the construction analysis. Table 5: Localized Significance of Emissions presents the results of localized emissions modeling for construction activity.
Emissions of these pollutants on the peak day of construction would not result in significant concentrations of pollutants at nearby sensitive receptors. Therefore, construction impacts on regional air quality would be less than significant.
Localized Operational Impacts
According to the SCAQMD localized significance threshold methodology, LSTs apply to on-site sources.
LSTs for receptors located at 100 meters for SRA 2 were conservatively used in this analysis. The 1.0‐ acre LST threshold was used for the Project Site. The operational emissions include all on‐site Project‐ related stationary sources (i.e., area and energy sources). As shown on Table 5, the maximum daily emissions during operations would not exceed applicable LSTs, and are not expected to result in Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 significant concentrations of pollutants at nearby sensitive receptors. Therefore, operational impacts would be less than significant.
Table 5: Localized Significance of Emissions
Source/Activity Emissions (pounds per day)1
NOX CO PM10 PM2.5
Construction Emissions
Demolition 2025 4.3 5.6 0.2 0.2
Building Construction 2025 5.1 6.9 0.2 0.2
Building Construction 2026 4.8 6.9 0.2 0.2
Architectural Coating 2026 0.9 1.1 <0.1 <0.1
Maximum Daily Emissions 5.1 6.9 0.2 0.2
SCAQMD Localized Screening Threshold
(1.0 acres of disturbance at 100 meters) 121 1,233 27 8 Exceed SCAQMD Threshold? No No No No
Operational Emissions
On‐Site Emissions (Area + Energy Sources) <0.1 0.3 <0.1 <0.1 SCAQMD Localized Screening Threshold
(1.0 acres of disturbance at 100 meters) 121 1,233 7 2
Exceed SCAQMD Threshold? No No No No
Notes:
1. Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix A.
Source: CalEEMod version 2022.1. Refer to Appendix A for model data outputs.
Carbon Monoxide Hot Spots
An analysis of CO “hot spots” is needed to determine whether the change in the level of service (LOS) of an intersection from Project-related traffic would have the potential to result in exceedances of the CAAQS or NAAQS. It has long been recognized that CO exceedances are caused by vehicular emissions, primarily when vehicles are idling at intersections. Vehicle emissions standards have become increasingly stringent in the last 20 years. Currently, the CO standard in California is a maximum of 3.4 grams per mile for passenger cars (requirements for certain vehicles are more stringent). With the turnover of older vehicles, introduction of cleaner fuels, and implementation of control technology on industrial facilities, CO concentrations have steadily declined in the South Coast Air Basin.
Accordingly, with the steadily decreasing CO emissions from vehicles, even very busy intersections do not result in exceedances of the CO standard. An analysis prepared for CO attainment in the South Coast Air Basin by the SCAQMD can assist in evaluating the potential for CO exceedances. CO attainment was thoroughly analyzed as part of the SCAQMD’s 2003 Air Quality Management Plan (AQMP). The Basin was re‐designated as attainment in 2007 and is no longer addressed in the SCAQMD’s AQMP. The 2003 AQMP is the most recent AQMP that addresses CO concentrations. As Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 part of the SCAQMD CO Hotspot analysis, the Wilshire Boulevard/Veteran Avenue intersection, one of the most congested intersections in Southern California with an average daily traffic (ADT) volume of approximately 100,000 vehicles per day, was modeled for CO concentrations. This modeling effort identified a CO concentration high of 4.6 parts per million (ppm), which is well below the 35 ppm federal standard. The Project considered herein would not produce the volume of traffic required to generate a CO hot spot in the context of SCAQMD’s 2003 CO hot spot analysis as the Project would generate 370 net daily vehicle trips.2 As the CO hotspots were not experienced at the Wilshire Boulevard/Veteran Avenue intersection even as it accommodates 100,000 vehicles daily, it can be reasonably inferred that CO hotspots would not be experienced in the Project vicinity. Therefore, impact on regional air quality would be less than significant.
AQMP Consistency
As part of its enforcement responsibilities, the U.S. EPA requires each state with nonattainment areas to prepare and submit a State Implementation Plan (SIP) that demonstrates the means to attain the federal standards. The SIP must integrate federal, state, and local plan components and regulations to identify specific measures to reduce pollution in nonattainment areas, using a combination of performance standards and market-based programs. Similarly, under State law, the California Ambient Air Quality Standards (CAAQS) require an air quality attainment plan to be prepared for areas designated as nonattainment regarding the state and federal ambient air quality standards. Air quality attainment plans outline emissions limits and control measures to achieve and maintain these standards by the earliest practical date.
The Project is located within the South Coast Air Basin, which is under the jurisdiction of the SCAQMD.
The SCAQMD is required, pursuant to the Federal Clean Air Act (FCAA), to reduce emissions of criteria pollutants for which the South Coast Air Basin is in nonattainment. To reduce such emissions, the SCAQMD drafted the 2016 AQMP and 2022 AQMP. The 2016 AQMP establishes a program of rules and regulations directed at reducing air pollutant emissions and achieving state (California) and national air quality standards. The 2022 AQMP builds upon measures already in place from previous AQMPs.3The primary purpose of the 2022 AQMP is to identify, develop, and implement strategies and control measures to meet the 2015 8-hour ozone National Ambient Air Quality Standard (NAAQS). Air quality management planning is a regional and multi-agency effort including the SCAQMD, the CARB, the Southern California Association of Governments (SCAG), and the U.S. EPA. The AQMPs’ pollutant control strategies are based on the latest scientific and technical information and planning assumptions, including SCAG’s growth projections and the RTP/SCS, updated emission inventory methodologies for various source categories, and SCAG’s latest growth forecasts. SCAG’s latest growth forecasts were defined in consultation with local governments and with reference to local general plans. The Project is subject to the SCAQMD’s 2016 and 2022 AQMPs.
2 The Project’s daily vehicle trips are based on Institute of Transportation Engineers (ITE) Trip Generation Manual, 11th Edition.
3 South Coast Air Quality Management District, 2022 Air Quality Management Plan, page ES-2, December 2022, http://www.aqmd.gov/home/air-quality/clean-air-plans/air-quality-mgt-plan.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Criteria for determining consistency with the AQMPs are defined by the following indicators:
• Consistency Criterion No. 1: The Project will not result in an increase in the frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMPs.
• Consistency Criterion No. 2: The Project will not exceed the assumptions in the AQMPs or increments based on the years of the Project build-out phase.
According to the SCAQMD’s CEQA Air Quality Handbook, the purpose of the consistency finding is to determine if a project is inconsistent with the assumptions and objectives of the regional air quality plans, and thus if it would interfere with the region’s ability to comply with CAAQS and NAAQS.4 The violations to which Consistency Criterion No. 1 refers are exceedances of the CAAQS or NAAQS.
As shown below, the Project would not exceed the construction or operational standards. Therefore, the Project would not result in an increase in frequency or severity of existing air quality violations, or cause or contribute to new violations, or delay the timely attainment of air quality standards or the interim emissions reductions specified in the AQMPs. Thus, the Project would be consistent with the AQMP under the first criterion.
Concerning Consistency Criterion No. 2, the 2022 AQMP contains air pollutant reduction strategies based on SCAG’s growth forecasts included in the 2020-2045 RTP/SCS. SCAG’s growth forecasts are made in consultation with local governments and with reference to their local general plans. The Project is consistent with the City of Beverly Hills General Plan land use designation for the Project Site and, therefore, the growth associated with the Project at the Project Site has been accounted for in SCAG’s latest growth forecasts. The 2020–2045 RTP/SCS provides socioeconomic forecast projections of regional population growth. The population, housing, and employment forecasts, which are adopted by SCAG’s Regional Council, are based on the local plans and policies applicable to the specific area; these are used by SCAG in all phases of implementation and review.5 As shown below, the air pollutant emissions resulting from Project implementation would not exceed the SCAQMD localized significance thresholds. Localized significance thresholds were developed to ensure no exceedances of the California or federal ambient air quality standards would occur if project emissions were below thresholds.6 As the Project would not increase the frequency or severity of an existing air quality violation or cause or contribute to new violations for air quality pollutants (including VOC, NOX, CO, SOX, PM10, and PM2.5), the Project also would not delay timely attainment of air quality standards or interim emission reductions specified in the AQMP. In addition, the Project would be consistent with employment growth projections in the AQMP. 4 South Coast Air Quality Management District, CEQA Air Quality Handbook, 1993. 5 Southern California Association of Governments, Connect SoCal (2020–2045 RTP/SCS), adopted September 2020, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal-plan_0.pdf?1606001176. 6 South Coast Air Quality Management District, Localized Significance Thresholds, https://www.aqmd.gov/home/rulescompliance/ceqa/air-quality-analysis-handbook/localized-significance-thresholds.
Kimley»Horn
kimley-horn.com 660 South Figueroa Street, Suite 2050, Los Angeles, CA 90017 213 261 4040 Based on the above, approval of the Project would not result in any significant effects relating to a conflict with or obstruction of the implementation of the SCAQMD’s AQMP.
Conclusion
Project implementation would result in less than significant construction and operational air quality impacts. No mitigation measures would be required.
Kimley»Horn
Appendix A
CalEEMod Modeling Results
450 Roxbury Detailed Report, 7/2/2024
1 / 40
450 Roxbury Detailed Report
Table of Contents
1. Basic Project Information
1.1. Basic Project Information
1.2. Land Use Types
1.3. User-Selected Emission Reduction Measures by Emissions Sector
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds
2.2. Construction Emissions by Year, Unmitigated
2.4. Operations Emissions Compared Against Thresholds
2.5. Operations Emissions by Sector, Unmitigated
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
3.3. Building Construction (2025) - Unmitigated
3.5. Building Construction (2026) - Unmitigated
3.7. Architectural Coating (2026) - Unmitigated
450 Roxbury Detailed Report, 7/2/2024
2 / 40
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
4.3. Area Emissions by Source
4.3.1. Unmitigated
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
4.6. Refrigerant Emissions by Land Use
4.6.1. Unmitigated
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
4.8. Stationary Emissions By Equipment Type
450 Roxbury Detailed Report, 7/2/2024
3 / 40
4.8.1. Unmitigated
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated
5. Activity Data
5.1. Construction Schedule
5.2. Off-Road Equipment
5.2.1. Unmitigated
5.3. Construction Vehicles
5.3.1. Unmitigated
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
5.5. Architectural Coatings
5.6. Dust Mitigation
450 Roxbury Detailed Report, 7/2/2024
4 / 40
5.6.1. Construction Earthmoving Activities
5.6.2. Construction Earthmoving Control Strategies
5.7. Construction Paving
5.8. Construction Electricity Consumption and Emissions Factors
5.9. Operational Mobile Sources
5.9.1. Unmitigated
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
5.10.3. Landscape Equipment
5.11. Operational Energy Consumption
5.11.1. Unmitigated
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
5.13. Operational Waste Generation
5.13.1. Unmitigated
450 Roxbury Detailed Report, 7/2/2024
5 / 40
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
5.16.2. Process Boilers
5.17. User Defined
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
5.18.2. Sequestration
5.18.2.1. Unmitigated
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
450 Roxbury Detailed Report, 7/2/2024
6 / 40
6.2. Initial Climate Risk Scores
6.3. Adjusted Climate Risk Scores
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
7.2. Healthy Places Index Scores
7.3. Overall Health & Equity Scores
7.4. Health & Equity Measures
7.5. Evaluation Scorecard
7.6. Health & Equity Custom Measures
8. User Changes to Default Data
450 Roxbury Detailed Report, 7/2/2024
7 / 40
1. Basic Project Information
1.1. Basic Project Information
Data Field Value
Project Name 450 Roxbury
Construction Start Date 1/1/2025
Operational Year 2026
Lead Agency —
Land Use Scale Project/site
Analysis Level for Defaults County
Windspeed (m/s) 2.70
Precipitation (days) 19.6
Location 450 N Roxbury Dr, Beverly Hills, CA 90210, USA County Los Angeles-South Coast
City Beverly Hills
Air District South Coast AQMD
Air Basin South Coast
TAZ 4308
EDFZ 16
Electric Utility Southern California Edison
Gas Utility Southern California Gas
App Version 2022.1.1.25
1.2. Land Use Types
Land Use Subtype Size Unit Lot Acreage Building Area (sq ft) Landscape Area (sq ft)
Special Landscape
Area (sq ft)
Population Description
450 Roxbury Detailed Report, 7/2/2024
8 / 40
Strip Mall 6.80 1000sqft 0.16 6,797 0.00 — — —
Other Asphalt
Surfaces
0.07 1000sqft < 0.005 0.00 0.00 — — —
1.3. User-Selected Emission Reduction Measures by Emissions Sector No measures selected
2. Emissions Summary
2.1. Construction Emissions Compared Against Thresholds Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.63 0.53 5.19 7.11 0.01 0.22 0.04 0.26 0.20 0.01 0.21 — 1,370 1,370 0.06 0.02 0.21 1,377 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 3.30 3.27 5.19 7.09 0.01 0.22 0.19 0.35 0.20 0.04 0.21 — 1,369 1,369 0.06 0.02 0.02 1,375 Average
Daily
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.45 0.38 3.67 5.03 0.01 0.15 0.04 0.19 0.14 0.01 0.15 — 960 960 0.04 0.01 0.07 964 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.08 0.07 0.67 0.92 < 0.005 0.03 0.01 0.03 0.03 < 0.005 0.03 — 159 159 0.01 < 0.005 0.01 160
2.2. Construction Emissions by Year, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 450 Roxbury Detailed Report, 7/2/2024
9 / 40
Year TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily -
Summer
(Max)
— — — — — — — — — — — — — — — — — —
2025 0.63 0.53 5.19 7.11 0.01 0.22 0.04 0.26 0.20 0.01 0.21 — 1,370 1,370 0.06 0.02 0.21 1,377 Daily -
Winter
(Max)
— — — — — — — — — — — — — — — — — —
2025 0.63 0.53 5.19 7.09 0.01 0.22 0.19 0.35 0.20 0.04 0.21 — 1,369 1,369 0.06 0.02 0.02 1,375 2026 3.30 3.27 4.86 7.04 0.01 0.19 0.04 0.23 0.17 0.01 0.18 — 1,367 1,367 0.06 0.02 0.01 1,373 Average
Daily
— — — — — — — — — — — — — — — — — —
2025 0.45 0.38 3.67 5.03 0.01 0.15 0.04 0.19 0.14 0.01 0.15 — 960 960 0.04 0.01 0.07 964 2026 0.22 0.21 0.34 0.49 < 0.005 0.01 < 0.005 0.02 0.01 < 0.005 0.01 — 90.6 90.6 < 0.005 < 0.005 0.01 91.0 Annual — — — — — — — — — — — — — — — — — —
2025 0.08 0.07 0.67 0.92 < 0.005 0.03 0.01 0.03 0.03 < 0.005 0.03 — 159 159 0.01 < 0.005 0.01 160 2026 0.04 0.04 0.06 0.09 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 15.0 15.0 < 0.005 < 0.005 < 0.005 15.1
2.4. Operations Emissions Compared Against Thresholds
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Un/Mit. TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.47 1.37 0.77 8.88 0.02 0.01 1.77 1.78 0.01 0.45 0.46 4.81 2,059 2,064 0.60 0.09 6.67 2,111 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 1.41 1.30 0.84 8.03 0.02 0.01 1.77 1.78 0.01 0.45 0.46 4.81 1,976 1,981 0.60 0.09 0.21 2,023 450 Roxbury Detailed Report, 7/2/2024
10 / 40
Average — — — — — — — — — — — — — — — — — —
Daily
(Max)
Unmit. 1.43 1.33 0.85 8.42 0.02 0.01 1.75 1.76 0.01 0.44 0.46 4.81 1,999 2,003 0.60 0.09 2.90 2,048 Annual
(Max)
— — — — — — — — — — — — — — — — — —
Unmit. 0.26 0.24 0.15 1.54 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 0.80 331 332 0.10 0.01 0.48 339
2.5. Operations Emissions by Sector, Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Sector TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.26 1.16 0.76 8.58 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,979 1,979 0.11 0.08 6.63 2,013 Area 0.22 0.21 < 0.005 0.30 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.22 1.22 < 0.005 < 0.005 — 1.22 Energy < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 74.9 74.9 0.01 < 0.005 — 75.3 Water — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Waste — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Refrig. — — — — — — — — — — — — — — — — 0.04 0.04
Total 1.47 1.37 0.77 8.88 0.02 0.01 1.77 1.78 0.01 0.45 0.46 4.81 2,059 2,064 0.60 0.09 6.67 2,111 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Mobile 1.24 1.14 0.83 8.03 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,898 1,898 0.11 0.09 0.17 1,926 Area 0.16 0.16 — — — — — — — — — — — — — — — —
Energy < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 74.9 74.9 0.01 < 0.005 — 75.3 Water — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Waste — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Refrig. — — — — — — — — — — — — — — — — 0.04 0.04
450 Roxbury Detailed Report, 7/2/2024
11 / 40
Total 1.41 1.30 0.84 8.03 0.02 0.01 1.77 1.78 0.01 0.45 0.46 4.81 1,976 1,981 0.60 0.09 0.21 2,023 Average
Daily
— — — — — — — — — — — — — — — — — —
Mobile 1.23 1.13 0.84 8.21 0.02 0.01 1.75 1.76 0.01 0.44 0.46 — 1,920 1,920 0.11 0.09 2.86 1,951 Area 0.20 0.20 < 0.005 0.20 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.83 0.83 < 0.005 < 0.005 — 0.84 Energy < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 74.9 74.9 0.01 < 0.005 — 75.3 Water — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Waste — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Refrig. — — — — — — — — — — — — — — — — 0.04 0.04
Total 1.43 1.33 0.85 8.42 0.02 0.01 1.75 1.76 0.01 0.44 0.46 4.81 1,999 2,003 0.60 0.09 2.90 2,048 Annual — — — — — — — — — — — — — — — — — —
Mobile 0.23 0.21 0.15 1.50 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 — 318 318 0.02 0.01 0.47 323 Area 0.04 0.04 < 0.005 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.14 0.14 < 0.005 < 0.005 — 0.14 Energy < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 12.4 12.4 < 0.005 < 0.005 — 12.5 Water — — — — — — — — — — — 0.16 0.54 0.70 0.02 < 0.005 — 1.23 Waste — — — — — — — — — — — 0.64 0.00 0.64 0.06 0.00 — 2.23 Refrig. — — — — — — — — — — — — — — — — 0.01 0.01
Total 0.26 0.24 0.15 1.54 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 0.80 331 332 0.10 0.01 0.48 339
3. Construction Emissions Details
3.1. Demolition (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
12 / 40
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.56 0.47 4.33 5.65 0.01 0.16 — 0.16 0.14 — 0.14 — 852 852 0.03 0.01 — 855 Demolitio
n
