Attachment 1_Resolution Certifying EIR etc.pdf — City Council Meeting Agenda, December 5, 2022

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RESOLUTION NO. 2022-R_____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CULVER CITY, (1)

CERTIFYING THE FINAL ENVIRONMENTAL IMPACT REPORT SCH
NO. 2021110079; (2) ADOPTING FINDINGS REQUIRED BY CEQA AND A

STATEMENT OF OVERRIDING CONSIDERATIONS BASED ON AN
ASSESSMENT OF PROJECT BENEFITS AGAINST THE PROJECT’S
SIGNIFICANT AND UNAVOIDABLE IMPACTS ; AND (3) MITIGATION

MONITORING PROGRAM IN COMPLIANCE WITH THE CALIFORNIA

ENVIRONMENTAL QUALITY ACT, FOR THE CROSSINGS CAMPUS PROJECT

(P2021-0272-EIR)

WHEREAS, on May 31, 2022, Culver Crossings Project LLC (the “Applicant” and “Owner”) filed an application for a Zoning Map Amendment and Comprehensive Plan, to construct a 536,000 square foot office development on a 4.46 -acre site. The development would include two buildings, one that is four story and the other five story. Both buildings include 3 levels of subterranean parking (the “Project”). The project would include two parcels, one in Culver City and one in Los Angeles. The Project is more specifically described by Los Angeles County Assessor Parcel Numbers 4312-015-005 in the City of Los Angeles, County of Los Angeles, State of California and by Los Angeles County Asse ssor Parcel Numbers 4312-015-006 in the City of Culver City, County of Los Angeles, State of California and 4312- 015 at 8833 and 8825 National Boulevard and 8771 Washington in Culver City, California, 90232 (Culver City Parcel); and 8876, 8884, 8886, And 8888 Venice Boulevard and 8827 and 8829 National Boulevard in Los Angeles; and
WHEREAS, the Project is a creative office campus that could include associated production spaces for multimedia content creation and capture. The development, including both Culver City and LA segments would be 536,000 square feet on a 4.46 -acre site. The development would include two multi -story buildings. Both buildings include 3 levels of

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subterranean parking. The City of Culver City is the lead agency for the CEQA environmental review process.

Culver Crossings Properties LLC, the Applicant, proposes to develop th e Crossings Campus Project (Project) , an office project on an approximately 4.46 -acre (194,334-square- foot [sf]) site consists of two properties: one 1.63 -acre (71,016 sf) parcel is located in the City of Culver City (Culver City Parcel) while the second 2.83-acre (123,318 sf) parcel is located in the City of Los Angeles (Los Angeles Parcel) (collectively referred to herein as the Project Site).

The Project Site is bounded by Venice Boulevard to the north, Washington Bo ulevard to the south, National Boulevard to the west, and existing commercial uses to the east. The Project Site is located at 8833 and 8825 National Boulevard and 8771 Washington in Culver City, California, 90232 (Culver City Parcel); and 8876, 8884, 8886, and 8888 Venice Boulevard and 8827 and 8829 National Boulevard in Los Angeles, California, 90232 (Los Angeles Parcel).

The Culver City Parcel is located to the east of the Downtown District of Culver City and in the Washington National Transit Oriented D evelopment District. The Los Angeles Parcel is located in the West Adams –Baldwin Hills –Leimert Community Plan area of Los Angeles.

Primary regional access is provided by two freeways; the Santa Monica Freeway (I-10) located approximately 630 feet north of the Project Site and the San Diego Freeway (I -405), located approximately 2.09 miles west of the Project Site. The Project Site is also served by the Los Angeles County Metropolitan Transportation Authority (Metro) “E” Line and multiple Metro and local bus lines that provide service along Venice, National, and Washington Boulevards.

The Project Site is currently improved with single -story warehouses that have been converted into retail, office, and surface and enclosed parking lots serving the existing uses on the Project Site. The Project Site is mostly flat with gradual sloping from north to south.

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Landscaping on the Project Site is limited to parking medians, street edge, and building perimeter planting.

The Culver City Parcel is currently developed with two buildings: (1) a 9,739-sf building that is currently used for storage; and (2) a 9,082 -sf building that is currently vacant. The two existing buildings total 18,821 sf of floor area. The balance of the Culver City Parcel consists of surface p arking and vehicular access that supports the existing uses on the Project Site.

Vehicular access to the Culver City Parcel is provided along National Boulevard. Pedestrian access to the Culver City Parcel is provided along National Boulevard and on Washin gton Boulevard at the southern edge of the Project Site.

The Los Angeles Parcel is currently improved with an 86,226-sf warehouse building that has been partitioned into six separate spaces consisting of 51,500 sf of office and 34,726 sf of retail. In addition to the floor area, there are 70 spaces of enclosed vehicular parking. Vehicular access to the Los Angeles Parcel is provided via the Culver City Parcel from National Boulevard. Pedestrian access is provided along the western edge on National Boulevard and via the northern edge of the site along Venice Boulevard.

The Project would involve demolition of the three existing buildings on the Project Site, totaling 105,047 sf, to support the proposed 536,000 sf integrated office complex. The Project would consist of two buildings, one on each of the two properties that comprise the Project Site.

Building 1 (on the Culver City Parcel) involves demolition of existing surface parking and two buildings totaling 18,821 sf and construction of a new 167,000 -sf office building. Building 1 would be four stories, measuring up to 56 feet in height to the top of the roofline, with a three - level subterranean garage containing 478 vehicular parking spaces and 51 bicycle parking spaces. Building 2 (on the Los Angeles Parcel) involves demolition of the existing building

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totaling 86,226 sf and construction of a new 369,000-sf office building. Building 2 would be four to five stories, measuring 56 feet to 75 feet in height to the top of the roof, with a three -level subterranean garage containing 738 vehicular parking spaces and 124 bicycle parking spaces.

The Project would include office space suitable for approximately 2,400 occupants and could include associated production spaces for multimedia content creation and capture.

Amenities for the building tenants would include an employee cafeteria, coffee stations, employee shuttle service, and other ancillary amenities typical of an integrated office complex development. The total floor area for the Project at final build -out would be 536,000 sf, with a floor area ratio (FAR) of 2.76:1. The Project would also include pedestrian -facing landscaping at the ground floor on National Boulevard and Venice Boulevard, a 7,120-sf publicly accessible, privately maintained open space amenity a long Washington Boulevard, as well as 51,600 -sf internal courtyard for the use of employees and occasional private tenant events. Construction is anticipated to start in April of 2022, subject to Project approval and is anticipated to be completed May of 2024; and
WHEREAS, in order to implement the proposed Project, approval of the following land use permits (collectively, “Entitlements”) are required:

1. Zone Map Amendment P2022-0144-ZMA, for the change of the existing designations from Industrial Commercial (IG) and East Washington Overlay (-EW) Zone to Planned Development (PD), to ensure the proper rezoning of the property and maintain consistency with the General Plan designation; and

2. Comprehensive Plan ( P2022-0144-CP): To ensure the Project is in compliance with all required standards and City ordinances, and establish all onsite and

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offsite conditions of approval to reflect the site features and compatibility of the proposed Project with the uses on adjoining properties; and