— — — — — — 0.05 0.05 — 0.01 0.01 — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.04 0.03 0.27 0.36 < 0.005 0.01 — 0.01 0.01 — 0.01 — 53.7 53.7 < 0.005 < 0.005 — 53.9 Demolitio
n
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 8.89 8.89 < 0.005 < 0.005 — 8.92 Demolitio
n
— — — — — — < 0.005 < 0.005 — < 0.005 < 0.005 — — — — — — — Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.05 0.04 0.05 0.59 0.00 0.00 0.13 0.13 0.00 0.03 0.03 — 131 131 0.01 < 0.005 0.01 133 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 450 Roxbury Detailed Report, 7/2/2024
13 / 40
Hauling < 0.005 < 0.005 0.05 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 42.2 42.2 < 0.005 0.01 < 0.005 44.2 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.04 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 8.38 8.38 < 0.005 < 0.005 0.01 8.49 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.66 2.66 < 0.005 < 0.005 < 0.005 2.79 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.39 1.39 < 0.005 < 0.005 < 0.005 1.41 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.44 0.44 < 0.005 < 0.005 < 0.005 0.46
3.3. Building Construction (2025) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.62 0.52 5.14 6.94 0.01 0.22 — 0.22 0.20 — 0.20 — 1,305 1,305 0.05 0.01 — 1,309 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.62 0.52 5.14 6.94 0.01 0.22 — 0.22 0.20 — 0.20 — 1,305 1,305 0.05 0.01 — 1,309 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
14 / 40
Off-Road
Equipment
0.40 0.34 3.36 4.54 0.01 0.14 — 0.14 0.13 — 0.13 — 853 853 0.03 0.01 — 856 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.07 0.06 0.61 0.83 < 0.005 0.03 — 0.03 0.02 — 0.02 — 141 141 0.01 < 0.005 — 142 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.15 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 30.1 30.1 < 0.005 < 0.005 0.11 30.5 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 35.3 35.3 < 0.005 < 0.005 0.10 37.0 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.13 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 28.5 28.5 < 0.005 < 0.005 < 0.005 28.9 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 35.4 35.4 < 0.005 < 0.005 < 0.005 36.9 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker 0.01 0.01 0.01 0.09 0.00 0.00 0.02 0.02 0.00 < 0.005 < 0.005 — 18.9 18.9 < 0.005 < 0.005 0.03 19.2 Vendor < 0.005 < 0.005 0.03 0.01 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 23.1 23.1 < 0.005 < 0.005 0.03 24.1 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 3.13 3.13 < 0.005 < 0.005 0.01 3.17 Vendor < 0.005 < 0.005 0.01 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 3.83 3.83 < 0.005 < 0.005 < 0.005 3.99 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 450 Roxbury Detailed Report, 7/2/2024
15 / 40
3.5. Building Construction (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.59 0.49 4.81 6.91 0.01 0.19 — 0.19 0.17 — 0.17 — 1,304 1,304 0.05 0.01 — 1,309 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.04 0.03 0.29 0.42 < 0.005 0.01 — 0.01 0.01 — 0.01 — 79.1 79.1 < 0.005 < 0.005 — 79.4 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.01 0.05 0.08 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 13.1 13.1 < 0.005 < 0.005 — 13.1 Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
16 / 40
Worker 0.01 0.01 0.01 0.12 0.00 0.00 0.03 0.03 0.00 0.01 0.01 — 27.9 27.9 < 0.005 < 0.005 < 0.005 28.3 Vendor < 0.005 < 0.005 0.04 0.02 < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 < 0.005 — 34.7 34.7 < 0.005 < 0.005 < 0.005 36.3 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.01 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 1.72 1.72 < 0.005 < 0.005 < 0.005 1.74 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 2.11 2.11 < 0.005 < 0.005 < 0.005 2.20 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.28 0.28 < 0.005 < 0.005 < 0.005 0.29 Vendor < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — 0.35 0.35 < 0.005 < 0.005 < 0.005 0.36 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
3.7. Architectural Coating (2026) - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Location TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Onsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.15 0.12 0.86 1.13 < 0.005 0.02 — 0.02 0.02 — 0.02 — 134 134 0.01 < 0.005 — 134 Architect
ural
Coatings
3.15 3.15 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 450 Roxbury Detailed Report, 7/2/2024
17 / 40
Average
Daily
— — — — — — — — — — — — — — — — — —
Off-Road
Equipment
0.01 0.01 0.05 0.06 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 7.32 7.32 < 0.005 < 0.005 — 7.34 Architect
ural
Coatings
0.17 0.17 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
Off-Road
Equipment
< 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.21 1.21 < 0.005 < 0.005 — 1.22 Architect
ural
Coatings
0.03 0.03 — — — — — — — — — — — — — — — —
Onsite
truck
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Offsite — — — — — — — — — — — — — — — — — —
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 0.02 0.00 0.00 0.01 0.01 0.00 < 0.005 < 0.005 — 5.59 5.59 < 0.005 < 0.005 < 0.005 5.66 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Average
Daily
— — — — — — — — — — — — — — — — — —
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.31 0.31 < 0.005 < 0.005 < 0.005 0.31 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Annual — — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
18 / 40
Worker < 0.005 < 0.005 < 0.005 < 0.005 0.00 0.00 < 0.005 < 0.005 0.00 < 0.005 < 0.005 — 0.05 0.05 < 0.005 < 0.005 < 0.005 0.05 Vendor 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Hauling 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00
4. Operations Emissions Details
4.1. Mobile Emissions by Land Use
4.1.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall 1.26 1.16 0.76 8.58 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,979 1,979 0.11 0.08 6.63 2,013 Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.26 1.16 0.76 8.58 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,979 1,979 0.11 0.08 6.63 2,013 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall 1.24 1.14 0.83 8.03 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,898 1,898 0.11 0.09 0.17 1,926 Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Total 1.24 1.14 0.83 8.03 0.02 0.01 1.77 1.78 0.01 0.45 0.46 — 1,898 1,898 0.11 0.09 0.17 1,926 Annual — — — — — — — — — — — — — — — — — —
Strip Mall 0.23 0.21 0.15 1.50 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 — 318 318 0.02 0.01 0.47 323 450 Roxbury Detailed Report, 7/2/2024
19 / 40
Other 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 0.00 0.00 0.00 0.00 Asphalt
Surfaces
Total 0.23 0.21 0.15 1.50 < 0.005 < 0.005 0.32 0.32 < 0.005 0.08 0.08 — 318 318 0.02 0.01 0.47 323
4.2. Energy
4.2.1. Electricity Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — 64.2 64.2 0.01 < 0.005 — 64.6 Other
Asphalt
Surfaces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 64.2 64.2 0.01 < 0.005 — 64.6 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — 64.2 64.2 0.01 < 0.005 — 64.6 Other
Asphalt
Surfaces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — — 64.2 64.2 0.01 < 0.005 — 64.6 Annual — — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — 10.6 10.6 < 0.005 < 0.005 — 10.7 Other
Asphalt
Surfaces
— — — — — — — — — — — — 0.00 0.00 0.00 0.00 — 0.00
450 Roxbury Detailed Report, 7/2/2024
20 / 40
Total — — — — — — — — — — — — 10.6 10.6 < 0.005 < 0.005 — 10.7
4.2.3. Natural Gas Emissions By Land Use - Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 — 10.8 Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 — 10.8 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 — 10.8 Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total < 0.005 < 0.005 0.01 0.01 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 10.7 10.7 < 0.005 < 0.005 — 10.8 Annual — — — — — — — — — — — — — — — — — —
Strip Mall < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.78 1.78 < 0.005 < 0.005 — 1.78 Other
Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 — 0.00 0.00 — 0.00 — 0.00 0.00 0.00 0.00 — 0.00 Total < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.78 1.78 < 0.005 < 0.005 — 1.78
4.3. Area Emissions by Source
450 Roxbury Detailed Report, 7/2/2024
21 / 40
4.3.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Source TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Products
0.15 0.15 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
0.02 0.02 — — — — — — — — — — — — — — — —
Landsca
pe
Equipme
nt
0.05 0.05 < 0.005 0.30 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.22 1.22 < 0.005 < 0.005 — 1.22 Total 0.22 0.21 < 0.005 0.30 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 1.22 1.22 < 0.005 < 0.005 — 1.22 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Consum
er
Products
0.15 0.15 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
0.02 0.02 — — — — — — — — — — — — — — — —
Total 0.16 0.16 — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Consum
er
Products
0.03 0.03 — — — — — — — — — — — — — — — —
Architect
ural
Coatings
< 0.005 < 0.005 — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
22 / 40
Landsca
Equipment
0.01 0.01 < 0.005 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.14 0.14 < 0.005 < 0.005 — 0.14 Total 0.04 0.04 < 0.005 0.04 < 0.005 < 0.005 — < 0.005 < 0.005 — < 0.005 — 0.14 0.14 < 0.005 < 0.005 — 0.14
4.4. Water Emissions by Land Use
4.4.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.96 3.25 4.22 0.10 < 0.005 — 7.41 Annual — — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 0.16 0.54 0.70 0.02 < 0.005 — 1.23 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.16 0.54 0.70 0.02 < 0.005 — 1.23 450 Roxbury Detailed Report, 7/2/2024
23 / 40
4.5. Waste Emissions by Land Use
4.5.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 3.85 0.00 3.85 0.38 0.00 — 13.5 Annual — — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — 0.64 0.00 0.64 0.06 0.00 — 2.23 Other
Asphalt
Surfaces
— — — — — — — — — — — 0.00 0.00 0.00 0.00 0.00 — 0.00
Total — — — — — — — — — — — 0.64 0.00 0.64 0.06 0.00 — 2.23
4.6. Refrigerant Emissions by Land Use
450 Roxbury Detailed Report, 7/2/2024
24 / 40
4.6.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — — — — — 0.04 0.04
Total — — — — — — — — — — — — — — — — 0.04 0.04
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — — — — — 0.04 0.04
Total — — — — — — — — — — — — — — — — 0.04 0.04
Annual — — — — — — — — — — — — — — — — — —
Strip Mall — — — — — — — — — — — — — — — — 0.01 0.01
Total — — — — — — — — — — — — — — — — 0.01 0.01
4.7. Offroad Emissions By Equipment Type
4.7.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
25 / 40
Daily, — — — — — — — — — — — — — — — — — —
Winter
(Max)
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
4.8. Stationary Emissions By Equipment Type
4.8.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Equipme
nt
Type
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
4.9. User Defined Emissions By Equipment Type
4.9.1. Unmitigated
Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) 450 Roxbury Detailed Report, 7/2/2024
26 / 40
Equipme TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e nt
Type
Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
4.10. Soil Carbon Accumulation By Vegetation Type
4.10.1. Soil Carbon Accumulation By Vegetation Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Vegetatio
n
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
27 / 40
4.10.2. Above and Belowground Carbon Accumulation by Land Use Type - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Land
Use
TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Total — — — — — — — — — — — — — — — — — —
4.10.3. Avoided and Sequestered Emissions by Species - Unmitigated Criteria Pollutants (lb/day for daily, ton/yr for annual) and GHGs (lb/day for daily, MT/yr for annual) Species TOG ROG NOx CO SO2 PM10E PM10D PM10T PM2.5E PM2.5D PM2.5T BCO2 NBCO2 CO2T CH4 N2O R CO2e Daily,
Summer
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
450 Roxbury Detailed Report, 7/2/2024
28 / 40
Daily,
Winter
(Max)
— — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
Annual — — — — — — — — — — — — — — — — — —
Avoided — — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Sequest
ered
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
Remove
d
— — — — — — — — — — — — — — — — — —
Subtotal — — — — — — — — — — — — — — — — — —
— — — — — — — — — — — — — — — — — — —
5. Activity Data
5.1. Construction Schedule
Phase Name Phase Type Start Date End Date Days Per Week Work Days per Phase Phase Description Demolition Demolition 1/1/2025 1/31/2025 5.00 23.0 —
Building Construction Building Construction 2/1/2025 1/31/2026 5.00 260 — 450 Roxbury Detailed Report, 7/2/2024
29 / 40
Architectural Coating Architectural Coating 2/1/2026 3/1/2026 5.00 20.0 —
5.2. Off-Road Equipment
5.2.1. Unmitigated
Phase Name Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor Demolition Tractors/Loaders/Backh
oes
Diesel Average 2.00 6.00 84.0 0.37
Demolition Rubber Tired Dozers Diesel Average 1.00 1.00 367 0.40 Demolition Concrete/Industrial
Saws
Diesel Average 1.00 8.00 33.0 0.73
Building Construction Cranes Diesel Average 1.00 4.00 367 0.29 Building Construction Forklifts Diesel Average 2.00 6.00 82.0 0.20 Building Construction Tractors/Loaders/Backh
oes
Diesel Average 2.00 8.00 84.0 0.37
Architectural Coating Air Compressors Diesel Average 1.00 6.00 37.0 0.48
5.3. Construction Vehicles
5.3.1. Unmitigated
Phase Name Trip Type One-Way Trips per Day Miles per Trip Vehicle Mix Demolition — — — —
Demolition Worker 10.0 18.5 LDA,LDT1,LDT2
Demolition Vendor — 10.2 HHDT,MHDT
Demolition Hauling 0.61 20.0 HHDT
Demolition Onsite truck — — HHDT
Building Construction — — — —
Building Construction Worker 2.18 18.5 LDA,LDT1,LDT2
450 Roxbury Detailed Report, 7/2/2024
30 / 40
Building Construction Vendor 1.11 10.2 HHDT,MHDT
Building Construction Hauling 0.00 20.0 HHDT
Building Construction Onsite truck — — HHDT
Architectural Coating — — — —
Architectural Coating Worker 0.44 18.5 LDA,LDT1,LDT2
Architectural Coating Vendor — 10.2 HHDT,MHDT
Architectural Coating Hauling 0.00 20.0 HHDT
Architectural Coating Onsite truck — — HHDT
5.4. Vehicles
5.4.1. Construction Vehicle Control Strategies
Non-applicable. No control strategies activated by user.
5.5. Architectural Coatings
Phase Name Residential Interior Area Coated
(sq ft)
Residential Exterior Area Coated
(sq ft)
Non-Residential Interior Area
Coated (sq ft)
Non-Residential Exterior Area
Coated (sq ft)
Parking Area Coated (sq ft)
Architectural Coating 0.00 0.00 10,196 3,399 4.50
5.6. Dust Mitigation
5.6.1. Construction Earthmoving Activities
Phase Name Material Imported (cy) Material Exported (cy) Acres Graded (acres) Material Demolished (Ton of Debris)
Acres Paved (acres)
Demolition 0.00 0.00 0.00 56.0 —
5.6.2. Construction Earthmoving Control Strategies
Non-applicable. No control strategies activated by user. 450 Roxbury Detailed Report, 7/2/2024
31 / 40
5.7. Construction Paving
Land Use Area Paved (acres) % Asphalt
Strip Mall 0.00 0%
Other Asphalt Surfaces < 0.005 100%
5.8. Construction Electricity Consumption and Emissions Factors kWh per Year and Emission Factor (lb/MWh)
Year kWh per Year CO2 CH4 N2O
2025 0.00 532 0.03 < 0.005
2026 0.00 532 0.03 < 0.005
5.9. Operational Mobile Sources
5.9.1. Unmitigated
Land Use Type Trips/Weekday Trips/Saturday Trips/Sunday Trips/Year VMT/Weekday VMT/Saturday VMT/Sunday VMT/Year Strip Mall 370 370 370 135,085 2,495 2,495 2,495 910,843 Other Asphalt
Surfaces
0.00 0.00 0.00 0.00 0.00 0.00 0.00 0.00
5.10. Operational Area Sources
5.10.1. Hearths
5.10.1.1. Unmitigated
5.10.2. Architectural Coatings
Residential Interior Area Coated (sq ft) Residential Exterior Area Coated (sq ft) Non-Residential Interior Area Coated (sq ft)
Non-Residential Exterior Area Coated
(sq ft)
Parking Area Coated (sq ft)
450 Roxbury Detailed Report, 7/2/2024
32 / 40
0 0.00 10,196 3,399 4.50
5.10.3. Landscape Equipment
Season Unit Value
Snow Days day/yr 0.00
Summer Days day/yr 250
5.11. Operational Energy Consumption
5.11.1. Unmitigated
Electricity (kWh/yr) and CO2 and CH4 and N2O and Natural Gas (kBTU/yr) Land Use Electricity (kWh/yr) CO2 CH4 N2O Natural Gas (kBTU/yr) Strip Mall 67,675 346 0.0330 0.0040 33,469
Other Asphalt Surfaces 0.00 346 0.0330 0.0040 0.00
5.12. Operational Water and Wastewater Consumption
5.12.1. Unmitigated
Land Use Indoor Water (gal/year) Outdoor Water (gal/year) Strip Mall 503,471 0.00
Other Asphalt Surfaces 0.00 0.00
5.13. Operational Waste Generation
5.13.1. Unmitigated
Land Use Waste (ton/year) Cogeneration (kWh/year)
Strip Mall 7.14 —
450 Roxbury Detailed Report, 7/2/2024
33 / 40
Other Asphalt Surfaces 0.00 —
5.14. Operational Refrigeration and Air Conditioning Equipment
5.14.1. Unmitigated
Land Use Type Equipment Type Refrigerant GWP Quantity (kg) Operations Leak Rate Service Leak Rate Times Serviced Strip Mall Other commercial A/C
and heat pumps
R-410A 2,088 < 0.005 4.00 4.00 18.0
Strip Mall Stand-alone retail
refrigerators and
freezers
R-134a 1,430 0.04 1.00 0.00 1.00
Strip Mall Walk-in refrigerators
and freezers
R-404A 3,922 < 0.005 7.50 7.50 20.0
5.15. Operational Off-Road Equipment
5.15.1. Unmitigated
Equipment Type Fuel Type Engine Tier Number per Day Hours Per Day Horsepower Load Factor
5.16. Stationary Sources
5.16.1. Emergency Generators and Fire Pumps
Equipment Type Fuel Type Number per Day Hours per Day Hours per Year Horsepower Load Factor
5.16.2. Process Boilers
Equipment Type Fuel Type Number Boiler Rating (MMBtu/hr) Daily Heat Input (MMBtu/day) Annual Heat Input (MMBtu/yr)
5.17. User Defined
450 Roxbury Detailed Report, 7/2/2024
34 / 40
Equipment Type Fuel Type
5.18. Vegetation
5.18.1. Land Use Change
5.18.1.1. Unmitigated
Vegetation Land Use Type Vegetation Soil Type Initial Acres Final Acres
5.18.1. Biomass Cover Type
5.18.1.1. Unmitigated
Biomass Cover Type Initial Acres Final Acres
5.18.2. Sequestration
5.18.2.1. Unmitigated
Tree Type Number Electricity Saved (kWh/year) Natural Gas Saved (btu/year)
6. Climate Risk Detailed Report
6.1. Climate Risk Summary
Cal-Adapt midcentury 2040–2059 average projections for four hazards are reported below for your project location. These are under Representation Concentration Pathway (RCP) 8.5 which assumes GHG emissions will continue to rise strongly through 2050 and then plateau around 2100.
Climate Hazard Result for Project Location Unit
Temperature and Extreme Heat 7.73 annual days of extreme heat Extreme Precipitation 7.05 annual days with precipitation above 20 mm Sea Level Rise — meters of inundation depth
450 Roxbury Detailed Report, 7/2/2024
35 / 40
Wildfire 0.30 annual hectares burned
Temperature and Extreme Heat data are for grid cell in which your project are located. The projection is based on the 98th historical percentile of daily maximum/minimum temperatures from observed historical data (32 climate model ensemble from Cal-Adapt, 2040–2059 average under RCP 8.5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Extreme Precipitation data are for the grid cell in which your project are located. The threshold of 20 mm is equivalent to about ¾ an inch of rain, which would be light to moderate rainfall if received over a full day or heavy rain if received over a period of 2 to 4 hours. Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
Sea Level Rise data are for the grid cell in which your project are located. The projections are from Radke et al. (2017), as reported in Cal-Adapt (Radke et al., 2017, CEC-500-2017-008), and consider inundation location and depth for the San Francisco Bay, the Sacramento-San Joaquin River Delta and California coast resulting different increments of sea level rise coupled with extreme storm events.
Users may select from four scenarios to view the range in potential inundation depth for the grid cell. The four scenarios are: No rise, 0.5 meter, 1.0 meter, 1.41 meters Wildfire data are for the grid cell in which your project are located. The projections are from UC Davis, as reported in Cal-Adapt (2040–2059 average under RCP 8.5), and consider historical data of climate, vegetation, population density, and large (> 400 ha) fire history. Users may select from four model simulations to view the range in potential wildfire probabilities for the grid cell. The four simulations make different assumptions about expected rainfall and temperature are: Warmer/drier (HadGEM2-ES), Cooler/wetter (CNRM-CM5), Average conditions (CanESM2), Range of different rainfall and temperature possibilities (MIROC5). Each grid cell is 6 kilometers (km) by 6 km, or 3.7 miles (mi) by 3.7 mi.
6.2. Initial Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 0 0 N/A
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 0 0 N/A
Wildfire 1 0 0 N/A
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 0 0 0 N/A
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores do not include implementation of climate risk reduction measures.
6.3. Adjusted Climate Risk Scores
Climate Hazard Exposure Score Sensitivity Score Adaptive Capacity Score Vulnerability Score Temperature and Extreme Heat 1 1 1 2
450 Roxbury Detailed Report, 7/2/2024
36 / 40
Extreme Precipitation N/A N/A N/A N/A
Sea Level Rise 1 1 1 2
Wildfire 1 1 1 2
Flooding N/A N/A N/A N/A
Drought N/A N/A N/A N/A
Snowpack Reduction N/A N/A N/A N/A
Air Quality Degradation 1 1 1 2
The sensitivity score reflects the extent to which a project would be adversely affected by exposure to a climate hazard. Exposure is rated on a scale of 1 to 5, with a score of 5 representing the greatest exposure.
The adaptive capacity of a project refers to its ability to manage and reduce vulnerabilities from projected climate hazards. Adaptive capacity is rated on a scale of 1 to 5, with a score of 5 representing the greatest ability to adapt.
The overall vulnerability scores are calculated based on the potential impacts and adaptive capacity assessments for each hazard. Scores include implementation of climate risk reduction measures.
6.4. Climate Risk Reduction Measures
7. Health and Equity Details
7.1. CalEnviroScreen 4.0 Scores
The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state.
Indicator Result for Project Census Tract
Exposure Indicators —
AQ-Ozone 58.2
AQ-PM 69.7
AQ-DPM 73.3
Drinking Water 49.6
Lead Risk Housing 26.7
Pesticides 0.00
Toxic Releases 74.0
Traffic 60.7
450 Roxbury Detailed Report, 7/2/2024
37 / 40
Effect Indicators —
CleanUp Sites 80.3
Groundwater 22.1
Haz Waste Facilities/Generators 66.6
Impaired Water Bodies 0.00
Solid Waste 93.7
Sensitive Population —
Asthma 4.45
Cardio-vascular 18.3
Low Birth Weights 3.40
Socioeconomic Factor Indicators —
Education 25.9
Housing 87.0
Linguistic 87.0
Poverty 33.8
Unemployment 70.9
7.2. Healthy Places Index Scores
The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
Indicator Result for Project Census Tract
Economic —
Above Poverty 68.24072886
Employed 40.65186706
Median HI 72.46246632
Education —
Bachelor's or higher 74.51559091
High school enrollment 4.709354549
450 Roxbury Detailed Report, 7/2/2024
38 / 40
Preschool enrollment 67.02168613
Transportation —
Auto Access 11.40767355
Active commuting 55.1777236
Social —
2-parent households 85.42281535
Voting 30.52739638
Neighborhood —
Alcohol availability 22.08392147
Park access 17.55421532
Retail density 98.83228538
Supermarket access 87.86090081
Tree canopy 61.15744899
Housing —
Homeownership 17.77235981
Housing habitability 14.69267291
Low-inc homeowner severe housing cost burden 3.464647761 Low-inc renter severe housing cost burden 49.04401386
Uncrowded housing 62.10701912
Health Outcomes —
Insured adults 74.51559091
Arthritis 0.0
Asthma ER Admissions 95.8
High Blood Pressure 0.0
Cancer (excluding skin) 0.0
Asthma 0.0
Coronary Heart Disease 0.0
450 Roxbury Detailed Report, 7/2/2024
39 / 40
Chronic Obstructive Pulmonary Disease 0.0
Diagnosed Diabetes 0.0
Life Expectancy at Birth 92.8
Cognitively Disabled 20.1
Physically Disabled 5.6
Heart Attack ER Admissions 85.8
Mental Health Not Good 0.0
Chronic Kidney Disease 0.0
Obesity 0.0
Pedestrian Injuries 68.9
Physical Health Not Good 0.0
Stroke 0.0
Health Risk Behaviors—
Binge Drinking 0.0
Current Smoker 0.0
No Leisure Time for Physical Activity 0.0
Climate Change Exposures—
Wildfire Risk 0.0
SLR Inundation Area 0.0
Children 90.2
Elderly 3.7
English Speaking 10.3
Foreign-born 93.1
Outdoor Workers 95.0
Climate Change Adaptive Capacity—
Impervious Surface Cover 17.3
Traffic Density 77.2
450 Roxbury Detailed Report, 7/2/2024
40 / 40
Traffic Access 87.4
Other Indices —
Hardship 42.9
Other Decision Support —
2016 Voting 29.1
7.3. Overall Health & Equity Scores
Metric Result for Project Census Tract
CalEnviroScreen 4.0 Score for Project Location (a) 44.0 Healthy Places Index Score for Project Location (b) 49.0 Project Located in a Designated Disadvantaged Community (Senate Bill 535) No Project Located in a Low-Income Community (Assembly Bill 1550) No Project Located in a Community Air Protection Program Community (Assembly Bill 617) No a: The maximum CalEnviroScreen score is 100. A high score (i.e., greater than 50) reflects a higher pollution burden compared to other census tracts in the state. b: The maximum Health Places Index score is 100. A high score (i.e., greater than 50) reflects healthier community conditions compared to other census tracts in the state.
7.4. Health & Equity Measures
No Health & Equity Measures selected.
7.5. Evaluation Scorecard
Health & Equity Evaluation Scorecard not completed.
7.6. Health & Equity Custom Measures
No Health & Equity Custom Measures created.
8. User Changes to Default Data
Screen Justification
Construction: Construction Phases No site prep, grading, or paving; using provided construction total length of 14 months Operations: Vehicle Data Based on project trip generation Appendix B
Historic Resources Assessment and Peer Review
Kimley»Horn
450 N. Roxbury Drive
Historical Resource Assessment and Project Impacts Analysis Prepared for:
Glaser Weil
Prepared by:
Architectural Resources Group
Los Angeles, CA
April 23, 2024
a I ‘ 1
A-111/11 Inili /l
///'
I
ll /I
III'11 nil h
I
25 Architectural
Resources Group
■i“8A
hil
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP i
TABLE OF CONTENTS
1. Introduction .......................................................................................................................................... 1
1.1 Executive Summary ........................................................................................................................ 1
1.2 Methodology .................................................................................................................................. 2
1.3 Preparer Qualifications .................................................................................................................. 2
2. Property Description and Development ................................................................................................ 3
2.1 General Setting ............................................................................................................................... 3
2.2 Office Building ................................................................................................................................ 4
2.3 Parking Garage ............................................................................................................................... 5
2.4 Chronology of Development and Use ............................................................................................ 8
3. Historical Background and Context ..................................................................................................... 13
3.1 Commercial Development of Beverly Hills .................................................................................. 13
3.2 Architecture .................................................................................................................................. 15
3.3 Ownership History ........................................................................................................................ 17
4. Regulatory Framework ........................................................................................................................ 19
4.1 Definition of Historical Resources ................................................................................................ 19
4.2 Federal, State, and Local Evaluation Criteria ............................................................................... 19
5. Evaluation of Historical Significance .................................................................................................... 24
5.1 Previous Evaluations and Studies ................................................................................................. 24
5.2 Evaluation of Significance ............................................................................................................ 24
6. Impacts Analysis .................................................................................................................................. 28
6.1 Summary of Historical Resource Findings .................................................................................... 28
6.2 Significance Threshold .................................................................................................................. 28
6.3 Project Description ....................................................................................................................... 29
6.4 Analysis of Project Impacts .......................................................................................................... 29
6.5 Summary of Continued Eligibility ................................................................................................. 30
7. Conclusion ........................................................................................................................................... 31
8. Bibliography ........................................................................................................................................ 32 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 1
1. Introduction
1.1 Executive Summary
At the request of Glaser Weil, Architectural Resources Group (ARG) has prepared this Historical Resource Assessment and Project Impacts Analysis for the proposed project (“the Project”) located at 450 N.
Roxbury Drive (APN: 4343‐024‐020), Beverly Hills, California. The Project Site (or “the Site”) is developed with a high‐rise office building and attached parking garage. Constructed in 1970, the building and parking garage were originally owned and occupied by Kaplan, Livingston, Goodwin, Berkowitz, and Selvin, a now‐defunct entertainment law firm. The property is currently owned by Starpoint Properties.
The office building and attached parking garage are not formally designated under federal (National Register of Historic Places), state (California Register of Historical Resources), or local (Beverly Hills Historic Preservation Ordinance) registration criteria. Furthermore, they do not appear to have been identified in the Beverly Hills Historic Resources Survey (Johnson Heumann Research Associates, 1985‐ 1986), the Historic Resources Survey Update of Survey Area 5: Commercial Properties (Jones & Stokes, 2006‐2007), or any other historic resource evaluation or survey. The property is not listed in California’s Built Environment Resource Directory (BERD).
In a Beverly Hills Architectural Commission Report prepared by City Planning staff on April 17, 2019, the subject property is noted as a potentially eligible historic resource. The report states that “The building appears to be an eligible historic resource as a potential contributor to an eligible post‐war historic commercial district…”1
The report does not provide information related to the boundaries of the district, when or how the district was identified, or under which registration criteria or level of significance (National Register, California Register, Beverly Hills Register) the district is eligible for designation.
The Project includes the rehabilitation of a portion of the parking garage for use as retail space. Four retail storefronts totaling approximately 6,797 square feet would be added in the south half of the ground floor level of the parking garage. Four of the garage bays would be altered to accommodate four glazed storefront assemblies fronting Roxbury Drive. Vehicular entries/exits at the east and west ends of the garage would be retained, as would parking spaces in the north half of the ground floor level, the two below‐ground levels, the second floor above‐ground level, and the roof level. See Section 6.3 for a more detailed description of the Project.
The purpose of this report is to fulfill the requirements of the California Environmental Quality Act (CEQA) as they relate to historical resources. CEQA states that “a project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.”2
An evaluation of potential impacts under CEQA includes both a determination of whether, and the extent to which, historical resources as defined by CEQA are present on and adjacent to the Site and, if so, the identification of potential impacts to historical resources caused by the Project.
Upon more in depth, property‐specific research conducted in preparation for this HRA, it is ARG’s professional opinion that the property at 450 N. Roxbury Drive is not eligible for listing in the National 1 City of Beverly Hills Planning Division, Beverly Hills Architectural Commission Report: 450 North Roxbury Drive, April 17, 2019. 2 California Public Resources Code, Section 21084.1. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 2
Register, California Register, or Beverly Hills Local Register of Historic Properties. However, given the 2019 staff report finding that the property is a potential contributor to an eligible postwar commercial historic district, ARG is conservatively treating the district as a historical resource under the California Environmental Quality Act (CEQA).
Thus, ARG conducted an analysis of the Project and evaluated its potential to impact historical resources.
ARG finds that the Project would not have a significant impact on historical resources, or the subject property’s potential eligibility as a district contributor.
1.2 Methodology
For the preparation of this report, ARG performed the following tasks for research, documentation, and analysis:
Visited the site on February 7, 2024 to assess existing conditions and document the property’s exterior and first floor lobby with digital photographs; Reviewed state and local technical bulletins, ordinances, and other materials related to the evaluation of historical resources;
Conducted primary and secondary source research related to the history of the building; Developed applicable historic contexts and themes; and Evaluated the property against eligibility criteria of the National Register, California Register, and the City of Beverly Hills Historic Preservation Ordinance. Reviewed the Project and evaluated its potential to impact historical resources under CEQA.
ARG staff consulted the following archives and repositories as part of our research for this assessment:
the Los Angeles Public Library; the archives of the Los Angeles Times and other local periodicals; drawings and building permits obtained from the City of Beverly Hills’s Community Development Department; online repositories; and ARG’s in‐house collection of architectural books and reference materials. A complete list of sources is included at the end of this report.
1.3 Preparer Qualifications
This report was prepared by Katie Horak, Principal; Evanne St. Charles, Senior Associate; and Sydney Landers, all of whom meet the Secretary of the Interior’s Professional Qualifications Standards, 36 CFR Part 61, in the discipline of Architectural History.3
3 National Park Service, “Professional Qualifications Standards,” accessed February 2024, https://www.nps.gov/articles/sec‐ standards‐prof‐quals.htm.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 3
2. Property Description and Development
2.1 General Setting
The property at 450 N. Roxbury is located two blocks or so northeast of the intersection of Wilshire and Santa Monica boulevards, in the main commercial shopping district of Beverly Hills (known as the “commercial triangle” or “golden triangle”). Development in the vicinity consists of low‐scale restaurant, retail, and office buildings, along with a handful of large hotel and office towers, primarily situated along Santa Monica and Wilshire. Blocks to the north of Santa Monica Boulevard are residential in character and generally lower in scale. The surrounding grid pattern is skewed at a 45‐degree angle to the cardinal directions, and the topography is flat.
The subject property consists of a rectangular parcel at the southeast corner of Santa Monica Boulevard and North Roxbury Drive. An alley (Bram Goldsmith Way) borders the parcel to the east, and another commercial building is located directly to the south.
General location map. The general location of the subject property is delineated by a dashed red line (Google Maps, 2024; annotations by ARG).
-elet IT.7.pme 1I
1 “IME
raran
2 . P
Di
I euhi
• i a S," i
W
4-4
4 I —
y
) I
f
■ rs
u- > ■ Te
&
0 t
5$t a 0 O
JRE le/
( CV
1. n Al
Si?
)
rjf. C
..
s
y.
7 )
2 kJ
22 e ♦R
aw
e
)
4a
J:P . emd .
9 /< ovec 4
Ks D
a “
-<
93 PWet
%
e -svy
4 55tW
12$72. w.iAss $ g.. 5e
1 ■;
i?
“—1,
• - o-e eni - T—ct "2 V • «
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 4
Parcel map. The boundaries of the subject property are delineated by a dashed red line (Google Maps, 2024; annotations by ARG).
2.2 Office Building
The subject property contains a ten‐story mixed‐use office building, with retail tenants on the ground floor and office and medical suites on the rest of the floors. A five‐level, partially subterranean parking structure (the upper two levels are above ground) with rooftop parking is attached to the south side of the building. The building was constructed in 1970 and represents a modest and late interpretation of the Corporate International style. It is rectangular in plan and sits flush with the sidewalk on its street‐facing sides. Both the building and parking structure are constructed of steel framing with concrete foundations.
The building is capped by a flat roof with a flat parapet. A plaster‐enclosed mechanical penthouse sits at the center of the roof. Exterior walls are painted concrete. The building features a rhythmic pattern of rectangular solar tinted, fixed windows divided by triangular pilasters starting at the second floor.
Concrete spandrel panels separate the windows between each floor, and a wide concrete frieze wraps around the building, dividing the first/ground story from the upper stories. The second through tenth floors are identical at all façades.
The primary façade of the building faces west, toward North Roxbury Drive, and is symmetrical in composition (aside from the retail storefronts on the first/ground story). The façade’s double‐height ground story is recessed behind four thick triangular columns and features a central entrance accessed by non‐original limestone paving and steps with steel handrails (original paving and steps were terrazzo).4 An
non‐original accessible ramp is directly to the north of the entrance. The main entrance comprises a pair of non‐original clear tempered glass double doors framed by fixed clear glazing above and on each side (original doors and surrounding glazing had dark aluminum frames). On each side of the entrance are 4 Limestone pavers and steel handrails were installed in 2006, according to specifications in the City of Beverly Hills Department of Community Development, Architectural Commission, Staff Report No. PL0606936. -L s C
(x. AYe
4 s’e . ■ bs ' ->
9 [ srr he e
>.%
7 r
2 4
— “he t
»
r I k te
% Wilshire Boulevard
22058
I
2 - >
.5
.Su
7 r
6 74
gt
of
r
—
500
y %
u
__ L
, wre ate <
.”g wes • *
"t
y
—
ree
r
M
n
4 3
K. *
2 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 5
floor‐to‐ceiling fixed windows with dark aluminum frames. The windows to the south of the entry have narrower mullions and appear to be replacements. A single metal slab door sits at the south end of the façade. Identical rows of fixed windows delineated by triangular pilasters line the upper stories.
The north façade fronts Santa Monica Boulevard. The façade’s double‐height ground story features seven bays divided by thick triangular columns. Two bays at the east end are clad in marble panels. The middle four bays are composed of fixed floor‐to‐ceiling windows with dark aluminum frames (some windows appear to be replacements given their thinner mullion profiles). The bay at the west end is composed of a non‐historic bank storefront with fully glazed metal double doors and surrounding glazing. The second through tenth floors of the north façade are identical to the west, east, and south façades.
The building’s rear (east) façade fronts an alley (Bram Goldsmith Way). The ground story is clad in concrete panels with a single vent and fire exit opening at the south end. The south end directly abuts the parking structure’s rear vehicular exit. The upper stories are nearly identical to the west and north façades, with the exception being that windows are triple rather than single light.
The ground story of the south façade directly abuts the parking structure and is obscured from the exterior. The second through tenth floors are identical in motif to the west, north, and east façades.
There are a handful of ventilation louvers that have been added to second and fifth floor window openings.
2.3 Parking Garage
The office building’s parking structure is two stories in height, with two levels of below‐ground parking.
The structure’s primary (west) façade fronts North Roxbury Drive. It is capped by a flat roof with a flat parapet wall concealing rooftop parking. The façade features two vehicular openings on the north and south ends. Both openings are accessed by curb cuts. The north end opening is double height and features entry and exit lanes, divided by a concrete median and parking barrier gates. The south end opening is single height with the upper level concealed by an aluminum screen featuring a vertically oriented, decorative diamond pattern (described as a “dragon” pattern on original drawings). A small, punched opening is located at the top corner of the screen. The south vehicular opening is divided by a concrete column and parking barrier gates between the entry and exit lanes. Four bays sit between the north and south vehicular entrances and are clad in aluminum screens with the same diamond pattern as seen over the south entry. Canted concrete planters sit at the base of each bay. Rectangular trellises covered in vines are installed in the planters in front of the aluminum screens. The bay abutting the north end opening includes a single metal slab door with a cut into the planter for accessibility. There is another canted concrete planter at the south end of the structure.