3. Extended Construction Hours Request, a land use entitlement allowing an additional hour of construction in the morning increasing the allowed construction time to 7:00 am to 8:00 pm to allow for specific constructive activity including pouring concrete grading and excavation; and
WHEREAS, the California Environmental Quality Act of 1970, as amended (California Public Resources Code 21000, et. seq.; and California Code of Regulations, Title 14, Ch. 3 15000, et. seq.; collectively, “CEQA”), gives to the lead agency the responsibility for considering the effects of a project, both individual and collective, of all physical development activities involved when action is taken by a lead agency to approve a Project; and WHEREAS, the City prepared an Initia l Environmental Study (Initial Study) for the Project, which determined that the Project may have a significant effect on the environment and that an Environmental Impact Report must be prepared. The Initial Study determined that the following areas must b e addressed in the Project EIR: aesthetics, air quality, cultural resources (historical resources and archaeological resources), energy, geology and soils, greenhouse gas emissions, hazards and hazardous materials, hydrology and water quality, land use and planning, noise, public services (fire and police), transportation, tribal cultural resources and Utilities and Service Systems (Water Supply and Waste Water); and WHEREAS, the City prepared a Notice of Preparation (“NOP”) of the Draft EIR, which was circ ulated to the affected agencies and the public, pursuant to CEQA for thirty days beginning on November 4, 2021, and numerous comments from agencies and the public were

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received in response. The City held a public scoping meeting on December 6, 2021, to obt ain information from the public as to issues that should be addressed in the Draft EIR; and WHEREAS, the City in accordance with provisions of CEQA Guidelines Sections 15085(a) and 15087(a), the City, serving as the Lead Agency: (1) prepared and transmitte d a Notice of Completion (NOC) to the State Clearinghouse; (2) published a Notice of Availability (NOA) of a Draft EIR which indicated that the Draft EIR was available for public review at the City’s Current Planning Division; (3) provided copies of the NO A and Draft EIR to the Culver City Julian Dixon Library; (4) posted the NOA and the Draft EIR on the City’s Planning Division website: https://www.culvercity.org/City-Projects/G-Planning-Projects; (5) sent a NOA to all property owners within 1,000 feet of the Project Site; (6) sent a NOA to the last known name and address of all organizations and individuals who previously requested such notice in writing or attended public meetings about the Projec t; and (7) filed the NOA with the County Clerk.

The public review period commenced on July 21, 2022, and ended on September 6, 2022, for a total of 47 days. The City conducted a virtual Community Meeting focused on the Project and a Public Meeting focused on the Draft EIR on August 16, 2022; and WHEREAS, the City received numerous written and oral comments to the Draft EIR, prepared responses to those comments and made appropriate changes to the Draft EIR. Those changes, comments and responses were made a part of the Final EIR for the Project in compliance with California Public Resources Code, Section 21092.5. The proposed written responses to comments from public agencies received during the 47-day review period were provided to such agencies and the Final EIR was made available on October 12, 2022; and WHEREAS, the Final Environmental Impact Report (EIR) includes the Draft EIR, dated July 2022, responses to written comments on the Draft EIR, responses to public testimony

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regarding Draft EIR issues raised during the public comment period, modifications to the Draft EIR text, and the Mitigation Monitoring Program (MMP). The Final EIR was prepared and circulated in compliance with CEQA; and
WHEREAS, on November 9, 2022, the Planning Commission held a duly noticed public meeting to receive public comment on the Final EIR and consider the proposed Final EIR.

During the course of the public hearing, the Planning Commission considered staff and consultant presentations, written comments received from public agencies and the public, staff reports, Applicant presentations, information presented to the Planning Commission to assist its understanding of the Project, the Final EIR, CEQA Findings of Fact and Statement of Overriding considerations and public comments and testimony on the Project. In addition, the Planning Commission considered the Final EIR prepared for the Project, including information provided in staff reports, the amended text of the Final EIR, information presented from experts and in public testimony , including letters submitted to the Planning Commission following the close of the public hearing before the Planning Commission, and other matters in the public record; and
WHEREAS, following conclusion of the public discussion and thorough deliberation of the subject matter, the Planning Commission , by a vote of 4 to 0, adopted Resolution 2021 - P019 recommending to the City Council ( 1 ) certification of the Final Impact Report SCH No. 2016111044; (2) adoption of CEQA findings and a mitiga tion monitoring program, in compliance with the California Environmental Quality Act, for Zoning Map Amendment P2022- 0144-ZMA, Comprehensive Plan P2021 -0144-CP; (3) approva l of Zoning Map Amendment P2022-0144-ZMA and Comprehensive Plan P2021-0144-CP; and (4) approval of Extended Construction Hours Request for the Project.

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NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CULVER CITY, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:

SECTION 1. GENERAL FINDINGS. Pursuant to the foregoing recitations, the following findings and hereby made:

1. Based on the findings contained in the Initial Study prepared by the City, it was determined that the proposed Project may have a significant effect on the environment and an EIR is required.

2. The Draft and Final EIRs, including the technical appendices and responses to comments, were prepared, circulated, and completed in compliance with CEQA.

3. Revisions have been appropriately made to the Draft EIR and such revisions, including responses to comments, and other documents related to the Draft EIR have been made a part of or incorporated into the Final EIR.

4. The revisions made to the Draft EIR and incorporated into the Final EIR do not require recirculation of the Draft EIR based on the following:
a. No significant new information has been added that would deprive the public of a meaningful opportunity to comment on a substantial adverse environmental effect of the project, a feasible way to mitigate or avoid such an impact that the Applicant has declined to implement, or a feasible project alternative; b. The new information, including certain factual corrections and minor changes, provides clarification to points and information already included in the Draft EIR; c. There are not significant new environmental impacts resulting from the Project from a new mitigation measure proposed to be implemented;

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d. There is no substantial increase in the sev erity of an environmental impact that has not been mitigated to a level of insignificance;
e. The Applicant has not declined to adopt any feasible project alternatives or mitigation measures, considerably different from others previously analyzed, that clearly lessen the environmental impacts of the Project; and f. The Draft EIR is not fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment precluded.

5. The Final EIR accurately describes the Project and identifies the discretionary approvals necessary for the project as listed in the recitations above.

6. The Final EIR adequately analyzes all of the potentially significant environmental impacts of approval of the Project, mitigation measures, environmental impact s and cumulative impacts which have been mitigated to a less than significant level, alternatives to the Project on the Project site, short-term and long-term impacts, growth inducing impacts, and significant and unavoidable impacts.

SECTION 2. CERTIFICATION FINDINGS. Based upon the above recitals and the entire record, including, without limitation, the Crossings Campus Draft and Final EIR, oral and written testimony and other evidence received, at the public hearings held on the Project and the Final EIR, the City Council further finds:

1. That the EIR for the Project is adequate, complete, and has been prepared in accordance with the California Environmental Quality Act (CEQA).

2. That the City Council has independently reviewed and considered the EIR in reachi ng its conclusions.

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3. The City Council has reviewed and considered in the EIR as well as the whole of the administrative record and the evidence and testimony presented in this matter, prior to making its decision on the Project.

4. The City Council find s that the Final EIR reflects the decision -maker’s independent judgment and analysis.

5. The City Council finds that a mitigation monitoring program (MMP) has been prepared and is adopted to enforce the mitigation measures required by the Final EIR and Project approvals (Exhibit B).

APPROVED and ADOPTED this 5th day of December 2022.

__________________________
DR. DANIEL LEE, Mayor
City of Culver City, California

ATTESTED BY: APPROVED AS TO FORM:

___________________________
JEREMY BOCCHINO, City Clerk HEATHER BAKER, City Attorney

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EXHIBIT A

FINDINGS REQUIRED BY CEQA
I. INTRODUCTION
The Environmental Impact Report (EIR), consisting of the Draft EIR and the Final EIR, is intended to serve as an informational document for public agency decision -makers and the general public regarding the objectives and components of the Cro ssings Campus Project (Project), an office project on an approximately 4.46 -acre (194,334 -square-foot [sf]) site consists of two properties: one 1.63-acre (71,016 sf) parcel is located in the City of Culver City (Culver City Parcel), while the second 2.83-acre (123,318 sf) parcel is located in the City of Los Angeles (Los Angeles Parcel) (collectively referred to as the Project Site). The Project Site is bounded by Venice Boulevard to the north, Washington Boulevard to the south, National Boulevard to the west, and existing commercial uses to the east. The Project Site is located at 8833 and 8825 National Boulevard and 8771 Washington in Culver City, California, 90232 (Culver City Parcel); and 8876, 8884, 8886, and 8888 Venice Boulevard and 8827 and 8829 National Boulevard in Los Angeles, California, 90232 (Los Angeles Parcel). The Project would involve demolition of the three existing buildings on the Project Site, totaling 105,047 sf, to support the proposed 536,000 sf integrated office complex. The Pro ject would consist of two buildings, one on each of the two properties that comprise the Project Site. Building 1 (on the Culver City Parcel) involves demolition of existing surface parking and two buildings totaling 18,821 sf and construction of a new 167,000-sf office building. Building 1 would be four stories, measuring up to 56 feet in height to the top of the roofline, with a three -level subterranean garage containing 478 vehicular parking spaces and 51 bicycle parking spaces. Building 2 (on the Los Angeles Parcel) involves demolition of the existing building totaling 86,226 sf and construction of a new 369,000 -sf office building. Building 2 would be four to five stories, measuring 56 feet to 75 feet in height to the top of the roof, with a three -level subterranean garage containing 738 vehicular parking spaces and 124 bicycle parking spaces.

The Project would include office space suitable for approximately 2,400 occupants and could include associated production spaces for multimedia content creation and capture. Amenities for the building tenants would include an employee cafeteria, coffee stations, employee shuttle service, and other ancillary uses typical of an integrated office complex development. The total floor area for the Project at final build-out would be 536,000 sf, with a floor area ratio (FAR) of

2.76:1. The Project would also include pedestrian -facing landscaping at the ground floor on National Boulevard and Venice Boulevard, a 7,120-sf publicly accessible, privately maintained amenity area along Washington Boulevard, as well as a 51,600 -sf internal courtyard for the use of employees and occasional private tenant events.

The City of Culver City (the City), as Lead Agency, has evaluated the environmental impacts of implementation of the Project by preparing an EIR (Case Number P2021 -0272-EIR/State Clearinghouse No. 2021110079). The EIR was prepared in compliance with the California Environmental Quality Act of 1970, Public Resources Code (PRC) Section 21000 et seq. (CEQA) and the Califor nia Code of Regulations Title 15, Chapter 6 (the CEQA Guidelines).

The findings discussed in this document are made relative to the conclusions of the EIR.

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CEQA Section 21002 provides that “public agencies should not approve projects as proposed if there are feasible alternatives or feasible mitigation measures available which would substantially lessen the significant environmental effects of such projects[.]” The procedures required by CEQA “are intended to assist public agencies in systematically identifying both the significant effects of proposed projects and the feasible alternatives or feasible mitigation measures which will avoid or substantially lessen such significant effects.” CEQA Section 21002 goes on to state that “in the event [that] specif ic economic, social, or other conditions make infeasible such project alternatives or such mitigation measures, individual projects may be approved in spite of one or more significant effects thereof.” The mandate and principles announced in CEQA Section 2 1002 are implemented, in part, through the requirement that agencies must adopt findings before approving projects for which EIRs are required. (See PRC § 21081[a]; CEQA Guidelines § 15091[a].) For each significant environmental impact identified in an E IR for a proposed project, the approving agency must issue a written finding, based on substantial evidence in light of the whole record, reaching one or more of the three possible findings, as follows:
1) Changes or alterations have been required in, or incorporated into, the project that avoid or substantially lessen the significant impacts as identified in the EIR. 2) Such changes or alterations are within the responsibility and jurisdiction of another public agency and not the agency making the finding. Such changes have been, or can or should be, adopted by that other agency.
3) Specific economic, legal, social, technological, other considerations, including considerations for the provision of employment opportunities for highly trained workers, make infeasible the mitigation measures or alternatives identified in the EIR.

The findings reported in the following pages incorporate the facts and discussions of the environmental impacts that are found to be significant in the Final EIR for the Project, as fully set forth therein. Although CEQA Guidelines Section 15091 of the does not require findings to address environmental impacts that an EIR identifies as merely “potentially significant,” these findings nevertheless fully account for all such effects identified in the Final EIR for the purpose of better understanding the full environmental scope of the Project. For each environmental issue analyzed in the EIR, the following information is provided:
• Description of Significant Effects – A description of the environmental effects identified in the EIR.
• Project Design Features – A list of the project design features or actions that are included as part of the Project.
• Mitigation Measures – A list of the mitigation measures that are required as part of the Project to reduce identified significant impacts.
• Finding – One or more of the three possible findings set forth above for each of the significant impacts.
• Rationale for Finding – A summary of the rationale for the finding(s).

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• Reference – A reference of the specific section of the EIR which includes the evidence and discussion of the identified impact.

With respect to a project for which significant impacts are not avoided or substantially lessened either through the adoption of feasible mitigation measures or feasible environmentally superior alternatives, a public agency, after adopting proper findings based on substantial evidence, may nevertheless approve the project, if the agency first adopts a statement of overriding considerations setting forth the spe cific reasons why the agency found that the project’s benefits rendered acceptable its unavoidable adverse environmental effects. (CEQA Guidelines § 15093, 15043[b]; see also PRC § 21081[b].) II. ENVIRONMENTAL REVIEW PROCESS
For purposes of CEQA and these Findings, the Record of Proceedings for the Project includes, but is not limited to, the following documents:

Initial Study. The Project was reviewed by the Planning Division of Culver City (serving as Lead Agency) in accordance with the requirements of CEQA (PRC § 21000, et seq.). The City prepared an Initial Study in accordance with CEQA Guidelines Section 15063(a).

Notice of Preparation. Pursuant to CEQA Guidelines Section 15082, the City then circulated a Notice of Preparation (NOP) to State, regional and local agencies, and members of the public for a 45 -day comment period commencing on November 4, 2021. The purpose of the NOP was to formally inform the public that the City was preparing a Draft EIR for the Project, and to solicit input regarding the scope and content of the environmental information to be included in the Draft EIR. In addition, a virtual Community Meeting and an EIR Scoping Meeting were held regarding the Project on December 6, 2021. Thirty -eight comment letters responding to the NOP were submitted to the City by various public agencies, interested organizations, and individuals. The NOP, Initial Study, and comment letters are included in Appendix A of the Draft EIR.

Draft EIR. The Draft EIR evaluated in detail the potential effects of the Project. It also analyzed the effects of a reasonable range of four alternatives to the Project, including a “No Project” alternative. The Draft EIR for the Project (State Clearinghouse No. 2021110079), incorporated herein by reference in full , was prepared pursuant to CEQA and the CEQA Guidelines. The Draft EIR was circulated for a 47 -day public comment period beginning on July 21, 2022 and ending on September 6, 2022. Copies of the written comments received are provided in the Final EIR. Pursuant to CEQA Guidelines Section 15088, the City, as Lead Agency, reviewed all comments received during the review period for the Draft EIR and responded to each comment in Section 2 of the Final EIR.

Notice of Completion. A Notice of Completion was sent with the Draft EIR to the Governor’s Office of Planning and Research State Clearinghouse for distribution to State Agencies on July 21, 2022, and notice was provided in newspapers of general and/or regional circulation.

Final EIR. The City published a Final EIR for the Project on October 12, 2022, which is hereby incorporated by reference in full. The Final EIR is intended to serve as an informational document for public agency decision-makers and the general public regarding objectives and

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components of the Project. The Final EIR addresses the environmental effects associated with implementation of the Project, identifies feasible mitigation measures and alternatives that may be adopted to reduce or eliminate these impacts, and includes written respons es to all comments received on the Draft EIR during the public review period. Responses were sent to all public agencies that made comments on the Draft EIR at least 10 days prior to certification of the Final EIR pursuant to CEQA Guidelines Section 15088 (b). In addition, all individuals that commented on the Draft EIR also received a copy of the Final EIR. The Final EIR was also made available for review on the City’s website. Notices regarding availability of the Final EIR were sent to those owners within a 500-foot radius of the Project Site, as well as individuals who commented on the Draft EIR, provided comments during the NOP comment period, or requested notice.