The rear (east) façade fronts an alley. The façade features two openings, a large vehicular opening at the north end and a pedestrian entrance to the south of the vehicular opening (the pedestrian entrance replaced a smaller screened rectangular opening at an unknown date). The vehicular opening is double height and features one lane for exiting, denoted by a concrete median and parking barrier gate. The pedestrian entrance is recessed and has two concrete steps accompanied by a metal railing. Original screened openings to each side of the pedestrian entrance have been infilled with concrete panels and metal vents. The rest of the façade is composed of two rows of square openings enclosed with decorative aluminum screens, akin to the screens on the primary (west) façade, but smaller. The north side of the Impacts Analysis April 23, 2024 nt and Project esource Assessme 450 N. Roxbury Drive Historical R 6 ARCHITECTURAL RESOURCES GROUP
çade faces an adjacent commercial building parking garage is attached to the office building. The south fa and is devoid of fenestration.
Existing Conditions Photographs
(ARG, east view façades, (west) primary and North
2024).
façade, south the of levels upper and (west) Primary
view north (ARG, 2024).
view façade, north of end west at storefront Bank 2024). (ARG, alley the from façade (east) Rear southeast (ARG, 2024).
end, east at bays panel marble floor, first façade North view southeast (ARG, 2024).
(ARG, entrance main of close‐up façade, Primary
2024).
-
HEHHMHHHHHHHIHHID.
1EMHHEHHEEI“III
w Me
W
/ MMHIIlll" /
- a I
"‘u I h]
1,
11 I H III*
sh Juj
i
I
2=41 1
!
»Bli|
m =a
uo.
thua Min
HMnHHl"""
..........
4 (IIIIIIII"""
JIIII!!""
4 _ sill:
fm
/
/,
bn"".'
. J W s <A
t 99 ‘ A
\ i
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 7
View east into the first floor main lobby (ARG, 2024). Interior detail of the first floor main lobby (ARG, 2024).
Primary (west) façade of the parking structure, view
southeast (ARG, 2024).
Primary façade of the parking structure, detail, view
northeast (ARG, 2024).
Primary (west) façade of parking structure, south
entrance/exit, view southeast (ARG, 2024).
Rear (east) façade of the parking structure, view
northwest (ARG, 2024).
7 1 $
1 ■■
(
I
Ms
s . J
sen”
TT
____
SNNNN
WNNN
e ‘
i::
U.
Iv
A
N
1 i
a - a
:
E.
=m-- ."s— l
m
MK
1882288882337
WSEEKMNNNEE
YERYYXKKE.
yyyyyy
!
I
■
-
■
' s.
i
H
s
4 M■
i
|
EEB
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 8
2.4 Chronology of Development and Use
The following is a chronology of development and use of the property. Source materials include online building permits from the City of Beverly Hills Community Development Department, historic newspaper articles, and historic photographs.
1969 A permit was pulled for the construction of a 10‐story office building. The original building permit lists the owner as the entertainment law firm Kaplan, Livingston, Goodwin, Berkowitz, and Selvin.5
Sheldon L. Pollack Co. is listed as builder and engineer, with staff architect Norbert W. Pieper responsible for the design.6 A second permit was issued for the construction of a “garage above and below street levels” to the south of the office building that can hold 382 cars.7 The permits lists the
same owner, architect, engineer, and contractor.8
1970 Newspapers suggest that the building was substantially completed and occupied by 1970.
Most building inspections were signed off by late 1970, with large TI permits being issued from 1970 until 1972.9
Early 1970s Based on early permit records and historic newspapers, the building’s early major occupants included Kaplan, Livingston, Goodwin, Berkowitz, and Selvin (building owner); the oil and gas law firm Ball, Hart, Hunt, Brown & Baerwitz; and Merrill Lynch; and Time, Inc (Time magazine).10 Other original tenants included law, realty, and financial companies.
1970s‐present The building has undergone numerous phases of interior tenant improvements on all floors, beginning in the 1970s. Some interior spaces have also undergone change of use from office to medical.11
1979 A permit was issued for minor structural demolition work at the roof level of the parking structure.12
1983 A permit was issued for reroofing of the building.13 A permit was issued to construct a storage room in the parking structure, eliminating two parking spaces.14
5 City of Beverly Hills Department of Building & Safety Permit No. 690137. 6 Sheldon L. Pollack Corp, “Office Building for Kaplan, Livingston, Goodwin, Berkowitz & Selvin,” Original Drawing Set from Permit No. 690137, 1969.
7 “$8.3 Million Placed on Three Buildings,” Los Angeles Times, April 9, 1972, 152. 8 City of Beverly Hills Department of Building & Safety Permit No. 8320. 9 City of Beverly Hills Department of Building & Safety, various permits; Merrill Lynch advertisement, Los Angeles Times, October 5, 1970.
10 City of Beverly Hills Department of Building & Safety Permit No. 441051, 439760 and 700505; “Our business is to help people make their money grow,” Los Angeles Times, June 24, 1970, 60. 11 City of Beverly Hills Department of Building & Safety, various permits. 12 City of Beverly Hills Department of Building & Safety Permit No. 693361. 13 City of Beverly Hills Department of Building & Safety Permit No. 831204. 14 City of Beverly Hills Department of Building & Safety Permit No. 830765. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 9
1984 Kaplan, Livingston, Goodwin, Berkowitz, and Selvin sold the building to Beverly Hills Federal Savings & Loan for $20 Million.15
1985 Beverly Hills Federal Savings & Loan sold the building to construction and building management company Koll Co. for $22.5 Million. Koll Co. leased the top two floors to United Artists for their corporate headquarters. 16
1991 Numerous permits were issued for a building‐wide retrofit to comply with Title 24 and the city’s high‐rise ordinance, resulting in the substantial remodeling of interior floors.
Homat Properties is listed as the owner. Permits list noted architect Gin Wong Associates as the architect.17
A permit was issued to remodel the parking structure. Gin Wong Associates is listed as the architect.18 (The extent of the parking structure remodel is unknown; however, based on a comparison of original drawings and current conditions, changes appeared to have been minor.)
1992 A permit was issued for window wall alignment and new tempered glass on the first floor (the extent of glazing replacement is unclear).19
2005 A permit was issued to install four ventilation louvers into exterior windows on the second floor of the (secondary) south façade.20
A permit was issued to remove broken concrete and replace the driveway in‐kind.21 A permit was issued for a renovation of the main lobby, extending the soffit ceiling, new flooring, new wall finishes and a new security desk.22 From visual observation at ARG’s site visit, any traces of Gin Wong’s 1991 renovation (including patterned tile flooring) were removed, and replaced.23
2006 Based on photos and permits on file with the Beverly Hills Community Development Department, the primary (west) façade was remodeled, including replacing the entry door (from existing double entry doors to clear tempered glass doors with stain stainless steel top and bottom plates), new limestone paving to match interior lobby, and new stainless steel railings.24
15 “Talk about a ‘hot property’,” Los Angeles Times, December 7, 1986, 192; “Beverly Hills Savings Moves,” Los Angeles Times, July 17, 1983, 147.
16 “Talk about a ‘hot property’,” Los Angeles Times; “Koll Co. Acquires Office Building,” Los Angeles Times, November 17, 1985, 194.
17 City of Beverly Hills Department of Building & Safety Permit No. C9102123. 18 City of Beverly Hills Department of Building & Safety Permit No. 91004989. 19 City of Beverly Hills Department of Building & Safety Permit No. 92002248. 20 City of Beverly Hills Department of Community Development, Architectural Review, Approval Letter No. PL0310281. 21 City of Beverly Hills Department of Building & Safety Permit No. BS0526482. 22 City of Beverly Hills Department of Building & Safety Permit No. BS0564518. 23 Gin Wong and Associates, “Ground Floor Entry & Lobby Floor Finish Pattern Plan,” dated 1991, drawing sourced from Lamprecht & Louden, “Historic Resource Assessment: Proposed Façade Remodeling, 450 North Roxbury Drive,” Prepared for the City of Beverly Hills Planning Department, 2019, 12.
24 City of Beverly Hills Department of Community Development, Architectural Commission, Staff Report No. PL0606936. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 10
An architectural review permit was issued for a façade remodel of the parking structure, including a new glass panel addition, replacing existing railing and adding new landscaping along Roxbury Drive.25
2009 A permit was issued for storefront alterations for a bank tenant.26 From visual observation and Google Streetview, it appears that the original storefront on the north façade (third bay from the east end) was infilled with fixed window glazing, and a new storefront was added to the last bay on the west end.
Ca. 2019 From visual observation and Google Streetview, it appears that the metal planting trellises were installed in the parking structure planter beds at some point between 2019 and 2021.
Historic Photos and Images
View northeast of the intersection of Santa Monica and Wilshire boulevards, 1972. The subject property is marked by red arrow (UCLA Digital Archives).
25 City of Beverly Hills Department of Community Development, Architectural Review Permit No. PL0606936. 26 City of Beverly Hills Department of Building & Safety Permit No. BS0903126.
L
"i =.
# EAMs. 11 A-Te . th
1 n e=Rs Fe - 2.
1 ,/)
r.
9 F
-—IIn,
s.
an
yas
sr.
.Shhhhhhhhh -
AAGAAAaaAn
Gev ■■ I Craft.)
1111*1*11
//
A
•art
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 11
View southeast of the intersection of Santa Monica Boulevard and Roxbury Drive, 1974. The subject property is on the left (photo by Ed Ruscha, Getty Research Institute).
View southeast of the subject property, 1974 (photo by Ed Ruscha, Getty Research Institute).
I
■
■■■■llllllllll -......-41.
IIII IllIIII IIII
llllllllll
il
li
II
H,
I
SH=*SHEEEEEH*mmmEmmem W wa
iliiiiINNHNHHNNN"lHiiiiiiiIN
Lar 3, -5. sEe.
4 ob Piit tt w) tYs pan FY oard , y W
•—-..-HHHM
innnn nunuunu
IIIIIIIII
‘‘ a
□
t
22291
V
I
3 11
3 i
4 D)
' 1-
ts
' g:
‘Ii ihh
e
N
Mt iti 1
mmes ■■
I
re
0 1 ==
•• ==
-1 2 ■■ • • m m
=
=ummui na immm
mmnma • m
—
9 r it
•mmsmmm. m n==.n 1mm
AL
M
L I । *
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 12
View southeast of the intersection of Santa Monica Boulevard and Roxbury Drive, 2007. The subject property is on the left (photo by Ed Ruscha, Getty Research Institute).
View southeast of the subject property, 2007 (photo by Ed Ruscha, Getty Research Institute). 11 %
1 I
EMI W
a
B ,
d
2"
J
nIIa
■ I! m
■■■■■■■I 1liiiIIIII IIIIIII|II
I III
III
#1l11111NIN
I
“ep
102
1 *.122 s,tes tAeo.
11 II
IIIIIII
nuuunun
yuuuunu
AA1-1AAAIH Nnnunun nuunuuu
15 55
dne-u . d..! Jmmaun n
Amus
I
nuuuuuuuununuuuuunun
nuuuunu
uuuuunu
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 13
3. Historical Background and Context
3.1 Commercial Development of Beverly Hills
The area that would become the City of Beverly Hills is centered on the junction of the Franklin, Coldwater, and Benedict Canyon drainages. This well‐watered locale was heavily used by prehistoric peoples and later inhabited by the Tongva (Gabrielino) tribe. This area was explored by New Spanish administrator Captain Gaspar de Portola in 1769, paving the way for colonists.27 Around 1822, the Mexican government granted the Rancho Rodeo de las Aguas to settlers Maria Rita Valdez and her husband Vicente Valdez, who used the area’s wetlands (cienegas) to water a 4,500 acre cattle ranch. The rancho passed through the hands of several other owners during the 19th century; some attempted to subdivide portions of the rancho for sale as small farms and even as a townsite, but met with failure.
The Rancho Rodeo de las Aguas saw a new burst of activity at the turn of the century, when the Amalgamated Oil Company hoped to exploit the land’s deeply buried oil reserves. When the oil proved inaccessible, the syndicate reorganized as the Rodeo Land and Water Company in 1906 and focused on subdividing the area currently bordered by Whittier Drive, Doheny Drive, Wilshire Boulevard, and the foothills above Sunset Boulevard as a real estate development. Prompted largely by concern over the water and school systems, residents voted to incorporate in 1914 and created the new City of Beverly Hills.28
Beverly Hills’s earliest commercial properties were constructed during its initial subdivision. The city’s first commercial building housed a grocery and butcher shop near the Pacific Electric station that was located at Canon Drive and Santa Monica Boulevard. In 1907, the Peck Building (demolished in the 1920s) was constructed by the Rodeo Land and Water Company at the southwest corner of Beverly Drive and Santa Monica Boulevard.29 In 1912, the Beverly Hills Hotel opened, attracting wealthy visitors and movie stars to the town. As Beverly Hills’s population did not increase significantly until the 1920s, commercial development continued at a leisurely pace through the first decades of the 20th century.
The 1920s real estate boom in Beverly Hills and throughout Southern California helped to spur commercial growth. In the late 1910s and early ‘20s, Hollywood celebrities such as Douglas Fairbanks, Mary Pickford, Will Rogers, Charlie Chaplin, and Gloria Swanson built their homes in the foothills above Sunset Boulevard.30 The city’s association with movie stars and the motion picture industry further attracted residents and new businesses. In 1923, the city’s Chamber of Commerce was formed in order to “promote the economic, commercial, industrial, civic and social welfare of the people of the City of Beverly Hills and vicinity.”31 Beverly Hills’s business district formed between Santa Monica Boulevard and the railroad tracks to the north, Rexford Drive to the east, and Wilshire Boulevard to the southwest. This 27 Marc Wanamaker, Early Beverly Hills (Charleston, SC: Arcadia Publishing, 2005), 7. 28 Beverly Hills Historical Society, “Beverly Hills, A Brief History,” accessed February 2024, http://www.beverlyhillshistoricalsociety.org/history.
29 Johnson Heumann Research Associates, Beverly Hills Historic Resources Survey, prepared for the City of Beverly Hills, 1985‐ 1986, 63.
30 PCR Services Corporation, Historic Resources Survey Report, Part I: Historic Resources Survey Update and Part II: Area 4 Multi‐ Family Residence Survey, prepared for the City of Beverly Hills, 2004, 12. 31 “History of the Chamber,” Beverly Hills Chamber of Commerce, accessed February 2024, http://www.beverlyhillschamber.com/pages/HistoryoftheChamber. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 14
area became known as the “commercial triangle” (sometimes referred to as the “golden triangle”). The city’s first business block was constructed in the 9400 block of Santa Monica Boulevard by J.L. Kennedy and William Canfield in the 1920s. Beverly Drive was the primary commercial corridor, home to a variety of businesses, including markets, clothiers, drug stores, and financial institutions. Between 1920 and 1934, over 200 commercial properties were constructed in Beverly Hills.32 By the 1920s, Santa Monica Boulevard had developed as a major thoroughfare, running through a significant portion of the city. Brick apartment houses and smaller Period Revival‐style commercial properties lined the two‐mile stretch of Santa Monica Boulevard through the city. Beverly Hills became home to several high‐end department stores and restaurants, including Saks Fifth Avenue, I. Magnin, the Beverly Hills Brown Derby, and Romanoff’s, the city’s most popular movie star dining establishment through the 1950s.33 By the mid‐1930s, large financial, retail, entertainment, and office buildings had been constructed, most of them in popular Moderne designs. The works of prominent local architects, including Parkinson and Parkinson, Walker and Eisen, Paul R. Williams, and S. Charles Lee comprised much of the city’s commercial building stock during this time period.34 As automobiles became mainstream in Southern California, Beverly Hills and other areas outside of downtown evolved into reputable commercial centers.
During the city’s population boom following World War II, Beverly Hills experienced a tremendous increase in commercial growth that redefined the landscape of major thoroughfares such as Wilshire and Santa Monica boulevards. Modest‐sized structures, typically three to four stories in height, comprised much of the city’s commercial construction from the late 1940s through the mid‐1950s. However, by the late 1950s and ‘60s, high‐rise financial buildings, office towers, and large‐scale retail properties, often designed by prominent local architects, began to characterize commercial development in Beverly Hills.35 Properties such as Welton Becket’s Beverly Hilton (1956), Edward Durrell Stone’s Perpetual Savings and Loan (1961), and Sidney Eisenshtat’s Lesser Enterprises (1962), came to define the city’s commercial building stock. Other noted postwar architects who contributed to Beverly Hills’s commercial streetscape include Maxwell Starkman, I.M. Pei, and A.C. Martin and Associates.36 Beverly Hills experienced an increase in the development of commercial high‐rise buildings in the late 1960s due to a number of factors:
1. The critical need for office space in the city.
2. An economically feasible floor area ratio (density) for commercial construction.
3. Liberalization of zoning regulations to permit full development of expensive real estate here within that ratio.37
32 Johnson Heumann Research Associates, Beverly Hills Historic Resources Survey, 63‐64. 33 Kevin Roderick and J. Eric Lynxwiler, Wilshire Boulevard: Grand Concourse of Los Angeles (Santa Monica: Angel City Press, 2005), 158.
34 Johnson Heumann Research Associates, Beverly Hills Historic Resources Survey, 71 and 78. 35 Gerald Faris, “Skyline Signaling End of B.H. Building Slump,” Los Angeles Times, 149 and 154. 36 PCR Services Corporation, Historic Resources Survey Report, 15; Jones & Stokes, “City of Beverly Hills Historic Resources Survey Report, Survey Area 5: Commercial Properties,” prepared for the City of Beverly Hills Planning and Community Development Department, June 2006, rev. April 2007, 7‐8.
37 Gerald Faris, “Skyline Signaling End of B.H. Building Slump,” Los Angeles Times, 149, 154 and 157. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 15
According to Max Strauss, city planning and building director, “With the changes in density and zoning, it is now possible to profitably develop buildings that would have spelled financial loss two and three years ago.”38 In 1967, City Council raised the building height limit to ten stories, further enabling new high‐rise construction.39 According to the city’s Planning Department, in 1969, “Current major office construction projects add[ed] up to some $23 million in basic building costs.”40 Wilshire Boulevard witnessed the bulk of this new development, with prominent projects including Craig Ellwood’s Security Pacific Plaza (1969), William Pereira’s Great Western Savings Center (1972), and Anthony Lumsden’s Manufacturers Bank (1974).41 While Wilshire Boulevard saw the largest concentration of high‐rise development during the 1960s and ‘70s, large‐scale Late Modern and Corporate International‐style commercial office buildings were also built along Santa Monica Boulevard, including the subject property at the corner of Roxbury Drive and Santa Monica Boulevard (450 N. Roxbury Drive, 1970), the Wells Fargo building at the corner of Camden Drive and Santa Monica Boulevard (441 N. Camden Drive, designed by Sidney Esinshtat, 1972), and the Bank of America building at 9440 Santa Monica Boulevard (designed by Oxley & Landau, 1974).
3.2 Architecture
The property at 450 N. Roxbury Drive represents a modest interpretation of the Corporate International style. The Corporate International style, sometimes referred to as Corporate Modernism or simply as “Corporate architecture,” is a subset of postwar Modernism that was primarily used in the design of large‐scale commercial office and government buildings in the 1950s through the early 1970s.42 With the country’s economic boom in the years following World War II, corporations were placed in the spotlight and looked to an architectural aesthetic that could position them as “agents of modernity and progress.”43 As a result, glass, steel, and concrete high rises became the interchangeable face of Corporate America.44 Rooted in functionality and structure, Corporate International architecture prioritized use and flexible interior spaces for office tenants instead of exterior ornamentation.45 The architectural aesthetic is characterized by vertical volumes, boxy massing, smooth unornamented cladding, and large expanses of glass divided by a steel or concrete structural elements. The architectural idiom thrived throughout greater Los Angeles given the region’s position as an epicenter for corporations and governmental institutions.46 Notable Corporate International buildings in Beverly Hills include Welton Becket’s City National Bank at 404 N. Roxbury Drive (1955), Palmer and Krisel’s Sunset International Petroleum Building at 8920 Wilshire Boulevard (1963), Sidney Eisenshtat’s Union Bank of California at 9460 Wilshire Boulevard (1960), and Craig Elwood’s Security Pacific Plaza at 9665 Wilshire Boulevard (1972).47 Corporate International architecture fell out of favor in the mid‐1970s as many architects 38 Ibid.
39 Ibid.
40 Ibid.
41 PCR Services Corporation, Historic Resources Survey Report, 16. 42 City of Los Angeles, “SurveyLA Los Angeles Citywide Historic Context Statement, Context: Architecture and Engineering, 1850‐ 1980, Subcontext: L.A. Modernism, 1919‐1980, Subtheme: Corporate International, 1949‐1975,” prepared by Daniel Paul for the City of Los Angeles, Department of City Planning, Office of Historic Resources (2021), 155. 43 Ibid. 44 Ibid, 129.
45 Ibid, 156.
46 Ibid, 158.
47 Jones & Stokes, City of Beverly Hills Historic Resources Survey Report. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 16
“began to express dissatisfaction with [its] ubiquitous aesthetic and formulaic methodology,” and later iterations of Modernism and Postmodernism gained popularity.48 Character defining features of the Corporate International style include:
Box‐shaped form
Concrete, steel and glass construction
Flat roof, either with flush eaves or cantilevered slabs Horizontal bands of flush metal windows or curtain walls Lack of applied ornament
Double‐height ground story set back behind columns or pilotis Integral parking structure
Landscaped plaza or integral plantings at the ground floor49 Norbert W. Pieper, Architect
The subject property was designed by architect Norbert W. Pieper, head of design at the architecture and engineering firm of Sheldon L. Pollack & Associates, Inc.50 Pieper was born in 1924 in Oakland, California.
He served with the US Navy during World War II before going on to earn his bachelor’s degree in architecture from the University of California at Berkeley in 1951.51 By the mid‐1950s, Pieper had begun working for Sheldon L. Pollack as head of the architectural department and later as vice president.52 He maintained this role with the firm for nearly four decades until Pollack tragically died in a plane crash in 1989.53 While research did not produce a significant amount of information related to Pieper’s work, some of his known projects include the post office in La Verne (1964), Carousel Theatre in West Covina (1965), Fisherman’s Village in Marina Del Rey (1969), and Seaport Village in San Diego (1979).
Sheldon L. Pollack, Builder and Engineer
Sheldon L. Pollack served as the builder and engineer of 450 N. Roxbury Drive. Born in Los Angeles in 1926, Pollack earned his civil engineering degree from the University of Southern California in 1948.54 After graduating, he worked for the Los Angeles Building and Safety Department from 1948 to 1950.55 Following a brief period in civil service, he joined the General Engineering Services Co. as chief engineer.
In 1954, Pollack established the engineering and architecture firm Sheldon L. Pollack & Associates and the construction company Sheldon L. Pollack Construction Corp. As described by Pollack, the two companies represented a “total concept,” offering comprehensive site analysis, design, planning, engineering, and 48 Ibid, 163.
49 Ibid, 165.
50 “Work on $1.5 Million Building Completed,” Los Angeles Times, December 13, 1959, 189. Builder and engineer Sheldon L.
Pollack formed the firm of Sheldon L. Pollack & Associates at the same time as his construction company, Sheldon L. Pollack Corp. 51 “Reinstatement Application for Norbert Wels Pieper,” American Institute of Architects, 1980; American Institute of Architects, American Architects Directory, 3rd Edition 1970 (New York: R.R. Bowker Company, 1970), 719. 52 “He Sticks to His Estimates,” Los Angeles Times, September 4, 1966, 58. 53 “Arizona Plane Crash Kills Developer Sheldon Pollack,” Los Angeles Times, February 20, 1989, 36. 54 “He Sticks to His Estimates,” Los Angeles Times; Andy Miller, “Private dormitory proposed by agency,” Daily Trojan, October 22, 1969, 1.
55 ”Sheldon Pollack Named Utility commissioner,” Los Angeles Times, August 17, 1960, 46. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 17
property management services for commercial real estate projects.56 Pollack prided himself on “developing buildings for clients at a predetermined price with a predetermined occupancy date.”57 In 1966, Sheldon A. Pollack & Associates and Sheldon L. Pollack Construction Corp. combined under Sheldon L. Pollack Corp. That same year, the company relocated from its headquarters in the Pico‐ Hayworth Building to its new headquarters at 3344 S. La Cienega Boulevard.58 Sheldon L. Pollack Corp. was acquired by American Medical Corp. (owner, manager, and developer of hospitals) in 1970.59 The following year, Pollack announced the formation of a new real estate development firm under his name, located at 404 N. Roxbury Drive.60
Throughout his forty‐year career, Pollack specialized in the development of commercial and institutional buildings, including a post office in La Verne (1964), Carousel Theatre in West Covina (1965), Fisherman’s Village in Marina Del Rey (1969), Seaport Village in San Diego (1979), and Harvey Mudd College dormitories in Claremont (1982). Pollack worked with architect Norbert W. Pieper for the majority of his career. While arguably prolific, the duo were known for “coming in on time and on budget, not [their] architectural theory.”61
Pollack was involved in the community outside of his business endeavors and served as a commissioner for the Bord of Public Utilities and Transportation commission from 1960 until 1965.62 He also served as president of the Civil Engineering Alumni of USC and director of the Foundation for the Junior Blind.63 Pollack died suddenly in a self‐piloted plane crash in 1989 at the age of 62.64
3.3 Ownership History
The subject property was originally owned and partially occupied by the entertainment law firm of Kaplan, Livingston, Goodwin, Berkowitz, and Selvin. Established in 1940 and led by senior founding partner Leon Kaplan, the firm had gained a reputation for handling “the affairs of many of the most glamourous people in Hollywood” by the late 1950s and ‘60s. According to Kaplan, “In the 1950s, we grew from a small, struggling entertainment firm to one that had influential clients and was a significant player in the industry.”65 By the early postwar period, the firm’s client list included 20th‐Century Fox, the William Morris Agency, Warner Brothers, Rita Hayworth, Charlse Bronson, and Flip Wilson, among 56 “Total Concept Key to Success of Pollack Co.,” Pasadena Independent, December 15, 1966, 13. 57 “He Sticks to His Estimates,” Los Angeles Times. 58 “Total Concept Key to Success of Pollack Co.,” Pasadena Independent; “Architectural Firm Occupies New Headquarters Building,” Los Angeles Times, November 8, 1959, 128. 59 “Sheldon L. Pollack Acquisition Agreed,” Los Angeles Evening Citizen News, January 22, 1970, 15; “Firm Acquires Sheldon Pollack,” Los Angeles Times, April 7, 1970, 55. 60 “Pollack Forms New Company,” Los Angeles Times, May 16, 1971, 169. 61 Wim de Wit and Christopher Alexander, Overdrive: L.A. constructs the future, 1940‐1990 (Los Angeles: Getty Research Institute, 2013), 206‐207.
62 ”Sheldon Pollack Named Utility commissioner,” Los Angeles Times. 63 “Pollack Heads Unit of Capital for Israel Inc.,” Valley Times, April 26, 1969, 10. 64 “Arizona Plane Crash Kills Developer Sheldon Pollack,” Los Angeles Times, February 20, 1989, 36. 65 Marilyn Black and Andy Lewis, “A Hollywood Power Lawyer’s Lost Memoir on Birthing Independent Film,” The Hollywood Reporter, April 21, 2016, accessed February 2024, https://www.hollywoodreporter.com/lifestyle/arts/a‐hollywood‐power‐ lawyers‐lost‐884979/.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 18
others.66 With their growing prominence and expansion in the mid‐1950s, Kaplan, Livingston, Goodwin, Berkowitz, and Selvin commissioned the architecture firm of Ashton & Wilson to design their new office building at 270 N. Canon Drive, which was completed in 1957; the firm operated out of the two top floors of the building for the next 13 years (building still extant).67 The company continued to grow into the late 1960s, prompting the need for a large office space. In 1969, the firm commissioned Sheldon Pollack and Norbert Pieper to design and construct the subject property.
The firm relocated to the ninth floor of the building upon its completion in 1970. While the company continued to prosper in the early to mid‐1970s, by the late 1970s, it appeared to be experiencing considerable growing pains, which were further exacerbated by a series of strikes in the entertainment industry. By 1981, 32 of its 65 partners and associates had left the company. The firm dissolved soon thereafter and sold 450 N. Roxbury Drive in 1983.68
Kaplan, Livingston, Goodwin, Berkowitz, and Selvin sold the property to Beverly Hills Federal Savings & Loan for $20 Million in 1983.69 Beverly Hills Federal Savings & Loan’s ownership of the property was short‐lived, and in 1985 they sold it to the construction and building management company Koll Co. for $22.5 Million. Koll Co. leased the top two floors to United Artists for their corporate headquarters and in 1986, United Artists acquired the property.70 By 1991, United Artists had sold the property to Homat Properties.71 It is unclear how long Homat Properties owned the building. However, by 2005, the current owner, Starpoint Properties, had acquired 450 N. Roxbury Drive.72 66 Dan Morain, “Scrambling to Represent the Stars,” Los Angeles Times, November 18, 1981. 67 It is unclear where the firm was located prior to 270 N. Canon Drive, but newspapers suggest their offices may have been in Hollywood.
68 Talk about a ‘hot property’,” Los Angeles Times; Morain, “Scrambling to Represent the Stars,” Los Angeles Times. 69 “Talk about a ‘hot property’,” Los Angeles Times, December 7, 1986, 192; “Beverly Hills Savings Moves,” Los Angeles Times, July 17, 1983, 147.
70 “Talk about a ‘hot property’,” Los Angeles Times; “Koll Co. Acquires Office Building,” Los Angeles Times, November 17, 1985, 194.
71 City of Beverly Hills Department of Building & Safety Permit No. C9102123. 72 City of Beverly Hills Department of Building & Safety Permit No. 0526482. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 19
4. Regulatory Framework
4.1 Definition of Historical Resources
Pursuant to Section 15064.5 of the California Code of Regulations (CCR), Title 14, Chapter 3, the following are considered historical resources for the purposes of CEQA:
1. A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (California Register).
2. A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the California Public Resources Code (PRC), or identified as significant in an historical resource survey meeting the requirements in Section 5024.1(g) of the PRC, shall be presumed to be historically or culturally significant.
3. Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California may be considered to be an historical resource, provided the lead agency's determination is supported by substantial evidence in light of the whole record. Generally, a resource shall be considered by the lead agency to be "historically significant" if the resource meets the criteria for listing in the California Register (PRC SS5024.1; Title 14 CCR, Section 4852).
4.2 Federal, State, and Local Evaluation Criteria
National Register of Historic Places
The National Register is the nation’s master inventory of known historic resources. Created under the auspices of the National Historic Preservation Act of 1966, the National Register is administered by the National Park Service (NPS) and includes listings of buildings, structures, sites, objects, and districts that possess historic, architectural, engineering, archeological, or cultural significance at the national, state, or local level. As described in National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation, in order to be eligible for the National Register, a resource must both (1) be significant and (2) retain sufficient integrity to convey its significance.
Significance is assessed by evaluating a resource against established criteria for eligibility. A resource is considered significant if it satisfies any one of the following four National Register criteria:73 A. Associated with events that have made a significant contribution to the broad patterns of our history;
B. Associated with the lives of significant persons in our past; 73 Some resources may meet multiple criteria, though only one needs to be satisfied for National Register eligibility. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 20
C. Embodies the distinctive characteristics of a type, period, or method of construction, or that represents the work of a master, or that possesses high artistic values, or that represents a significant and distinguishable entity whose components may lack individual distinction; D. Has yielded, or may be likely to yield, information important in prehistory or history.
Once significance has been established, it must then be demonstrated that a resource retains enough of its physical and associative qualities – or integrity – to convey the reason(s) for its significance. Integrity is best described as a resource’s “authenticity” as expressed through its physical features and extant characteristics. Whether a resource retains sufficient integrity for listing is determined by evaluating it against the seven aspects of integrity defined by the NPS:
Location (the place where the historic property was constructed or the place where the historic event occurred);
Setting (the physical environment of a historic property); Design (the combination of elements that create the form, plan, space, structure, and style of a property);
Materials (the physical elements that were combined or deposited during a particular period of time and in a particular manner or configuration to form a historic property); Workmanship (the physical evidence of the crafts of a particular culture or people during any given period in history or prehistory);
Feeling (a property’s expression of the aesthetic or historic sense of a particular period of time); and
Association (the direct link between an important historic event/person and a historic property).
Integrity is evaluated by weighing all seven of these aspects together and is ultimately a “yes or no” determination – that is, a resource either retains sufficient integrity or it does not.74 Some aspects of integrity may be weighed more heavily than others depending on the type of resource being evaluated and the reason(s) for its significance. Since integrity depends on a resource’s placement within a historic context, integrity can be assessed only after it has been established that the resource is significant, and under which criteria.
Generally, a resource must be at least 50 years of age to be eligible for listing in the National Register.
Exceptions are made if it can be demonstrated that a resource less than 50 years old is (1) of exceptional importance or (2) is an integral component of a historic district that is eligible for the National Register.
California Register of Historical Resources
The California Register is the authoritative guide to the State’s significant historical and archeological resources. In 1992, the California legislature established the California Register “to be used by state and local agencies, private groups, and citizens to identify the state’s historical resources and to indicate what 74 Derived from National Register Bulletin 15, Section VIII: “How to Evaluate the Integrity of a Property.” 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 21
properties are to be protected, to the extent prudent and feasible, from substantial adverse change.”75 The California Register program encourages public recognition and protection of resources of architectural, historical, archeological, and cultural significance; identifies historical resources for state and local planning purposes; determines eligibility for historic preservation grant funding; and affords certain protections under CEQA. All resources listed in or formally determined eligible for the National Register are automatically listed in the California Register. In addition, properties designated under municipal or county ordinances, or through local historic resources surveys, are eligible for listing in the California Register.
The structure of the California Register program is similar to that of the National Register, but places its emphasis on resources that have contributed specifically to the development of California. To be eligible for the California Register, a resource must first be deemed significant at the local, state, or national level under one of the following four criteria, which are modeled after the National Register criteria listed above:
1. It is associated with events or patterns of events that have made a significant contribution to the broad patterns of local or regional history, or the cultural heritage of California or the United States;
2. It is associated with the lives of persons important to local, California, or national history;
3. It embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of a master, or possesses high artistic values;
4. It has yielded, or has the potential to yield, information important to the prehistory or history of the local area, state, or the nation.76
Like the National Register, the California Register also requires that resources retain sufficient integrity to be eligible for listing. A resource’s integrity is assessed using the same seven aspects of integrity used for the National Register. However, since integrity thresholds associated with the California Register are generally less rigid than those associated with the National Register, it is possible that a resource may lack the integrity required for the National Register but still be eligible for listing in the California Register.
There is no prescribed age limit for listing in the California Register, although California Register guidelines state that “sufficient time must have passed to obtain a scholarly perspective on the events or individuals associated with the resource.”77
75 California Public Resources Code, Section 5024.1 (a). 76 California Public Resources Code SS5024.1, Title 14 CCR, Section 4852. 77 California Office of Historic Preservation, Technical Assistance Series #6: California Register and National Register: A Comparison (Sacramento, CA: California Department of Parks and Recreation, 2001), 3. According to the Instructions for Recording Historical Resources (Office of Historic Preservation, March 1995), “Any physical evidence of human activities over 45 years old may be recorded for purposes of inclusion in the OHP’s filing system. Documentation of resources less than 45 years old may also be filed if those resources have been formally evaluated, regardless of the outcome of the evaluation.” This 45‐year threshold is intended to guide the recordation of potential historical resources for local planning purposes, and is not directly related to an age threshold for eligibility against California Register criteria. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 22
Resources are automatically listed in the California Register if they are listed in or have been officially determined eligible for the National Register. State Historic Landmarks #770 and forward are also automatically listed in the California Register.78
City of Beverly Hills Historic Preservation Ordinance
Historic preservation in Beverly Hills is governed by Title 10, Chapter 3, Articles 32 and 32.5 of the Beverly Hills Municipal Code (referred to hereafter as the Ordinance). The Ordinance authorizes the Cultural Heritage Commission (CHC) to recommend the nomination of properties as local landmarks and historic districts to the City Council. To facilitate this process, the Ordinance establishes requirements a property must meet in order to qualify for designation as a landmark listed in the City of Beverly Hills Register of Historic Properties. The 2012 Ordinance was revised and updated in 2015, with an additional amendment in 2016; all criteria and definitions used in this document are effective as of April 1, 2016.
To be eligible for local designation as a historic landmark, a property must satisfy the following sets of requirements (A and B) as noted:
A. A landmark must meet all of the following requirements:
(1) It is at least forty five (45) years of age, or is a property of extraordinary significance; (2) It possesses high artistic or aesthetic value, and embodies the distinctive characteristics of an architectural style or architectural type or architectural period; (3) It retains substantial integrity79 from its period of significance; and (4) It has continued historic value to the community such that its designation as a landmark is reasonable and necessary to promote and further the purposes of this article.
B. In addition to those listed above, a landmark must meet at least one of the following requirements:
(1) It is listed on the National Register of Historic Places; (2) It is an exceptional work80 by a master architect81; 78 California Office of Historic Preservation, Technical Assistance Series #5: California Register of Historical Resources, The Listing Process (Sacramento, CA: California Department of Parks and Recreation, n.d.), 1. 79 In BHMC 10‐3‐3202, the Ordinance defines “substantial integrity” as “Integrity that is considerable in importance, value, degree, amount, or extent, and that continues to exist, or would have continued to exist, but for work done without appropriate permits after the enactment of this article.”
80 A 2016 amendment to BHMC 10‐3‐32 in Ord. 15‐O‐2700 defines “exceptional work” as “A remarkably superior example of architectural work that has been recognized as such by members of the architectural community. At a minimum, the work's exceptional quality shall have been documented by at least one of the following: a) it was the subject of a major architectural award; b) it was substantively discussed (i.e., not just mentioned) and photographically depicted in a monograph on a master architect's career; or c) it was substantively discussed or photographically depicted in at least two (2) publications (e.g., a book, treatise, trade magazine article, film, or set of photographs made available to the public by an institutional archive) authored by acknowledged experts in the field of architecture. A monograph or publication made available to the public solely in electronic form and without any reasonable expectation of compensation to the author, or substantially authored by the architect of the work, shall not count toward this minimum.”
81 In BHMC 10‐3‐3202, the Ordinance defines “master architect” as “An architect of widely recognized greatness in the field of architecture whose individual genius influenced his or her age.” 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 23
(3) It is an exceptional work that was owned and occupied by a person of great importance, and was directly connected to a momentous event in the person's endeavors or the history of the nation.