Public Hearing. A duly noticed public hearing for the Project was held by the Current Planning Division on November 9, 2022.

III. RECORD OF PROCEEDINGS
For purposes of CEQA and these Findings, the Record of Proceedings for the Project includes, but is not limited to, the following documents and other materials that constitute the administrative record upon which the City approved the Project. The following information is incorporated by reference and made part of the record supporting these Findings of Fact:
• All Project plans and application materials, including supportive technical reports; • The Draft EIR and Appendices, Final EIR and Appendices, and all documents relied upon or incorporated therein by reference;
• The Mitigation Monitoring Program (MMP) prepared for the Project; • The Culver City General Plan and related EIR;
• The City of Los Angeles General Plan and related EIR; • The Southern California Association of Governments (SCAG)’s 2016 -2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) and related EIR (SCH No. 2015031035);
• The Culver City Municipal Code, including, but not limited to, the Zoning Ordinance; • The City of Los Angeles Municipal Code, including, but not limited to, the Zoning Ordinance and Subdivision Ordinance;
• All records of decision, resolutions, staff reports, memoranda, maps, exhibits, l etters, minutes of meetings, summaries, and other documents approved, reviewed, relied upon, or prepared by any City commissions, boards, officials, consultants, or staff relating to the Project;
• Any documents expressly cited in these Findings of Fact, in addition to those cited above; and

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• Any and all other materials required for the record of proceedings by PRC Section 21167.6(e).

Pursuant to PCR Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e), the documents and other materials that constitute the Record of Proceedings upon which the City has based its decision are located in and may be obtained from the Current Planning Division, as the custodian of such documents and other materials that constitute the record of proceedings, located at Culver C ity Hall, 9770 Culver Boulevard, 2 nd Floor, Culver City, CA 90232.

In addition, copies of the Draft EIR and Final EIR are available on the City’s Planning Division website at: https://www.culvercity.org/City-Projects/G-Planning-Projects). Copies were also available for in -person review at the Culver City Julian Dixon Library, Baldwin Hills Branch Library, and City of Los Angeles Central Library.

IV. DESCRIPTION OF THE PROJECT
The Project Site is currently improved with single single -story warehouses that have been converted into retail, office, and surface and enclosed parking lots serving the existing uses on the Project Site. The Project Site is mostly flat with gradual sloping from north to south.

Landscaping on the Project Site is limited to parking medians, street edge, and building perimeter planting.

The Culver City Parcel is currently developed with two warehouse buildings: (1) a 9,739 -sf building that is currently used f or storage; and (2) a 9,082 -sf building that is currently vacant.

The two existing buildings total 18,821 sf of floor area. The balance of the Culver City Parcel consists of surface parking and vehicular access that supports the existing uses on the Project Site. Vehicular access to the Culver City Parcel is provided along National Boulevard.

Pedestrian access to the Culver City Parcel is provided along National Boulevard and on Washington Boulevard at the southern edge of the Project Site.

The Los Angeles Parcel is currently improved with an 86,226 -sf warehouse building that has been partitioned into six separate spaces consisting of 51,500 sf of office and 34,726 sf of retail. In addition to the floor area, there are 70 spaces of enclosed vehicular parking. Vehicular access to the Los Angeles Parcel is provided via the Culver City Parcel from National Boulevard. Pedestrian access is provided along the western edge on National Boulevard and via the northern edge of the site along Venice Boulevard.

The Project would involve demolition of the three existing buildings on the Project Site, totaling 105,047 sf, to support the proposed 536,000 -sf integrated office complex. The Project would consist of two buildings, one on each of the two properties that co mprise the Project Site.

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four to five stories, measuring 56 feet to 75 feet in height to the top of the roof, with a three - level subterranean garage containing 738 vehicular parking spaces and 124 bicycl e parking spaces.

2.76:1. The P roject would also include pedestrian -facing landscaping at the ground floor on National Boulevard and Venice Boulevard, a 7,120-sf publicly accessible, privately maintained amenity area along Washington Boulevard, as well as a 51,600 -sf internal courtyard for the use of employees and occasional private tenant events.

1. Project Site Zoning/Land Use Designations
The Culver City Parcel: The General Plan land use designation of the Culver City component of the Project Site is General Corridor Commercial. Within Culver City, Washington Boulevard is primarily designated as General Corridor Commercial and, in the Project area, this designation encompasses both sides of Washington Boulevard between Helms Avenue and Robertson Boulevard. Both sides of National Boulevard are also designated as General Corridor Commercial along the Project Site and south to a point at which National Boulevard turns to the southeast. At this point, the south side of National Boulevard is designated as Industrial. A Low Density Residential (two-family) residential neighborhood is generally located to the south of the Industrial designated area of National Boulevard near the Project Site. A Medium Density Residential land use designation is located south of Washington Boulevard’s General Corridor Commercial designation to the southeast of the Project Site on both sides of Helms Avenue. The General Corridor Commercial designation allows a range of small - to medium-scale commercials uses, with an emphasis on community -serving retail to which patrons often travel by car. The General Corridor Commercial designation is intended to support desirable existing and future neighborhood and community servicing commercial uses, and limited medium -density housing opportunities comp atible with adjacent residential neighborhoods. The designation is characterized by areas with a two - to three-story height limit, recognizing the proximity to residential neighborhoods and the other Commercial Corridor designated areas with a height limit up to 56 feet.

The zoning designation of the Culver City portion of the Project Site is Industrial General (IG) District but carries a General Plan designation of General Corridor. According to Culver City Municipal Code (CCMC) Section 17.230.010.B, the IG Zone applies to areas appropriate for a wider variety of industrial use than that permitted under the Light Industrial (IL) Zone.

The Los Angeles Parcel : The Los Angeles portion of the Project Site is located in the West Adams–Baldwin Hills–Leimert Community Plan (Community Plan) and designated Community Center (Transit -Oriented Development Area, Commercial Node). The City of Los Angeles’ commercial hierarchy is derived from the General Plan Framework Element but defined in the Community Plan and inclu des the following four general categories: Regional Center, Commercial Center, Neighborhood District, and Mixed -Use Boulevard. Community Centers

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intensify business and social activity compared to Neighborhood Centers. They contain uses that serve the lar ger community and are generally medium scaled , although this varies depending on the character of the surrounding area. Community Centers, as with the Project area, are often served by small shuttles, local and rapid buses, or subway stops.

The Project Site is designated under the Community Plan and the West Adams–Baldwin Hills– Leimert Community Plan Implementation Overlay as within the Venice/National Transit Oriented District (TOD) Subarea. As described in the Community Plan, the purpose of TODs is to p romote more livable communities by minimizing traffic and pollution impacts from traveling for purposes of work, shopping, school, and recreation. TOD is defined in the Community Plan as moderate - to high-density development located within an easy walk of a major transit stop, generally with a mix of residential, employment, and shopping opportunities.

TOD encourages walking and transit use without excluding the automobile. TOD can be new construction or redevelopment of one or more buildings whose design and orientation facilitate transit use.