For purposes of this subsection B3, personal events such as birth, death, marriage, social interaction, and the like shall not be deemed to be momentous; (4) It is an exceptional property that was owned and occupied by a person of great local importance; (5) It is an iconic property82; or
(6) The landmark designation procedure is initiated, or expressly agreed to, by the owner(s) of the property. (Ord. 15‐O‐2682, eff. 11‐19‐2015).
Mirroring the National Register and California Register, the Ordinance requires that a resource retain integrity. The Ordinance defines integrity as “the ability of a property to convey its historical significance through its location, design, setting, materials, workmanship, feeling, relevant association, and character defining features.”83 This builds upon the definition that is used by the National Register. 82 In BHMC 10‐3‐3202, the Ordinance defines “iconic property” as “A property that has been visited and photographed so often by residents and visitors to the city that it has become inextricably associated with Beverly Hills in the popular culture and forms part of the city's identity to the world at large.”
83 BHMC 10‐3‐3202, Definitions.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 24
5. Evaluation of Historical Significance
5.1 Previous Evaluations and Studies
The property at 450 N. Roxbury Drive is not formally listed in the National Register, California Register, or Beverly Hills Local Register of Historic Properties. Furthermore, it was not identified in the Beverly Hills Historic Resources Survey (Johnson Heumann Research Associates, 1985‐1986) or Historic Resources Survey Update of Survey Area 5: Commercial Properties (Jones & Stokes, 2006‐2007). It is not listed in California’s Built Environment Resource Directory (BERD).
According to a 2019 Architectural Commission Report prepared by City Planning staff, the subject property is a potential contributor to an eligible postwar commercial historic district. The staff report describes the property in the following manner:
The building design expresses a simplified grid pattern with a repeating triangular motif found in the projecting triangulated vertical piers between the individual window bays and on the garage structure metal relief panels. The building appears to be an eligible historic resource as a potential contributor to an eligible post‐war historic commercial district.84 The report does not provide information related to the boundaries of the district, when or how the district was identified, or under which registration criteria or level of significance (National Register, California Register, Beverly Hills Register) the district is eligible for designation.
5.2 Evaluation of Significance
Because the subject property was cited as eligible by City staff as a potential contributor to an eligible postwar historic district in 2019, ARG did not re‐evaluate the property for eligibility as a district contributor. Rather, it is conservatively being treated as a potential district contributor for the purposes of this report. The following is an evaluation of potential individual eligibility.
The building and attached parking garage at 450 N. Roxbury Drive do not appear to be individually eligible for listing in the National Register, California Register, or as a Beverly Hills Landmark.
Following is an evaluation of the property for individual eligibility against federal, state, and local criteria.
National and California Register
National and California Register Criteria A/1: associated with events that have made a significant contribution to the broad patterns of history.
Constructed in 1970, the subject property is associated with the pattern of increased development of high‐rise commercial buildings in Beverly Hills and along major streets such as Santa Monica and Wilshire boulevards following changes in zoning and an increase in the city’s building height limit in the late 1960s.
In 1969 alone, new major office construction projects in the city amounted to approximately $23 million in basic building costs. While the subject property is generally associated with the rise in Beverly Hills’s 84 City of Beverly Hills Planning Division, Beverly Hills Architectural Commission Report: 450 North Roxbury Drive, April 17, 2019. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 25
large‐scale commercial development in the late 1960s and ‘70s, it is one of dozens of extant commercial office buildings constructed during this time period, some of which are enumerated in Section 3.1 and Section 3.2 of this report and included in the Beverly Hills Historic Resources Survey Update of Survey Area 5: Commercial Properties (Jones & Stokes, 2006‐2007). Thus, the property does not singularly convey this association with postwar high‐rise commercial development patterns in the city in any significant way. For this reason, 450 N. Roxbury Drive is not eligible under Criteria A/1.
National and California Register Criteria B/2: associated with the lives of persons significant in our past.
Since its construction in 1970, the subject building has been owned and occupied by a number of national and international companies whose executives and chairpersons have presumably made significant contributions to their industries. The building was originally owned and partially occupied by the entertainment law firm of Kaplan, Livingston, Goodwin, Berkowitz, and Selvin, led by senior founding partner Leon Kaplan. Founded in 1940, the firm had gained a reputation for handling “the affairs of many of the most glamourous people in Hollywood” by the late 1950s and ‘60s, representing clients such as 20th‐Century Fox, the William Morris Agency, Warner Brothers, Rita Hayworth, Charles Bronson, and Flip Wilson, among others.85 The law firm, and Leon Kaplan, in particular, appears to have played a significant role in the development and growth of the entertainment industry and has a direct association with the subject property. However, per National Register Bulletin 15, “each property associated with an important individual should be compared to other associated properties to identify those that best present the person’s historic contributions.”86 Kaplan’s significance as a founding partner of the entertainment law firm is arguably better represented by the extant office building at 270 N. Canon Drive, where the company rose to prominence in the late 1950s and ‘60s. Thus, the subject property is not eligible for its association with Kaplan.
Other early occupants of the property included the oil and gas law firm of Ball, Hart, Hunt, Brown & Baerwitz, Merrill Lynch, and Time, Inc. Owners of the property in the 1980s included Beverly Hills Savings and Loan, Koll Co., and United Artists. While some of these owners/occupants represent large national and international companies with executives and chairpersons who have made significant contributions to their respective industries, the subject property does not appear to have served as an early, long‐ standing, and/or singular location of any of these companies. Both Time, Inc. and Merrill Lynch held multiple offices during their occupancy of the subject property, and 450 N. Roxbury Drive does not appear to have served as their main headquarters. While the property served as United Artists’ corporate headquarters in the 1980s, the company, which was founded in 1919, had reached its most formative period in terms of its contributions to the entertainment industry long before its ownership/occupation of the building. For these reasons, the subject property is not eligible for its associations with these corporations or any significant individuals who led or were employed by them.
For the reasons stated above, the property is ineligible under Criteria B/2. 85 Dan Morain, “Scrambling to Represent the Stars,” Los Angeles Times, November 18, 1981. 86 National Register Bulletin 15, 15. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 26
National and California Register Criteria C/3: embodies the distinctive characteristics of a type, period, or method of construction, or that represents the work of a master, or that possesses high artistic values, or that represents a significant and distinguishable entity whose components may lack individual distinction.
The subject building is a modest and relatively late example of the Corporate International style. The building retains the typical features of the architectural idiom, including its boxy massing, flat roof, steel and concrete structural system, double‐height ground story set back behind columns, and overall lack of ornamentation. However, it lacks the distinctive characteristics found in more highly articulated examples of the style, such as horizontal bands of flush windows or curtain walls and landscaped plazas. There are better examples of Corporate International commercial high‐rise buildings found throughout the city and delineated in Section 3.2. Furthermore, research did not suggest that Norbert W. Pieper, the building’s original architect or Sheldon Pollack, the building’s original developer, were considered masters of their respective fields. Notably, the duo were known more for their efficiency and ability to stay on budget as opposed to their architectural prowess. Gin Wong Associates (who is on the Beverly Hills list of master architects)87 designed a substantial interior remodel of the building and remodel of the parking structure in the early 1990s, including a redesign of the main ground floor lobby. However, building permits and visual observation of the building lobby during ARG’s site visit suggest that little, if any, of Wong’s design remains. And, based on a comparison of original drawings and current conditions, the changes Wong oversaw for the parking structure were very minor. Thus, it cannot be said that the building’s interior design or the parking structure remodel represents Wong’s work as a master architect.
For the reasons stated above, the subject property is not eligible under Criteria C/3.
National and California Register Criteria D/4: has yielded or may likely yield information important in prehistory or history.
ARG did not observe any features on the property that appear likely to yield information important in prehistory or history. In addition, the property has been graded and developed, and its shallow subsurface is unlikely to yield such information. Therefore, based on what can be observed on the site, the property does not appear to be eligible under Criterion D or 4 of the National or California Registers.
City of Beverly Hills Landmark Criteria
ARG concludes that the property does not meet eligibility criteria for listing as a Beverly Hills Landmark.
Following is an evaluation of 450 N. Roxbury under local registration criteria.
Part A Eligibility Criteria (resource must meet all four of the following requirements):
Criterion A.1: it is at least forty five (45) years of age, or is a property of extraordinary significance.
Constructed in 1970, the subject property is 54 and thus satisfies Criterion A.1. 87 https://www.beverlyhills.org/cbhfiles/storage/files/11532334261958763470/MasterArchitectList_Version3‐1_active.pdf. 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 27
Criterion A.2: it possesses high artistic or aesthetic value, and embodies the distinctive characteristics of an architectural style or architectural type or architectural period.
As described in its evaluation under National/California Register Criteria C/3, the property represents a modest and relatively late example of a Corporate International style office building. While the building retains the typical features of the architectural idiom, it lacks the distinctive characteristics found in more highly articulated examples of the style, such as horizontal bands of flush windows or curtain walls and landscaped plazas. Furthermore, there are several better, more highly articulated examples of the style and architectural type as described in Section 3.2 of this report.
Criterion A.3: it retains substantial integrity from its period of significance.
The building retains its original location at the intersection of Roxbury Drive and Santa Monica Boulevard and its setting within the Beverly Hills commercial triangle. While the building has undergone several interior remodels since its original construction, and some of its original storefronts have been altered with new doors/glazing, the vast majority of the building’s original materials and design features (flat roof, boxy massing, fixed aluminum windows divided by triangular‐shaped pilasters, double‐height ground story recessed behind columns, integrated parking garage) remain intact. Its intact design and materials help to convey its original workmanship and historic feeling and association. Thus, the building retains all seven aspects of integrity (location, design, setting, materials, workmanship, feeling, and association) as defined by the National Park Service and meets Criterion A.3.
Criterion A.4: it has continued historic value to the community such that its designation as a landmark is reasonable and necessary to promote and further the purposes of this article.
Because the building is a relatively late and modest example of a Corporate International office building, reflects one of dozens of commercial high rises built in the city during the 1960s and ‘70s, and does not appear to have any singularly significant associations with notable historic individuals, it cannot be said that the building possesses historic value to the community in a way that would merit consideration under this criterion. Thus, the property does not satisfy Criterion A.4.
Summary of Local Eligibility
In summary, the subject property meets Landmark Criteria A.1 and A.3. It does not meet Criteria A.2 and A.4. Because a property must satisfy all four Part A eligibility criteria for consideration as a Beverly Hills Landmark, 450 N. Roxbury Drive is not eligible for local designation. It has thus not been evaluated under Part B eligibility criteria.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 28
6. Impacts Analysis
6.1 Summary of Historical Resource Findings
Pursuant to Section 15064.5(a)(2) of the State CEQA Guidelines (CEQA Guidelines), the term "historical resource" includes a resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (California Register); a resource included in a local register of historical resources or identified as significant in a historical resources survey meeting the requirements defined in Section 5024.1(g) of the Public Resources Code; or any resource which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California…provided the lead agency’s determination is supported by substantial evidence in light of the whole record.
Per the 2019 Architectural Commission Report prepared by City Planning staff, the subject property is a potential contributor to an eligible postwar commercial historic district. While the report does not provide information related to the boundaries of the district, when or how the district was identified, or whether it is eligible for listing in the California Register, ARG is conservatively treating the property as a contributor to the potential district and the district as a historical resource under CEQA.
6.2 Significance Threshold
According to California CEQA Guidelines, a project has the potential to impact a historical resource when the project involves a “substantial adverse change” in the resource’s significance. Substantial adverse change is defined as “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of an historical resource would be materially impaired.”88
The significance of an historical resource is materially impaired when a project:
a) Demolishes or materially alters in an adverse manner those physical characteristics of an historical resource that convey its historical significance and that justify its inclusion in, or eligibility for, the California Register of Historical Resources; or b) Demolishes or materially alters in an adverse manner those physical characteristics that account for its inclusion in a local register of historical resources pursuant to Section 5020.1(k) of the Public Resources Code or its identification in an historical resources survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, unless the public agency reviewing the effects of the project by a preponderance of evidence that the resource is not historically or culturally significant; or
c) Demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for inclusion in the 88 CEQA Guidelines, Section 15064.5.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 29
California Register of Historical Resources as determined by a lead agency for the purposes of CEQA.89
6.3 Project Description
The Project includes the rehabilitation of a portion of the office building’s attached parking garage for use as retail space. Four retail storefronts totaling approximately 6,797 square feet would be added in the south half of the ground floor level of the parking garage. Four of the garage bays, which are currently infilled with original, decorative aluminum screens and raised planters, would be altered to accommodate four glazed storefront assemblies fronting Roxbury Drive. Vehicular entries/exits at the east and west ends of the garage would be retained, as would parking spaces in the north half of the ground floor level, the two below‐ground levels, the second floor above‐ground level, and the roof level. No changes to the office building are proposed under the Project.
6.4 Analysis of Project Impacts
As noted above, a project has the potential to impact a historical resource if the project would result in a “substantial adverse change” to its significance. Generally speaking, substantial adverse change is defined as demolition or material alteration in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its inclusion in or eligibility for listing in a federal, state, and/or local register of historical resources.
As discussed above, 450 N. Roxbury Drive was identified by City staff as a potential contributor to an eligible postwar commercial historic district, and ARG is conservatively treating the district as a historical resource for the purposes of CEQA. As described in ARG’s evaluation of significance in Section 5.2, the subject property is not individually eligible for listing in the National Register, California Register, or as a Beverly Hills Landmark. Because the historical resource as defined by CEQA is the postwar commercial historic district and not the individual office building and attached parking garage, the focus of the analysis provided herein is the potential material impairment of 450 N. Roxbury Drive as a district contributor and the ability of the historic district to continue to convey its significance after completion of the Project.
The Project would not result in the demolition of the building or attached parking garage. The Project proposes a few changes to the exterior of the parking garage, including removal of original aluminum screens/panels and raised planters in four bays fronting Roxbury Drive and the installation of four glazed retail storefront assemblies. However, the overall height, form, massing, setbacks, design, and the majority of the property’s original features and materials (i.e. its simplified grid pattern, vertical concrete piers, and size/pattern of its window and garage bays, as noted in the 2019 Architectural Commission Report), would remain. No changes would be made to the exterior of the office building.
Because the Project would preserve the vast majority of 450 N. Roxbury’s extant historic materials and features, the building and attached parking garage would retain the physical characteristics that account 89 Ibid.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 30
for their potential eligibility as a contributor to the eligible postwar commercial historic district identified by City staff in 2019.
6.5 Summary of Continued Eligibility
In summary, the Project would not result in any changes to 405 N. Roxbury Drive such that it would no longer be potentially eligible as a contributor to the eligible postwar commercial historic district identified by City Planning staff. The property would continue to convey its overall appearance and original design as a postwar commercial office building. The Project would not alter the height, scale, or setbacks of the subject property, and thus, no proposed changes would impact any important views within the district.
For these reasons, the postwar commercial historic district would continue to be eligible for listing after the Project is completed.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 31
7. Conclusion
In conclusion, the Project would not have a significant impact on the eligible postwar commercial historic district identified by City staff in 2019, which ARG is conservatively treating as a historical resource under CEQA. The Project includes the rehabilitation of a portion of the ground level of the 450 N. Roxbury Drive parking garage for retail use and the addition of glazed retail storefronts in four garage bays facing Roxbury Drive. The office building and parking garage were identified by City staff in 2019 as a contributor to an eligible postwar commercial historic district.
The Project would not materially impair the significance of the subject property or the historic district as a whole. Work proposed under the Project would retain the majority of the original features and materials of the property, and the property would remain potentially eligible as a contributor to the potential postwar commercial district. The significance of the postwar commercial historic district would not be impaired by the Project.
450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 32
8. Bibliography
American Institute of Architects. American Architects Directory, 3rd Edition. New York: R.R. Bowker Company, 1970.
American Institute of Architects. “Reinstatement Application for Norbert Wels Pieper.” 1980.
Beverly Hills Historical Society. “Beverly Hills, A Brief History.” Accessed February 2024. http://www.beverlyhillshistoricalsociety.org/history.
Black, Marilyn, and Andy Lewis. “A Hollywood Power Lawyer’s Lost Memoir on Birthing Independent Film.” The Hollywood Reporter. April 21, 2016. Accessed February 2024. https://www.hollywoodreporter.com/lifestyle/arts/a‐hollywood‐power‐lawyers‐lost‐884979/.
California Code of Regulations (Title 14, Division 6, Chapter 3, Sections 15000‐15387).
California Office of Historic Preservation. Technical Assistance Series #1: California Environmental Quality Act (CEQA) and Historical Resources. Sacramento: California Department of Parks and Recreation, n.d.
California Office of Historic Preservation. Technical Assistance Series #5: California Register of Historical Resources, The Listing Process. Sacramento, CA: California Department of Parks and Recreation, n.d.
California Office of Historic Preservation. Technical Assistance Series #6: California Register and National Register: A Comparison. Sacramento, CA: California Department of Parks and Recreation, 2001.
California Public Resource Code (Section 21000‐21177).
City of Beverly Hills. Historic Preservation Ordinance of the City of Beverly Hills, (Ord. 15‐O‐2682, eff. 11‐ 19‐2015). Beverly Hills Municipal Code 10‐3‐32, 2015.
City of Beverly Hills Department of Building & Safety. Building Permits, 1969‐2024.
City of Beverly Hills Planning Division, Beverly Hills Architectural Commission Report: 450 North Roxbury Drive, April 17, 2019.
City of Los Angeles. “SurveyLA Los Angeles Citywide Historic Context Statement, Context: Architecture and Engineering, 1850‐1980, Subcontext: L.A. Modernism, 1919‐1980, Subtheme: Corporate International, 1949‐1975.” Prepared by Daniel Paul for the City of Los Angeles, Department of City Planning, Office of Historic Resources, 2021.
Daily Trojan articles, various dates.
de Wit, Wim and Christopher Alexander. Overdrive: L.A. constructs the future, 1940‐1990. Los Angeles:
Getty Research Institute, 2013.
Gin Wong and Associates. “Ground Floor Entry & Lobby Floor Finish Pattern Plan.” Dated 1991, drawing sourced from Lamprecht & Louden, “Historic Resource Assessment: Proposed Façade 450 N. Roxbury Drive Historical Resource Assessment and Project Impacts Analysis April 23, 2024 ARCHITECTURAL RESOURCES GROUP 33
Remodeling, 450 North Roxbury Drive.” Prepared for the City of Beverly Hills Planning Department, 2019.
“History of the Chamber.” Beverly Hills Chamber of Commerce. Accessed February 2024. http://www.beverlyhillschamber.com/pages/HistoryoftheChamber.
Johnson Heumann Research Associates. Beverly Hills Historic Resources Survey. Prepared for the City of Beverly Hills, 1985‐1986.
Jones & Stokes. City of Beverly Hills Historic Resources Survey Report. Part I: Historic Resources Survey Update and Part II: Area 5: Commercial Property Survey. Prepared for the City of Beverly Hills, 2006‐2007.
Los Angeles County Office of the Assessor.
Los Angeles Evening Citizen News articles, various dates.
Los Angeles Times articles, various dates.
Pasadena Independent articles, various dates.
PCR Services Corporation. Historic Resources Survey Report, Part I: Historic Resources Survey Update and Part II: Area 4 Multi‐Family Residence Survey. Prepared for the City of Beverly Hills, 2004.
Roderick, Kevin and J. Eric Lynxwiler. Wilshire Boulevard: Grand Concourse of Los Angeles. Santa Monica:
Angel City Press, 2005.
Sheldon L. Pollack Corp. “Office Building for Kaplan, Livingston, Goodwin, Berkowitz & Selvin.” Original Drawing Set from Permit No. 690137, 1969.
United States Department of the Interior, National Park Service. National Register Bulletin 15: How to Apply the National Register Criteria for Evaluation. Washington D.C., U.S. Department of the Interior, National Park Service, 1990, revised 1997.
Valley Times articles, various dates.
Wanamaker, Marc. Early Beverly Hills. Charleston, SC: Arcadia Publishing, 2005.
P.O. Box 542
Long Beach, CA
562.500.9451
1 Ostashay & Associates
CONSULTING
Memorandum
To: Minjee Hahm, Associate Planner Date: 04/30/2023
City of Beverly Hills
From: Jan Ostashay, Principal OAC
cc: Cindy Gordon, AICP, Principal Planner
Re: PEER REVIEW: Historic Assessment Report - 450 North Roxbury Drive, Beverly Hills Overview
At the request of the City of Beverly Hills Community Development Department, Planning Division, Ostashay & Associates Consulting (OAC) has conducted a peer review of a historic resource assessment report prepared for a proposed project at the property referenced above. The historic resource assessment report prepared by Architectural Resources Group (ARG) is entitled 450 North Roxbury Drive Historical Resource Assessment and Project Impacts Analysis (ARG report) and is dated “April 23, 2024” (hereinafter the consultant report or ARG report).
The ARG consultant report was prepared to determine if any historical resources, as defined by the California Environmental Quality Act (CEQA), are present on or in the vicinity of the project site and, if so, to identify those identified historical resources may be adversely impacted by the proposed project. The consultant report, therefore, evaluated the subject property under applicable statutes and regulations of CEQA and the California Register of Historical Resources (California Register). In addition, the property was also evaluated for potential listing in the National Register of Historic Places (National Register) and the City of Beverly Hills Register of Historic Properties (Local Register).
The consultant report concludes that the subject property does not satisfy the criteria mandates required under Section 10-3-3212 of the City’s Historic Preservation Ordinance for designation as a local landmark. The property was also found to be ineligible for inclusion in the National Register and California Register as it did not satisfy any of the necessary significance criteria under those registration programs. However, the property was identified as a potential contributor to an eligible post-war commercial historic district in a Beverly Hills Architectural Commission Report prepared by City Planning staff on April 17, 2019. As such, ARG is conservatively treating the historic district as a historical resource as defined under CEQA.1 ARG also conducted an analysis of the proposed project to assess its potential to impact the identified historical resource (the potential post-war commercial historic district). ARG concludes that the project would not have a significant impact on the historical resource or the subject property’s potential eligibility as a district contributor. In reviewing the ARG report, OAC concurs with the consultant’s evaluation findings and impact analysis determination. 1 California Environmental Quality Act (CEQA) Guidelines, Section 15064.5.
PEER REVIEW: Historical Resource Assessment Report – 450 N. Roxbury Drive 2 Introduction
Generally, peer reviews of historic resources assessment reports are conducted to reassure lead agencies requesting the assessments that the identification and evaluation efforts performed are adequate, that the eligibility determinations made are logical and well supported, and that the document will, if necessary, facilitate environmental compliance under the provisions of CEQA.
Review of historic resources documents for quality control is an essential part of the environmental review process.
As a primer, historic resources fall within the jurisdiction of several levels of government. Federal laws provide the framework for the identification, evaluation, designation, and in certain instances, protection of historic resources. States and local jurisdictions play active roles in the identification, recordation, landmarking, and protection of such resources within their communities.
The National Historic Preservation Act of 1966, as amended, promulgated standardized practices and guidelines for identifying, evaluating, and documenting historic properties (Secretary of the Interior’s Standards and Guidelines [Preservation Planning, Identification, and Evaluation]). The State Office of Historic Preservation (OHP) and most local governments in California recognize these practices and guidelines and recommend their use in order to maintain objectivity and consistency in the preparation of historic preservation documents and survey assessments.
Peer Review Assessment
Peer Review Methodology
This peer review addresses the overall acceptability of the ARG consultant report by considering the technical adequacy of the identification and evaluation of historical resources and assessing if the formal findings and conclusion of the project impact analysis are sound and well justified. A review for accuracy, clarity, thoroughness, and understanding of the information provided in the report was also conducted as part of the peer review.
Our process in conducting the peer review included an examination of the consultant report and observation of the project site. We also performed additional research and reviewed building permits, Sanborn fire insurance maps, historic aerial photographs, prior survey assessments of the area, and other primary and secondary sources relevant to the subject property and immediate neighborhood. The following peer review comments are provided in consideration of the historical resource assessment report prepared by ARG to assist in the CEQA review process by the city.
Report Content, Clarity, and Format
In addition to reviewing and assessing evaluation findings and potential project impacts, an essential element of peer reviews is the assessment of the clarity of presentation, the adequacy of the research and context development, the appropriate application of significance criteria, and a thorough understanding of the proposed project for which the report findings and conclusions are based.
Upon reviewing the ARG report, the general content and format of the document appears to be adequately researched, logically formatted, professionally sound, and technically supported. In considering the recognized and accepted standardized practices and guidelines for conducting such assessment work ARG has followed the basic principles with the development of an organized historic context, straightforward property description, introduction of the applicable regulatory framework, PEER REVIEW: Historical Resource Assessment Report – 450 N. Roxbury Drive 3 and the reasonable application of federal, state, and local significance criteria. The narrative providing the project description and impact analysis for CEQA purposes also appears sound and technically well supported. In addition, the inclusion of supporting material as attachments to the report aids in understanding the development of the site and immediate area, and further provides evidence to support the assessment evaluation and impact analysis findings.
Evaluation Findings
Previous Evaluations and Studies
The commercial (office) building located at 450 North Roxbury Drive is not listed in the National Register, California Register, or Beverly Hills Local Register. Moreover, the subject property has not been previously identified or assessed in any of the prior city-sponsored surveys and has not been previously evaluated for local, state, or federal level historical significance under any other survey efforts.
However, in a Beverly Hills Architectural Commission Report prepared by City Planning staff dated April 17, 2019, the subject property was noted as a potential eligible historic resource. The report states that “The building appears to be an eligible historic resource as a potential contributor to an eligible post-war commercial historic district…” The report does not provide any specific information related to the boundaries of the district, how or when the district was identified, or under which registration criteria or level of significance (National Register, California Register, or Beverly Hills Local Register) the district is eligible for designation.
Evaluation of Significance
Because the subject property was cited as eligible by City staff as a potential contributor to an eligible post-war commercial historic district in 2019, ARG did not re-evaluate the property for eligibility as a district contributor. Instead, ARG has conservatively treated the subject property as a district contributor for the purposes of the assessment report.
For individual significance, ARG evaluated the subject property against federal, state, and local significance criteria. They concluded that the 450 North Roxbury Drive property appears ineligible for listing in the City of Beverly Hills Local Register, as it did not satisfy the required mandates of the significance criteria (Beverly Hills Municipal Code 10-3-3212). In addition, the property was found ineligible for inclusion in the National Register and California Register due to lack of association with important historical events or trends, architectural merit, and notable personages.
Based on the background research data, photographs, and historical archival material collected and reviewed by OAC in addition to the information and supporting materials provided in the ARG report, OAC concurs with their evaluation of historical significance findings. As such, the subject property appears ineligible for individual listing under any of the federal, state, or local registration programs.
OAC also concurs with the ARG approach of conservatively treating the property as a contributor to an eligible post-war commercial historic district and treating the district as a historical resource under CEQA.
PEER REVIEW: Historical Resource Assessment Report – 450 N. Roxbury Drive 4 CEQA Compliance
Project Summary
As discussed in the ARG report, the proposed project includes the rehabilitation of a portion of the subject property’s attached parking garage for use as retail space. Four retail storefronts would be added within the south half of the existing ground level of the parking structure. Four of the garage bays, which are currently infilled along the public sidewalk with original, decorative aluminum screens and raised planters, would be altered to accommodate four glazed storefront assemblies fronting Roxbury Drive. Vehicular entries/exits at the east and west ends of the garage would be retained, as would the parking spaces in the north half of the ground floor level, the two below-ground levels, the second floor above ground level, and the roof level. No changes to the office building itself are proposed under the project.
CEQA Analysis
As the subject property has been identified as a potential contributor to an eligible post-war commercial historic district, the ARG consultant report has conservatively treated the district as a historical resource for the purposes of CEQA.
Under CEQA, a project has the potential to impact a historical resource if the project would result in a “substantial adverse change” to its significance. A substantial adverse change is defined under CEQA as demolition or material alteration in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its inclusion in or eligibility for listing in a federal, state, and/or local register of historical resources.2 ARG has concluded that the scope of work proposed under the project would not cause an adverse impact, as defined under CEQA. The project would not result in the demolition or significant alteration of the office building or the attached garage. No changes would be made to the exterior of the commercial building itself. The project proposes a few exterior changes to the attached parking structure, including removal of the original aluminum screens/panels and raised planters in four bays fronting Roxbury Drive and the installation of four glazed storefront assemblies for retail purposes.
The consultant report also states that the overall height, form, massing, setbacks, design, and majority of the original features and materials of the office building and garage would remain intact upon completion of the project. As such, the subject property would retain those qualities that qualify it as a contributor to the potential post-war commercial historic district, as identified by City staff in the Architectural Commission Report dated April 17, 2019. ARG also concludes that the post-war commercial historic district (the historical resource for CEQA purposes) would continue to be eligible for listing after the project is finished.
Upon consideration of the information in the ARG report and after conducting an independent review of the property and proposed project, OAC concurs with the consultant’s determination that for the purposes of CEQA, the commercial building is a contributor to a potential post-war commercial historic district and as such the district is considered a historic resource under the CEQA Guidelines.
OAC also concurs with the findings of the ARG report that the project would not result in a substantial adverse impact to the identified historical resource (the post-war commercial historic district) and 2 CEQA Guidelines, Section 15064.5 (b).
PEER REVIEW: Historical Resource Assessment Report – 450 N. Roxbury Drive 5 would not have a significant effect on the environment. Therefore, no mitigation measures are required for this component of CEQA review.
Conclusion
OAC has completed its peer review of the ARG report as it relates to the historical evaluation of the subject property and the CEQA analysis of the proposed project and potential impacts to the identified historical resource (the post-war commercial historic district) and contributing property.
OAC finds there is sufficient information in the consultant’s report to evaluate the subject property in proper context and concurs that it is ineligible for listing in the National Register, California Register, and Beverly Hills Local Register. OAC also concurs with ARG’s conservative treatment of the subject property as a contributor to a potential post-war commercial historic district and that this district is considered a historical resource pursuant to CEQA.
The proposed project would rehabilitate a portion (ground floor) of the existing multi-level garage for retail use, while retaining the original use and configuration of the extant commercial building and a substantial portion of the existing garage structure for its original purpose. The alterations proposed do not radically change, obscure, or destroy the key features or qualities that define the subject property as a contributor to a potential historic district or the district as a whole.
Based on the analysis in the ARG report and the additional research conducted on the property by OAC, the integrity and historical significance of the subject property and potential historic district would not be materially impaired by the implementation of the proposed project. OAC, therefore, concurs with the conclusionary findings of the ARG report and that the proposed project would not cause a substantial adverse change to the subject property and the potential historic district. The assessment analysis provided in the consultant’s report appears sound and justifiably defensible for CEQA review.
PEER REVIEW: Historical Resource Assessment Report – 450 N. Roxbury Drive 6 ATTACHMENT A
Historical Resource Assessment and Project Impact Analysis Report 450 North Roxbury Drive
Beverly Hills, California
Prepared by:
Architectural Resources Group (ARG)
Los Angeles, CA
Dated: April 23, 2024
[UNDER SEPARATE COVER]
Appendix C
Archaeological Resources Assessment
Klmley»>Horn
Archaeological Resources Assessment
for the
450 North Roxbury Drive Project
in the
City of Beverly Hills
Los Angeles County, California
Prepared by:
Jessica Mauck, MA, RPA
Jamie Nord, MA, RPA
Kimley-Horn and Associates, Inc.
3801 University Avenue, Suite 300
Riverside, California 92501
September 6, 2024
KimleyHorn
Expect More. Experience Better.
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | i
TABLE OF CONTENTS
_Toc172806755
1.0 INTRODUCTION..........................................................................................................................1
1.1 Project Description.........................................................................................................1
1.2 Regulatory Setting..........................................................................................................4
1.3 Cultural and Natural Setting ...........................................................................................7
2.0 METHODS...................................................................................................................................8
3.0 RESEARCH ..................................................................................................................................9
4.0 RECOMMENDATIONS...............................................................................................................11 REFERENCES..........................................................................................................................................13
ATTACHMENTS
Attachment 1: Sacred Lands File (SLF) Results from the Native American Heritage Commission (NAHC) Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 1
1.0 INTRODUCTION
Kimley-Horn and Associates, Inc. (KHA) conducted an Archaeological Resources Assessment for the 450 North Roxbury Drive Project (Project) area located within the City of Beverly Hills (City) in Los Angeles County, California. This study was completed to support the City, as the Lead Agency under the California Environmental Quality Act (CEQA), and their review of potential impacts to archaeological resources as a result of the proposed Project. A literature review and records search were conducted for the property to identify the likelihood of present archaeological resources that would be adversely impacted by the Project. Due to the existing built environment and inability to survey for archaeological resources, the assessment did not include archaeological fieldwork. Potential impacts to historic built environment resources are addressed in 450 N. Roxbury Drive, Historical Resource Assessment and Project Impacts Analysis prepared in April 2024 by Architectural Resources Group.
1.1 Project Description
The Project is located within the City of Beverly Hills, Los Angeles County, California within Township 1 South and Range 15 West of the USGS Beverly Hills 7.5 minute quadrangle (Figure 1; United States Geological Survey 2022). Specifically, the Project is located at 450 North Roxbury Drive (APN 4343-024- 020), which currently contains a high-rise office building and attached parking garage developed in 1970. The Project area is surrounded by a mix of commercial and residential development and is bounded by Santa Monica Boulevard/State Route 2 (SR-2) to the northwest, Bram Goldsmith Way (an alley) to the northeast, North Roxbury Drive to the southwest, and a medical office to the southeast (Figure 2).
The Applicant is requesting a Zone Text Amendment (ZTA) and General Plan Amendment (GPA) to allow an increase in the maximum floor area ratio (FAR) as a result of the conversion of the ground level of an existing parking structure abutting a public street to retail business(es), as defined in Beverly Hills Municipal Code (BHMC) Section 10-3-100, up to a depth of 70 feet from the front property line, subject to approval of a Development Plan Review pursuant to BHMC Section 10-3-3100.1 In compliance with the proposed ZTA and GPA, the Project is proposing a conversion of 6,797 square feet of an existing parking structure, resulting in a new total of 103,647 square feet of proposed floor area. Pursuant to BHMC Section 10-3-2745, the maximum allowable floor area for the Project Site is 72,960 square feet. Therefore, the 6,797 square feet conversion is approximately 9.3 percent of the existing building square footage (96,850 square feet) and would be less than 10 percent of the maximum allowable floor area for the site. The Project would remove 29 existing parking spaces (including 24 single parking spaces and 5 tandem parking spaces) on the ground floor and restripe the remaining ground level of parking to replace the 3 removed ADA spaces, which would be relocated to be adjacent to the northeastern end of the proposed retail spaces. 1 The ZTA and GPA would apply to the entire Business Triangle of the City; however, future projects that would seek to utilize the ZTA and GPA would be subject to environmental review at such time.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 2
Figure 1: Vicinity Map
126
126 N
Project Vicinity
14 VD
118
VD
W
“IP
Is Calabasas
nta Monica “U 110
/fountains
“D.
Los Ange
187
Santa Monica
“I V
Huntington Park
o
VID
□
VP •P
Redondo Beach
o
N
A
2.51.25 0 2.5 5 7.5 10 O
Kimley>»Horn
East Los
Angeles
National
reation Area
Rancho Palos
Verdes County of Los An<
2 SafeGraph, FAO, METI/NASA, USGS, Bureau of Land Management, EPA, NPS, USFWS
T orrance
o
Santa Clarita
o
Simi Valley
o
Burbank
O
Malibu
o
Inglewood
o
19 Glendale
o x
San Fernando
O
Beverly Hills
o
La Canada
Flintridge
O \
Magic Mountain
Nilderness Area
Topanga State
Park
213
Pasadenans ---- WAD
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 3
Figure 2: Project Area
G-0 /
Project Area
J
es
e.
SM-4 ",
a 4
... s
\\
2 FI
g
g
F0 er.
. e6. % s
6 3
6 I
N
n
E.
y a
r
Weth
GammimSaf 20 10 0 20 40 60 80
F S
—I ab... M | It
Kimley»Horn
s
Blvd
______ ad DNTBOCorrnunity Maps. Contributors, of Alge
“ap, Mlcrzof; Eri, Tornam, G
Tschnologiss, Inic, MET/NASA USG.S, Buesu of Lend Iw
Isislei NPS, US Csnsus Bureau, USDA USFWS, M
%
2 A'
Corn
I Pwwiire"BTVa"
0lag0s, Juic, MEUU/
Fs
%I
*•
022 * V V
axarMICi
e fS
n 5
.. -
.9A
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 4
1.2 Regulatory Setting
California Environmental Quality Act
CEQA applies to all discretionary projects undertaken or subject to approval by the state’s public agencies (California Code of Regulations 14(3), § 15002(i)). Under CEQA, “A project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment” (Cal. Code Regs. Tit. 14(3), § 15064.5(b)). Guidelines for Implementation of CEQA (CEQA Guidelines) Section 15064.5(a) defines a “historical resource” as a resource that meets one or more of the following criteria:
• Listed in, or eligible for listing in, the California Register of Historical Resources (California Register)
• Listed in a local register of historical resources (as defined at Cal. Public Res. Code § 5020.1(k)) • Identified as significant in a historical resource survey meeting the requirements of § 5024.1(g) of the Cal. Public Res. Code
• Determined to be a historical resource by a project’s lead agency (Cal. Code Regs. Tit. 14(3), § 15064.5(a))
A historical resource consists of “Any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California…Generally, a resource shall be considered by the lead agency to be ‘historically significant’ if the resource meets the criteria for listing in the California Register of Historical Resources” (Cal. Code Regs. Tit. 14(3), § 15064.5(a)(3)). The significance of a historical resource is impaired when a project demolishes or materially alters in an adverse manner those physical characteristics of a historical resource that convey its historical significance and that justify its eligibility for the California Register. If an impact on a historical or archaeological resource is significant, CEQA requires feasible measures to minimize the impact (CEQA Guidelines § 15126.4 (a)(1)). Mitigation of significant impacts must lessen or eliminate the physical impact that the project will have on the resource. Section 5024.1 of the Cal. Public Res. Code (PRC) established the California Register. Generally, a resource is considered by the lead agency to be “historically significant” if the resource meets the criteria for listing in the California Register (Cal. Code Regs. tit. 14(3), § 15064.5(a)(3)).
Finally, CEQA requires that significant effects on unique archaeological resources be considered and addressed. CEQA defines a unique archaeological resource as any archaeological artifact, object, or site about which it can be clearly demonstrated that, without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
• Contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information.
• Has a special and particular quality such as being the oldest of its type or the best available example of its type.