V. ENVIRONMENTAL IMPACTS FOUND NOT TO BE SIGNIFICANT OR LESS THAN

SIGNIFICANT WITHOUT MITIGATION IN THE INITIAL STUDY
The Current Planning Division prepared an Initial Study dated November 2, 2021, which is located in Appendix A of the Draft EIR. The Initial Study found the following environmental impacts not to be significant or less than significant without mitigation:

I. Aesthetics
a. Scenic Vista
b. Scenic Resources
c. Visual Character
d. Light & Glare
II. Agricultural and Forest Resources
a. Farmland
b. Existing Zoning for Agricultural Use
c. Forest Land or Timberland Zoning
d. Loss or Conversion of Forest Land
e. Other Changes in the Existing Environment
III. Air Quality
d. Objectionable Odors
IV. Biological Resources

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a. Special Status Species
b. Riparian Habitat and Wetlands
c. Wetlands
e. Local Preservation Policies
f. Habitat Conservation Plans
V. Cultural Resources
c. Human remains
VII. Geological Resources
a. Landslide
e. Septic Tanks
IX. Hazards and Hazardous Materials
a. Airport Land Use Plans
f. Wildland Fires
X. Hydrology and Water Quality
d. Flood Hazard, Tsunami, Seiche
XI. Land Use and Planning
a. Divide an Established Community
XII. Mineral Resources
a. Loss of Known Mineral Resources
b. Loss of Mineral Resources Recovery Site
XIII. Noise
c. Airport Land Use Plans and Private Airstrips
XIV. Population and Housing
a. Induce Substantial Unplanned Population Growth
b. Displacement of Existing Residents
XV. Public Services
a.iii Schools

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a.iv. Parks
a.v. Other Public Services
XVI. Recreation
a. Substantial Physical Deterioration of an Existing Park b. Construction or Expansion of Recreational Facilities

XIX. Utilities and Service Systems
d. Solid Waste Generation
e. Solid Waste Regulations
XX. Wildfire
a. Emergency Response Plan
b. Exacerbate Wildfire Risk
c. Emergency Infrastructure
d. Post-fire Risk
The City has reviewed the record and agrees with the conclusion that the above environmental issues would not be significantly affected by the Project and, therefore, no additional findings are needed. The City ratifies, adopts, and incorporates the analysis, explanation, findings, responses to comments, and conclusions of the Initial Study.

VI. ENVIRONMENTAL IMPACTS FOUND NOT TO BE SIGNIFICANT OR LESS THAN

SIGNIFICANT PRIOR TO MITIGATION
Impacts of the Project that were determined to have no impact or be less than significant in the EIR (including having a less than significant impact, as a result of implementation of project design features and regulatory compliance measu res) and that require no mitigation are identified below. The City has reviewed the record and agrees with the conclusion that the following environmental issues would not be significantly affected by the Project and, therefore, no additional findings are needed. The following information does not repeat the full discussions of environmental impacts contained in the EIR. The City ratifies, adopts, and incorporates the analysis, explanation, findings, responses to comments, and conclusions of the EIR.

1. Air Quality
(A) Consistency with Applicable Air Quality Management Plan

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(1) Southern California Air Quality Management District CEQA Air Quality Handbook Policy Analysis
Construction Growth Projections
As detailed in Section 4.2, Air Quality, of the Draft EIR, the Project would generate approximately 411 short-term construction jobs, but these jobs would not necessarily bring new construction workers or their families into the region, since construction workers are typically drawn from an existing regional pool of construction workers who travel among construction sites within the region as individual projects are completed, and are not typically brought from other regions to work on developments such as the Project. Moreover, these jobs would be temporary in nature. Therefore, the Project’s construction jobs would not conflict with the long- term employment or population projections upon which the 2016 Air Quality Management Plan (20156 AQMP) is based. Impacts would be less than significant.

Operations Growth Projections
As detailed in Section 4.2, Air Quality, of the Draft EIR, and discussed in the Initial Study, which is included in Appendix A of the Draft EIR, the Project’s growth would fall within the growth projections contained in the 2016 –2040 RTP/SCS, wh ich forms the basis of the growth projections in the 2016 AQMP. The Project would include office space suitable for approximately 2,400 occupants including 748 occupants in Building 1 and 1,652 occupants in Building 2. In addition to office space, there could be production spaces for multimedia content creation and capture, as well as amenities for building tenants, such as an employee cafeteria, coffee stations, and employee shuttle service.

SCAG’s final growth forecast for employment details 1,899,500 employees in 2020 to 2,169,100 employees in 2040 in the City of Los Angeles and 49,100 employees in 2020 and 53,000 employees in 2040 in the City of Culver City. The Project’s estimated increase in employees would represent approximately less than one per cent of the growth in employees in the City of Los Angeles (Building 2) and 19 percent of the growth in employees in the City of Culver City (Building 1) in the 2016 –2040 RTP/SCS, between 2020 and 2040. The Project would, therefore, also fall within the g rowth projections as contained in the 2016 –2040 RTP/SCS, and ultimately the growth projections in the AQMP.

The growth would occur in a transit rich area, which would minimize potential growth in transportation-related emissions. The Project Site is serv ed by the Los Angeles County Metropolitan Transportation Authority (Metro) “E” Line and multiple Metro and local bus lines that provide service along Venice, National, and Washington Boulevards.

Projects, uses, and activities that are consistent with the population, housing, and employment growth projections upon which 2016 AQMP forecasted emission levels are based would not jeopardize attainment of the air quality reductions identified in the AQMP, even if their emissions exceed the South Coast Air Quality Management District (SCAQMD)’s thresholds of significance. As a result, the Project would not conflict with the growth projections used in the development in the 2016 AQMP. Impacts would be less than significant.

Air Quality Violations

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As detailed in Sec tion 4.2, Air Quality, of the Draft EIR, Project construction and operations would not increase the frequency or severity of an existing violation or cause or contribute to new violations for any criteria pollutant with implementation of Mitigation Measure AQ-MM-1.

Accordingly, impacts regarding the timely attainment of air quality standards or interim emission reductions specified in 2016 AQMP would be less than significant.

Air Quality Mitigation Measures
As detailed in Section 4.2, Air Quality, of the Draft EIR, the Project would implement Mitigation Measure AQ-MM-1 to reduce short -term NOX emissions impacts during construction to less than significant. The Project would also comply with all applicable regulatory standards (e.g., SCAQMD Rule 403, etc. ) as required by SCAQMD, as summarized above. In addition, the Project would incorporate project design features to support and promote environmental sustainability as discussed in Section 4.6, Greenhouse Gas Emissions, of the Draft EIR. While these feat ures are designed primarily to reduce GHG emissions, they would also serve to reduce the criteria air pollutants discussed herein. Furthermore, with regulatory compliance, no significant air quality impacts would occur.
2016 AQMP Control Measures
Construction: As detailed in Section 4.2, Air Quality, of the Draft EIR, during its construction phase, the Project would comply with CARB’s requirements to minimize short -term emissions from on-road and off-road diesel equipment and with SCAQMD’s regulations, such as Rule 403 for controlling fugitive dust and Rule 1113 for controlling VOC emissions from architectural coatings. Furthermore, the Project would utilize construction contractors in compliance with State on -road and off -road vehicle rules, including the Airborne Toxic Control Measures (ATCMs) that limits heavy-duty diesel motor vehicle idling to five minutes at any location (Title 13 CCR, Section 2485), the Truck and Bus regulation that reduces NOX, PM10, and PM2.5 emissions from existing diesel vehicles operating in California (13 CCR, Section 2025) and the In-Use Off-Road Diesel Fueled Fleets regulation that reduces emissions by the installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emission controlled models (13 CCR, Section 2449). The Project’s construction contractor would be required to comply with these regulatory control measures and other applicable SCAQMD rules specified and incorporated in the 2016 AQMP.

Compliance with these regulatory control measures would ensure the Project would not conflict with AQMP control strategies intended to reduce emissions from construction equipment and activities. Impacts would be less than significant.