• Is directly associated with a scientifically recognized important prehistoric or historic event or person.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 5
CEQA Guidelines Section 15064.5 Appendix G includes significance criteria relative to archaeological and historical resources. These have been utilized as thresholds of significance here, and a project would have a significant environmental impact if it would:
• Cause a substantial adverse change in the significance of a historical resource as defined in Section 10564.5;
• Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 10564.5;
• Disturb any human remains, including those interred outside of formal cemeteries.
California Public Resources Code
California PRC § 5024.1 establishes the California Register of Historical Resources (CRHR). The register lists all California properties considered to be significant historical resources. The CRHR also includes all properties listed or determined eligible for listing in the NRHP, including properties evaluated and determined eligible under § 106.
California PRC § 5020 to 5029.5 continued the former Historical Landmarks Advisory Committee as the State Historical Resources Commission. The commission oversees the administration of the CRHR and is responsible for designating State Historical Landmarks and Historical Points of Interest.
California PRC § 5079 to 5079.65 define the functions and duties of the Office of Historic Preservation, which administers federal- and state-mandated historic preservation programs in California as well as the California Heritage Fund.
California PRC § 5097.9 to 5097.991 provide protection to Native American historical and cultural resources and sacred sites; identify the powers and duties of the Native American Heritage Commission (NAHC); require that descendants be notified when Native American human remains are discovered; and provide for treatment and disposition of human remains and associated grave goods.
California Health and Safety Code
California Health and Safety Code § 7050.5-7055 govern the process for reporting inadvertent discoveries of human remains to the County Coroner; the process for the County Coroner to report human remains of Native American descent to the NAHC; and the protections offered against removal or desecration of human remains.
California Code of Regulations
The California Code of Regulations govern the nomination of resources to the CRHR (14 California Code of Regulations [CCR] § 4850). The regulations set forth the criteria for eligibility as well as guidelines for assessing historical integrity and resources that have special considerations.
California Register of Historical Resources (CRHR)
The State Historical Resources Commission has designed this program for use by State and local agencies, private groups, and citizens to identify, evaluate, register, and protect California’s historical resources. The CRHR is the authoritative guide to the State’s significant historical and archeological resources.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 6
The CRHR program encourages public recognition and protection of resources of architectural, historical, archeological, and cultural significance; identifies historical resources for state and local planning purposes; determines eligibility for state historic preservation grant funding; and affords certain protections under CEQA. To be eligible for listing in the CRHR, a resource must meet at least one of the following criteria:
• Is associated with events that have made a significant contribution to the broad patterns of local or regional history or the cultural heritage of California or the United States. • Is associated with the lives of persons important to local, California, or national history. • Embodies the distinctive characteristics of a type, period, region, or method of construction; represents the work of a master; or possesses high artistic values. • Has yielded, or has the potential to yield, information important to the prehistory or history of the local area, California or the nation.
In addition to having significance, resources must have integrity for the period of significance. The period of significance is the date or span of time within which significant events transpired or significant individuals made their important contributions. Integrity is the authenticity of a historical resource’s physical identity as evidenced by the survival of characteristics or historic fabric that existed during the resource’s period of significance. Alterations to a resource or changes in its use over time may change its historical, cultural, or architectural significance. Simply, resources must retain enough of their historic character or appearance to be recognizable as historical resources and to convey the reasons for their significance. A resource that has lost its historic character or appearance may still have sufficient integrity for the CRHR if, under Criterion 4, it maintains the potential to yield significant scientific or historical information or specific data.
Isolated finds, such as a single artifact with no other associated cultural materials, are generally considered to be ineligible for listing in the CRHR. However, the nature of the isolated resource and any available ethnographic data regarding affiliated Native American populations should be carefully considered during the evaluation process, particularly as it relates to potential eligibility under Criterion
4. California Historical Landmarks
California Historical Landmarks are buildings, structures, sites, or places that have been determined to have statewide historical significance. The resource must be approved for designation by the County Board of Supervisors or the City/Town Council in whose jurisdiction it is located; be recommended by the State Historical Resources Commission; and be officially designated by the Director of California State Parks. A resource must meet at least one of these following criteria:
• Be the first, last, only, or most significant of its type in the state or within a large geographic region (Northern, Central, or Southern California).
• Be associated with an individual or group having a profound influence on the history of California.
• Be a prototype of, or an outstanding example of, a period, style, architectural movement or construction or is one of the more notable works or the best surviving work in a region of a pioneer architect, designer, or master builder.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 7
California Points of Historical Interest
California Points of Historical Interest are sites, buildings, features, or events that are of local (city or county) significance and have anthropological, cultural, military, political, architectural, economic, scientific or technical, religious, experimental, or other value. Points of Historical Interest designated after December 1997 and recommended by the State Historical Resources Commission are also listed in the CRHR. No historical resource may be designated as both a landmark and a point. If a point is subsequently granted status as a landmark, the point designation is retired. To be eligible for designation as a Point of Historical Interest, a resource must meet at least one of the following criteria:
• Be the first, last, only, or most significant of its type within the local geographic region (city or county).
• Be associated with an individual or group having a profound influence on the history of the local area.
• Be a prototype of, or an outstanding example of, a period, style, architectural movement or construction or be one of the more notable works or the best surviving work in the local region of a pioneer architect, designer or master builder.
City of Beverly Hills
The City adopted a Historic Preservation Ordinance (HPO) in 2012, which established the City’s Cultural Heritage Commission (CHC), a local register of historic properties, and the various authorities of the CHC and processes under which the inventory, evaluation, and preservation of registered properties is governed. The HPO underwent a comprehensive update in 2016 after a series of public meetings and review by the Planning Commission and CHC.
1.3 Cultural and Natural Setting
The Project area is located within southern portion of Los Angeles County within the Los Angeles Basin. The Los Angeles Basin is a structural depression that is approximately 50 miles long and 20 miles wide that developed as a result of tectonic forces and the San Andreas Fault zone (Ingersoll and Rumelhart 1999; Critelli et al. 1995). Sediments have eroded into the basin from the surrounding mountains since the middle Miocene (13 million years ago), resulting in thousands of feet of sediment accumulation within the Basin. When the sea level dropped during the Pleistocene (2.58 million to 11,700 years ago), the uppermost layers of the Basin then became composed of alluvial sediments (Yerkes et al. 1965). In the present day, the Project area is mapped as being underlain by younger Quaternary alluvium (Qya), though these native soils have been extensively disturbed due to prior development (Campbell et al. 2016). The area, like much of California, contains a unique and diverse climate and environment. This regional diversity provided Native Californians the ability to exploit a range of different plants, animals, and natural resources.
The proposed Project site is located within the ancestral territory of the Gabrieleño/Tongva. Although Alfred Kroeber recorded the territories of southern California tribes in 1925, the ancient territorial borders remain inexact for two reasons: first, territorial boundaries were flexible and, secondly, indigenous borders and land use were not recorded until after European settlements displaced many Native American communities. Although firm and defining borders cannot be known, archaeological, ethnographic, and historic evidence exists to support the prehistoric use by the Gabrieleño/Tongva Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 8
(Gabrieleño [Tongva] Band of Mission Indians). It is generally understood that their ancestral territory included the watersheds of the San Gabriel, Santa Ana, and Los Angeles Rivers, portions of the Santa Monica and Santa Ana Mountains, the Los Angeles Basin, the coast from Aliso Creek to Topanga Creek, and San Clemente, San Nicolas, and Santa Catalina Islands.
The Gabrieleño/Tongva have a rich and diverse material culture, traditionally including shell set in asphaltum, carvings, painting, baskets, an extensive steatite industry, and a wide range of stone, shell, and bone materials. At the time of European colonization, they inhabited numerous permanent villages in fertile lowlands along waterways in sheltered areas along the coast, each of which held a population in the low hundreds. Smaller villages were also located at varying distances from these permanent villages, all of which were highly connected via economic, religious, and social ties (Bean and Smith 1978). Villages contained circular and domed homes made of tule mats, fern, or carrizo, as well as small, circular earth-covered sweathouses (Kroeber 1925; Bean and Smith (1978). Their hunting and gathering subsistence strategy included land and offshore efforts that resulted in the take of both small and large land animals, sea mammals, river and ocean fish, and a variety of plant resources. The population sometimes migrated between villages on a temporary basis throughout the year, returning to their permanent villages for ceremony or when resources needed to be replenished (Hudson and Blackburn 1982).
Records show that the long history of European colonization and harmful displacement of Native Americans initially began in 1542 as a result of Juan Rodríguez Cabrillo visiting the area during exploration. Following many subsequent Spanish visits to the region, the colonization of the indigenous population continued in 1769 around the same time as the establishment of Missions San Gabriel in 1771 and San Fernando in 1797. Due in part to the introduction of new diseases, as well as the harsh conditions of mission life, the indigenous population quickly dwindled and cultural practices were lost. Following the secularization of the missions, most surviving Gabrieleño/Tongva became wage laborers on the ranchos of Mexican California, and were later nearly completely wiped out as a result of a smallpox outbreak in the 1860s. The combination of removal, murder, disease, forced labor, and poor diet contributed to the harmful diaspora of the Gabrieleño/Tongva from established villages to scattered areas of the Los Angeles Basin for survival (Bean and Smith 1978). This history of displacement within their own ancestral lands has led to difficulty in attaining federal recognition.
However, the 20th century found a revitalization of the Gabrieleño/Tongva people and culture, and though the communities remain unrecognized by the Federal government, they remain a very active people in the Los Angeles area today.
2.0 METHODS
All efforts made for the completion of this report was completed pursuant to requirements set forth in CEQA. This study is intended to identify whether archaeological resources are located within the Project area, whether any present archaeological resources are potentially significant pursuant to the abovereferenced regulations and standards, and to develop specific recommendations that will address potential impacts to existing or potential archaeological resources. Tasks completed include:
• A Sacred Lands File (SLF) search through the NAHC, submitted by the City of Beverly Hills, • A cultural records search through the South Central Coastal Information Center (SCCIC) to identify any studies conducted and/or resources recorded within or adjacent to the Project area, Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 9
• Review of geological and historical maps and imagery to identify the archaeological sensitivity of the project area, and
• Development of recommendations and/or mitigation measures for cultural resources identified or potentially unrecorded within the Project area
3.0 RESEARCH
KHA conducted a records search at the SCCIC on June 27, 2024 to identify any previously recorded archaeological resources or previously conducted cultural resources studies within the Project area plus a 0.5 mile buffer (Figure 3). The results of the records search noted that no previous studies have taken place and no resources have been recorded within the Project area. Further, while twenty-four (24) cultural resources studies have been conducted within 0.5 mile of the Project area, no archaeological resources have been recorded within the buffer area. Due to the level of disturbance that occurred across the Los Angeles Basin many decades before the adoption and implementation of archaeological resource-based regulations, it is likely that much of the archaeological landscape within the area was destroyed prior to the ability to document these resources. As such, it is important to review a negative record search result for archaeological resources in this area alongside other information, such as applicable geological information, historical imagery, and the existing level of development for a specific Project area.
As such, a review of available geologic maps, topographic maps, and historic aerial imagery was conducted for the Project area. Geologic maps show that the Project area is underlain by younger Quaternary alluvium (Qya) (Campbell et al.). Human occupation took place in the more recent Holocene era and, as such, younger geologic units such as those within the Project area typically have a moderateto-high potential for archaeological resources at surface or near surface level. However, historic aerials and topographic maps show that development within the Project area, and therefore, ground disturbance, occurred prior to earliest imagery on file from 1947. Additionally, the Project area looks to have been redeveloped at least once, and currently contains a below-ground garage that expands two levels (Historic Aerials). As a result of this review, it is apparent that the Project area has been subjected to an extensive amount of ground disturbance, including at least 40-50 ft below surface to accommodate a subterranean two-story parking garage.
A SLF search request was submitted to the NAHC by the City of Beverly Hills on June 12, 2024. Results were received on July 2, 2024 noting the results were positive for an SLF within the vicinity of the Project area, and recommended additional outreach be conducted to the Gabrieleño/Tongva San Gabriel Band of Mission Indians (Attachment 1). It is important to note that this repository is not exhaustive and a positive result for only one Native American Tribe does not necessarily indicate the Project area has little to no cultural value to other affiliated Tribes. This type of information, to include whether or not the Project area contains or potentially contains a Tribal Cultural Resource (TCR), as defined by CEQA (as amended, 2014), is most commonly obtained via government-to-government consultation. The City of Beverly Hills will conduct consultation in accordance with CEQA (as amended, 2014) and, as such, the results of consultation and analysis related to whether or not the Project area has potential contain a TCR is not included within this report.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 10
Figure 3: Project Area Plus 0.5 Mile Buffer
2 B e 2__ __
■ n?
Project Area Plus 0.5 Mile Buffer
J 77 221
1. 3
1 5, a
)
( R
A 1 ! C
M.
VI S G N
v Park
> ■ft P
9 O. 6 ie VE 4
ii 4 % ’
L
--
J
A iG E!
A 1 S
2 — . —= O ibrary
32° 4
X ( n
— V V e
20 8 C
SH) Bl BM
13 y
Q BN24 0 T7 F
§
&
8 8
9 I
9 5
F
J A' s ati g
9 as J i
i
3 Jwr Idw pre
c
3 d IPI:
Q vo 8
o
8 try.. ,\ 8
si I V
/
Ci
• 8 N
>1 IET5 CENT
KSUDIOS
7 i
Al Well ors8Oil ells
UB
V 10
X
300 150 0 300 600 900 1
98 VSCew. s %
3 ?
MM---
COUNTRY
9 >
/
t
1 tu i
O.
-o.
1,200
Meters
&
D
J
A• C
U
pw
/
N
V
. Bl
v.
LOS ANGELES COUNTRY CLUB )
Y
0 o%
I
I
U
Roxbury
Park
C o
_W"HDE=nHHEWA""H"E Maranannu
Pam
s
TW OR
r Y<:O) IM Uniu 5
171
\
I O
Ai
I
© “W
j
/
i ( 16733 Socety=i.cu
o
wr
l
I
phi
(Z4
Kimley»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 11
4.0 RECOMMENDATIONS
No archaeological resources were identified within the Project area as a result of the records search and associated research. Additionally, it is unlikely that undisturbed archaeological resources are present within the Project area given the extent of prior development. As such, no archaeological resources that meet the definition of “Historical Resources” or “Unique Archaeological Resources”, as defined by CEQA, have been identified within the Project area as a result of this study. However, it is important to note that this report does not include discussion related to the presence of TCR, as defined by CEQA (as amended, 2014), as this is determined via government-to-government consultation between the City of Beverly Hills and Native American Tribes. As such, recommendations made within this report as it relates to archaeological resources of Native American origin should be considered alongside the results of Tribal consultation.
Though the report concludes that intact archaeological resources are unlikely to be present within the Project area, conditions of approval should be included that outline the process for treatment of any archaeological resources and/or human remains inadvertently discovered during Project implementation. With such conditions of approval in place, impacts to archaeological resources would be less than significant. An example of such conditions, which may be updated as a result of Tribal consultation, are included below:
1. Inadvertent Discovery of Archaeological Resources: In the event that any archaeological resources are encountered during Project implementation, all activities shall immediately cease within 50 feet of the discovery. The applicant shall immediately notify the City and an archaeologist that meets Secretary of Interior (SOI) professional qualifications (Project Archaeologist) who shall evaluate the find in accordance with State and local guidelines and make a recommendation to the City related to the potential significance of the resource. The City shall also contact consulting Native American Tribes regarding any finds of Native American origin to review the potential for the resource as a Tribal Cultural Resource (TCR). If any find is determined to be significant and/or a TCR, the Project Archaeologist shall make recommendations related to avoidance of the resource or, if avoidance is determined to be infeasible by the City, other appropriate treatment measures to minimize impacts to the resource (i.e., data recovery/excavation). Should data recovery/excavation be the chosen treatment for the resource, the City shall confer with the Project Archaeologist and, for resources of Native American origin, consulting Tribes to identify final disposition (i.e., reburial, curation, etc.). All agreed upon treatment activities will be overseen by the Project Archaeologist and, for resources of Native American origin, by representatives of consulting Tribes who wish to place a monitor on site for these efforts. The Project Archaeologist shall draft a report that speaks to the discovery, recordation, evaluation, treatment, and final disposition of the resource and submit the draft to the City for review. All documents related to the resource shall be submitted to the City and the South Central Coastal Information Center (SCCIC) once finalized.
2. Inadvertent Discovery of Human Remains. In the event that human remains are identified during project implementation, all activities shall halt immediately within 100 feet of the discovery and all actions outlined within California Health and Safety Code Section 7050.5 and California Public Resources Code Section 5097.98 shall be followed. This includes immediate Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 12
notification to the County Coroner, who will be responsible for identifying if the remains are related to criminal activity or if they are of Native American origin. If the remains are determined to be Native American, the County Coroner shall contact the Native American Heritage Commission within 24 hours, who will then designate and contact a Most Likely Descendant (MLD). The MLD has 48 hours to visit the site of discovery and make recommendations to the landowner related to appropriate disposition. Should the landowner and MLD disagree on disposition, the matter may be mediated by the NAHC. Should mediation fail, the landowner is required to reinter the remains with appropriate dignity on the property in a location that will not be subject to further disturbance.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
September 2024
Page | 13
REFERENCES
Bean, Lowell John, and Charles R. Smith. 1978. Gabrielino. In Handbook of North American Indians, Vol. 8, California. William C. Sturtevant, gen. ed., Robert F. Heizer, vol. ed. Washington: Smithsonian Institution.
Critelli, S. P. Rumelhart, and Ingersoll, R. 1995. Petrofacies and provenance of the Puente Formation (middle to upper Miocene), Los Angeles Basin, southern California: implications for rapid uplift and accumulation rates. Journal of Sedimentary Research A65: 656-667.
Campbell, R.H., Wills, C.J., Irvine, P.J., and B.J. Swanson. 2016. Preliminary geologic map of the Los Angeles 30’ X 60’ quadrangle, California. 1:100,000. Preliminary Geologic Maps PGM-13-
06.2016.
Gabrieleño (Tongva) Band of Mission Indians Government Website. https://www.gabrielenonsn.us/maps. Accessed June 27, 2024.
Historic Aerials. https://www.historicaerials.com/viewer. Accessed June 30, 2024 Hudson, Travis, and Blackburn, Thomas C. 1982. The Material Culture of the Chumash Interaction Sphere, Volume III: Clothing, Ornamentation, and Grooming. Ballena Press Anthropological Papers, No. 28.
Ingersoll, R. V. and P. E. Rumelhart. 1999. Three-stage basin evolution of the Los Angeles basin, southern California. Geology 27: 593-596.
Kroeber, Alfred L. 1925. Handbook of the Indians of California. Bureau of American Ethnology Bulletin No. 78. Washington D.C.: Smithsonian Institution. Reprinted in 1976, New York: Dover.
United States Geological Survey. 2022. Beverly Hills, California 7.5-minute topographic quadrangle map.
Yerkes, R.F., T.H. McCulloh, J.E. Schollhamer, and J.G. Vedder. 1965. Geology of the Los Angeles Basin:
an introduction. Geological Survey Professional Paper 420-A.
Kimley>»Horn
City of Beverly Hills 450 North Roxbury Drive Project
Archaeological Resources Assessment
ATTACHMENT 1
Sacred Lands File (SLF) Results from the Native American Heritage Commission (NAHC) STATE OF CALIFORNIA Gavin Newsom, Governor
NATIVE AMERICAN HERITAGE COMMISSION