Operation: As detailed in Section 4.2, Air Quality, of the Draft EIR, the Project’s location, design, and land uses would be consistent with the 2016 AQMP during operations. With regard to land use developments such as the Project, the 2016 –2040 RTP/SCS land use control measures (i.e., goals and policies) focus on locating future growth within High Quality Transit Areas (HQTAs) and reducing vehicle trips and vehicle miles travelled (VMT). The Project represents an infill development within an existing urbanized area that would concentrat e new residential and commercial uses within an HQTA. Therefore, the Project would be consistent with SCAG’s 2016–2040 RTP/SCS, as it is located within an HQTA. The Project would be designed and constructed with sustainability and transit orientation as guiding principles. The Project Site is

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served by the Los Angeles County Metro “E” Line and multiple Metro and local bus lines that provide service along Venice, National, and Washington Boulevards.

As described in Section 4.12, Transportation, of the Dra ft EIR, the Project would support transportation control strategies related to reducing vehicle trips for employees and visitors.

The Project Site would be served by an existing fixed -route intercampus shuttle program that currently transports employees between Apple buildings in Culver City and the Metro “E” Line Station. Furthermore, the Applicant has proposed a voluntary Transportation Demand Management (TDM) Program, as required by Project Design Feature TRAF -PDF-2, to make non-automobile commutes attractive and viable options by providing employees with mobility once they arrive at work, access to needed services during the day, and other financial incentives to participate.

As such, the Project is consistent with the 2016 AQMP’s goal of reducing mobi le source emissions as a source of NOX and PM2.5. Project operation would also comply with applicable SCAQMD rules for operational emissions sources, including Rule 1470, Rule 1113, and Rule 1146.2.

Thus, the Project would not conflict with the 2016 AQMP with respect to transportation control strategies from the 2016 –2040 RTP/SCS that are intended to reduce VMT and resulting regional mobile source emissions. Impacts would be less than significant. (2) The City of Culver City General Plan and Mandatory Green Bui lding Program
As detailed in Section 4.2, Air Quality, of the Draft EIR, the Project would promote the City of Culver City General Plan objectives and policies to reduce single occupancy vehicle trips and VMT through its location near public transit, project design, and TDM Program, as required by Project Design Feature TRAF -PDF-2. The Project would provide bicycle access and on -site bicycle parking facilities, pedestrian access, an existing fixed -route intercampus shuttle program with connection to the Me tro “E” Line Station, future commuter shuttle service, and various on -site amenities and financial incentives as part of a TDM Program. Providing pedestrian and bicycle access that minimizes barriers and links the Project Site with external streets encourages people to walk instead of drive and reduces VMT. Therefore, the Project would support a land use pattern that encourages reduced vehicle trips and transportation air pollutant emissions.

The Project would also be consistent with the City of Culver Ci ty Mandatory Green Building Program. As described in Chapter 2, Project Description, Section 2.6.7, Sustainability Features, of the Draft EIR, the Project would be designed to achieve US Green Building Council (USGBC) Leadership in Energy and Environmenta l Design (LEED) Gold equivalent, inclusive of environmentally sustainable building features and construction protocols required by the City of Los Angeles Green Building Code, the Culver City Mandatory Green Building Program requirements, and California Green Building Standards (CALGreen) Building Code.

The Project would not conflict with applicable goals, objectives, and policies of the City of Culver City General Plan and the Culver City Mandatory Green Building, and impacts would be less than significant.

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(3) City of Los Angeles Policies
As detailed in Section 4.2, Air Quality, of the Draft EIR, the Project would be consistent with the City of Los Angeles General Plan Air Quality Element and Plan for a Healthy Los Angeles.

As the City of Los Angeles General Plan Air Quality Element would seek to reduce reliance on single occupancy vehicle trips, the Project would be consistent with this goal. The Project would provide bicycle access and on -site bicycle parking facilities, pedestrian access, an existing fixed-route intercampus shuttle program with connection to the Metro “E” Line Station, future commuter shuttle service, and various on-site amenities and financial incentives as part of a TDM Program. The TDM Program would cover TDM Support Services, Marketing and Communications, Public Tra nsit, Rideshare, Bicycling, Walking, Pre -tax Commuter Benefit, Commuter Club, Commute Expert Program, Guaranteed Ride Home Program, Intercampus and Commuter Shuttles, Campus Bike Share Program, and On-Site Services.

In addition, the Project would be consistent with the developing land use pattern that features greater concentration of urban density along major arterials and near transit options. The Project also includes primary entrances for pedestrians and bicyclists that would be safe, easily accessible, and in close proximity to transit stops. The accessibility and mobility provided by the Project would be consistent with the Plan for a Healthy Los Angeles as it would provide people with the opportunity to thrive. Additionally, the Project will compl y with City of Los Angeles EV charging requirements, which include the provision of at least 30 percent of total parking spaces provided on the Project Site to be capable of supporting future electric vehicle supply equipment (EVSE) and a minimum of 10 percent of the total parking spaces in Building 2 to be equipped with EV charging stations. Provisions of the EVSE and EV parking spaces would help to facilitate and encourage use of alternative fueled vehicles and reduce the Project’s mobile emissions. Other building energy efficiency measures, as mentioned above, would reduce building-related air pollutant emissions.

The Project would not conflict with applicable goals, objectives, and policies of the City of Los Angeles General Plan Air Quality Element and Plan for a Healthy Los Angeles pertaining to air quality, and impacts would be less than significant.
(B) Construction Emissions
(i) Localized Emissions
As set forth in Table 4.2 -11 of the Draft EIR, the Project’s maximum localized construction emissions would be below the localized significance thresholds, and localized construction emissions impacts to existing sensitive receptors would be less than significant. (ii) Toxic Air Contaminants
As detailed in Section 4.2, Air Quality, of the Draft EIR, based on the sh ort-term duration of Project construction and compliance with regulations that would minimize emissions, construction of the Project would not expose sensitive receptors to substantial toxic air contaminant (TAC) concentrations.

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Furthermore, the Project wo uld be required to implement Mitigation Measure AQ -MM-1 to reduce regional NO X emissions. The mitigation measure would have co -benefits of reducing emissions of PM10 and PM2.5 from heavy-duty diesel construction equipment, further reducing the TAC emissio ns during construction activities. Therefore, impacts from TACs during construction would be less than significant.
(C) Operational Emissions
(i) Regional Emissions
As set forth in Table 4.2 -8 of the Draft EIR, the Project’s operational emissions would not exceed SCAQMD’s regional significance thresholds for VOC, NOX, CO, SO2, PM10, and PM2.5 emissions. Therefore, Project impacts related to regional operational emissions would be less than significant.
(ii) Operation – Localized Emissions
As set forth in Table 4.2-12 of the Draft EIR, the Project’s maximum localized operational emissions would be below the localized significance thresholds, and localized operational emissions impacts to existing sensitive receptors would be less than significant.

Based on the Pr oject’s Transportation Impact Study, under Horizon Year plus Project (2045) conditions, the intersection of Venice Boulevard and S. Robertson Boulevard would have a traffic volume of approximately 64,950 average daily trips (ADT), which is below the daily traffic volumes of 400,000 vehicles per day that would be expected to generate CO exceedances as evaluated in the 2003 AQMP. This daily trip estimate is based on the peak hour conditions of the intersection. There is no reason unique to the Air Basin met eorology to conclude that the CO concentrations at the Venice Boulevard and S. Robertson Boulevard intersection would exceed the 1-hour CO standard if modeled in detail, based on the studies undertaken for the 2003 AQMP. In addition, CO background concent rations within the vicinity of the modeled intersection have substantially decreased since preparation of the 2003 AQMP primarily due to ongoing fleet turnover of older on-road light duty vehicles and use of cleaner fuels. In 2003, the 1-hour background C O concentration was 5 ppm and has decreased to 2 ppm in 2014.

Therefore, the Project does not trigger the need for a detailed CO hotspots model and would not cause any new or exacerbate any existing CO hotspots. The Project’s off-site operational activities, including the highest average daily trips, would not expose sensitive receptors to substantial CO concentrations. As a result, impacts related to localized mobile -source CO emissions are considered less than significant.
(iii) Toxic Air Contaminants
As set forth in Table 4.2-12 of the Draft EIR, the SCAQMD recommends that operational health risk assessments be conducted for substantial sources of operational diesel particulate matter (DPM) (e.g., truck stops and warehouse distribution facilities that genera te more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has provided guidance for analyzing mobile source diesel emissions. The Project would not include any truck stop or warehouse distribution uses, and, as such, operations would generate only minor amounts of diesel emissions from mobile sources, such as delivery trucks and occasional

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maintenance. Furthermore, Project trucks would be required to comply with the applicable provisions of 13 CCR, Section 2025 (Truck and Bus regulation) to minimize and reduce PM10, PM2.5, and NOX emissions from existing diesel trucks. Therefore, Project operation would not be considered a substantial source of DPM.

With respect to the use of consumer products and architectur al coatings, the office uses associated with the Project would be expected to generate minimal TAC emissions from these sources. Typical sources of acutely and chronically hazardous TACs include industrial manufacturing processes (e.g., chrome plating, el ectrical manufacturing, petroleum refinery).

The Project would not include these types of potential industrial manufacturing process sources. It is expected that quantities of hazardous TACs generated on -site (e.g., cleaning solvents, paints, landscape p esticides) for the types of proposed land uses would be below thresholds warranting further study under the California Accidental Release Program (CalARP).

As a result, toxic or carcinogenic air pollutants are not expected to occur in any substantial amounts in conjunction with operation of the proposed land uses within the Project Site. Based on the uses expected on the Project Site, operation of the Project would not expose sensitive receptors to substantial TAC concentrations, and operational impacts wo uld be less than significant.
(iv) Cumulative Impacts
a. Construction – TACs
As set forth in Table 4.2 -12 of the Draft EIR, similar to the Project, the greatest potential for TAC emissions at each related project would generally involve diesel particulate emission s associated with heavy equipment operations during grading and excavation activities.

According to SCAQMD methodology, health effects from carcinogenic air toxics are usually described in terms of individual cancer risk. “Individual Cancer Risk” is the likelihood that a person exposed to concentrations of TACs over a 70 -year lifetime will contract cancer, based on the use of standard risk -assessment methodology. Construction activities are temporary and short-term events; therefore, construction activities at each related project would not result in a long-term substantial source of TAC emissions. Additionally, SCAQMD’s CEQA Air Quality Handbook and SCAQMD’s supplemental online guidance/information do not require a health risk assessment for short -term construction emissions. It is, therefore, not required or meaningful to evaluate long-term cancer impacts from construction activities which occur over relatively short durations. As such, given the short -term nature of these activities, cumulative toxic emission impacts during construction would be less than significant. b. Operation
According to SCAQMD, if an individual project results in air emissions of criteria pollutants that exceed SCAQMD’s recommended daily thresholds for project-specific impacts, then the project would also result in a cumulatively considerable net increase of these criteria pollutants. As operational emissions would not exceed any of SCAQMD’s regional or localized significance thresholds, the emissions of non -attainment pollutants and precursors generated by Project operations would not be cumulatively considerable. In addition, the Project would not result in

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any substantial sources of TACs and, thus, would not contribute to a cumulative impact. Thus, during operation, the Projec t would not result in a cumulative impact to air quality, as the Project’s contributions to regional, localized, and TAC emissions would not be cumulatively considerable.

2. Cultural Resources – Historic Resources
As discussed in the Initial Study prepared fo r the Project, which is included as Appendix A of the Draft EIR, and as further detailed in Section 4.3 of the Draft EIR, existing on -site buildings are not considered historical resources. In addition, due to the distance between the Project Site and the nearest historical resource, as well as intervening development, the Project would have a less-than-significant impact on these resources. Therefore, the Project would not cause a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5. Impacts to historical resources would be less than significant, and no mitigation measures would be required. The Project would not indirectly impact adjacent historic resources.

3. Energy
As demonstrated in t he Energy Section of the Draft EIR, Section 4.4, the Project would not cause wasteful, inefficient, or unnecessary consumption of energy during construction or operation. The Project’s energy requirements would not significantly affect local or regional supplies or capacity. The Project’s energy usage during base and peak periods would be consistent with electricity and natural gas future projections for the region. Electricity generation capacity and supplies of natural gas and transportation fuels woul d be sufficient to meet the needs of Project -related construction and operational activities. During operations, the Project would comply with applicable energy efficiency requirements, such as the State Building Energy Efficiency Standards and applicable provisions of CalGreen, as well as include energy conservation measures beyond such requirements. Moreover, the Project would not conflict with adopted energy conservation plans or violate state or federal energy standards.

In summary, the Project’s ene rgy demands would not significantly affect available energy supplies and would comply with relevant energy efficiency standards. In addition, based on the analysis in Draft EIR Section 4.4, the Project’s impacts would not be cumulatively considerable and cumulative energy use impacts are concluded to be less than significant.

4. Greenhouse Gas Emissions
The significance of the Project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b) by considering whether the Project complies with applicable plans, policies, regulations, and requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of greenhouse gas emissions. For this Project, as a land use development project, the most directly applicable adopted regulatory plan to reduce GHG emissions is the 2020–2045 RTP/SCS, which is designed to achieve regional GHG reductions from the land use and transportation sectors as required by SB 375 and the State’s long -term climate goals. The analysis also considers consistency with regulations or requirements including CARB’s Climate Change Scopin g Plan and City of Culver City’s and City of Los Angeles’s plans, programs, and policies including Culver City’s Green Building Program, City

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of Los Angeles’s Green New Deal/Sustainable City pLAn, and City of Los Angeles’s Green Building Program.

As shown in Tables 4.6 -10 and 4.6 -11 of the Draft EIR , when taking into consideration implementation of relevant Project design features, as well as the requirements set forth in Culver City’s Green Building Program, t he City of Los Angeles Green Building Program and full implementation of current state mandates, the Project’s GHG emissions in 2026 would be 8,466 MTCO2e per year (amortized over 30 years) during construction and 8,982 MTCO2e per year during operation, resulting in a combined total of 9,262 MTCO2e per year. When existing emissions of 2,045 MTCO2e per year are subtracted, the Project results in net GHG emissions of 7,218 MTCO2e per year.

As provided in Table 4.6 -6 of the Draft EIR, the Project would not conflict with the Climate Change Scoping Plan which is intended to reduce GHG emissions.

The Project is the type of land use development that is encouraged by the 2020-2045 RTP/SCS to reduce VMT and expand multi-modal transportation options, in order for the region to achieve the GHG reductions from the land use and transportation sectors required b y SB 375, which, in turn, advances the State’s long -term climate policies. By furthering implementation of SB 375, the Project would support regional land use and transportation GHG reductions consistent with state regulatory requirements. The Project wo uld not conflict with the GHG reduction - related actions and strategies contained in the 2020 -2045 RTP/SCS as shown in Table 4.6 -7 of the Draft EIR. As such, impacts related to consistency with the 2020-2045 RTP/SCS would be less than significant.

Table 4.6-8 of the Draft EIR provides a discussion of the Project’s consistency with applicable GHG-reducing actions from Los Angeles’s Green New Deal/Sustainable City pLAn. As discussed therein, the Project would be consistent with the applicable goals and actions of Los Angeles’s Green New Deal/Sustainable City pLAn.

For the reasons discussed in Draft EIR Section 4.6, the Project’s post -2030 emissions trajectory is expected to follow a declining trend, consistent with the 2030 and 2050 targets and Executive Orders S-3-05 and B-30-15.

As determined in Draft EIR Section 4.6, given the Project’s consistency with statewide, regional, and local plans adopted for the purpose of reducing GHG emissions, it is concluded that the Project’s incremental contribution to GHG emissions and their effects on climate change would not be cumulatively considerable. For these reasons, the Project’s cumulative contribution to global climate change is less than significant. (A) Project Design Features
The City finds that Project Design Feature GHG-PDF-1, which is incorporated into the Project and is incorporated into these Findings as though fully set forth herein, would reduce the potential greenhouse gas emissions of the Project. This project design feature was considered in the analysis of potential impacts.

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5. Hazards and Hazardous Materials – Proximity to Schools, Hazardous Materials Site, Emergency Response
As detailed in Section 4.7 of the Draft EIR, impacts relative to proximity to schools, impacts regarding being listed on government al hazardous materials lists and impacts regarding adopted emergency response plans or emergency evacuation plans were determined to be less than significant without mitigation.

6. Hydrology and Water Quality – Groundwater, Flood, Drainage and Water Quality Control Plan
As detailed in Section 4.8 of the Draft EIR, impacts relative to the construction and operation of the Project would not significantly decrease groundwater supplies or interfere with groundwater recharge such that the Project may impede sustain able groundwater management of the basin. In addition, impacts on drainage patterns that would cause increased siltation and flooding on - or off-site, create or contribute to the exceedance of the existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff, or impede or redirect flood flows would be less than significant. Furthermore, impacts regarding a water quality control plan or sustainable groundwater management plan, and impacts regarding new or expanded stormwater drainage facilities were determined to be less than significant.

7. Land Use and Planning – Consistency with Local Plans and Applicable Policies As detailed in Section 4.9, Land Use and Planning, of the Draft EIR, the Project would not conflict with policies adopted to avoid or mitigate an environmental effect and, as such, impacts with respect to the 2020 –2045 Regional Transportation Plan/Sustainable Communities Strategy. Additionally, the Project would not conflict with Culver City General P lan and other policies adopted to avoid or mitigate an environmental effect. Furthermore, the Project would not conflict with City of Los Angeles General Plan and other policies adopted to avoid or mitigate an environmental effect.

8. Noise
(A) Construction
(i) Off-Site Construction Noise
As set forth in Draft EIR Section 4.10, in particular Table 4.10 -11, the noise levels generated by construction trucks during all stages of Project construction would be less than the significance threshold of an increase of 5 dBA Leq for construction noise. Therefore, temporary noise impacts from off-site construction traffic would be less than significant. (ii) On-Site Vibration (Building Damage and Human Annoyance) As set forth in Draft EIR Section 4.10, Noise, pages 4.10-56 through 4.10-57, vibration impacts from on -site construction activities would be less than significant with respect to structural damage and no significant Project -related structural damages grou ndborne vibration impacts

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would occur from on-road construction vehicles. As set forth on page 4.10-57, impacts would be less than significant with respect to human annoyance. (iii) Cumulative On-Site Construction Vibration (Building Damage and Human Annoyance)
As set forth in Draft EIR Section 4.10, Noise, page 4.10-62, the Project would not contribute to cumulative construction vibration impact with respect to building damage associated with on - site construction and the cumulative impact would be less than significant. Moreover, potential cumulative construction vibration impacts with respect to human annoyance associated with on-site construction would be less than significant.
(B) Operations
(i) Operational Noise
As set forth in detail in Draft EIR Section 4.10, Noise, pages 4.10-43 through 4.10-53, including Tables 4.10-12 through 4.10-14, Project operations would not result in the exposure of persons to or generation of noise levels in excess of established noise standards. Therefore, the Project’s operational noise impacts from on- and off-site sources would be less than significant. (ii) Operational Vibration
As set forth in Draft EIR Section 4.10, Noise, page 4.10-58, operation of the Project would not increase the existing vibration levels in the immediate vicinity of the Project Site. As such, vibration impacts associated with operation of the Project would be less than significant. (iii) Cumulative Operational Noise
As detailed in Draft EIR Section 4.10, Noise, pages 4.10 -61 through 4.10-62, the Project and related projects would not result in the exposure of persons to or generation of noise levels in excess of the significance criteria established by the City or in a substantial permanent increase in ambient noise levels in the vicinity of the Project Site above levels existing without the Project and the related projects. Therefore, cumulative operational noise impacts from on-site and off- site sources would be less than significant.
(v) Cumulative Operational Vibration
As detailed in Draft EIR Section 4.10, Noise, page 4.10-62, based on the distance of the related projects from the Project Site and the operational vibration levels associated with the Project, cumulative vibration impacts associated with operation of the Project and related projects would be less than significant.
(C) Project Design Features
The City finds that Project Design Features NOI -PDF-1 through NOI -PDF-8, which are incorporated into the Project and are incorporated into these Findings as though fully set forth herein, would reduce the potential noise impacts of the Project. These project design features were considered in the analysis of potential impacts.

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9. Public Services
Consistent with City of Hayward v. Trustees of California State University (2015) 242 Cal.App.4th 833, significant i mpacts under CEQA consist of adverse changes in any of the physical conditions within the area of a project, and potential impacts on public safety services are not an environmental impact that CEQA requires a project applicant to mitigate: “[T]he obligation to provide adequate fire and emergency medical services is the responsibility of the city. (Cal. Const., art. XIII, § 35, subd. (a)(2) [“The protection of the public safety is the first responsibility of local government and local officials have an ob ligation to give priority to the provision of adequate public safety services.”].) The need for additional fire protection services is not an environmental impact that CEQA requires a project proponent to mitigate.” Although that case specifically addressed fire services, its holding also applies to other public services. (A) Public Services – Fire Protection
As set forth in Draft EIR Section 4.11.1, Public Services – Fire Protection, pages 4.11.1 -19 through 4.11.1-29, Project construction, operation, and cumulative impacts would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which would cause si gnificant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for fire protection services. Therefore, impacts to fire protection services during Project construction, operation, and in the cumulative condition would be less than significant. (B) Public Services – Police Protection
As set forth in Draft EIR Section 4.11.2, Public Services – Police Protection, pages 4.11.2-15 through 4-11.2-22, Project construction, operation, and cumulative impacts would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, need for new or physically altered governmental facilities, the construction of which would cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for police protection services. Therefore, impacts to police protection services during Project construction, operation, and in the cumulative condition would be less than significant. (i) Police Protection – Project Design Features
The City finds that Project Design Features POL-PDF-1 through POL-PDF-2, incorporated into the Project, reduce the potential police protection impacts o f the Project. The project design features were considered in the analysis of potential impacts.

11. Transportation
(A) Program, Plans, Ordinance or Policy
As set forth in Draft EIR Section 4.12, Transportation, pages 4.12 -27 through 4.12 -36, and Appendix M, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

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(B) CEQA Guidelines Section 15064.3, subdivision (b)
As set forth in Draft EIR Section 4.12, Transportation, page 4.12 -37, Draft EIR Appendix M, Traffic Study, and Updated Appendix M in the Final EIR, Project -level impacts related to VMT were determined to be less than significant.
(C) Hazardous Design
As set forth in Draft EIR Section 4.12, Tr ansportation, pages 4.12 -38 through 4.12 -39, the Project would not include any hazardous geometric design features. (D) Emergency Access
As set forth in Draft EIR Section 4.12, Transportation, pages 4.12 -40 through 4.12 -41, the Project would not result in inadequate emergency access. (E) Cumulative Impacts
As set forth in Draft EIR Section 4.12, Transportation, pages 4.12 -41 through 4.12 -42, the Project’s contribution to impacts related to programs, plans, ordinances, or policies; or vehicle miles traveled; or haza rdous design; or emergency access would not be cumulatively considerable and cumulative impacts would be less than significant. (F) Project Design Features
The City finds that Project Design Feature TRAF -PDF-1 and TRAF -PDF-2, which are incorporated into the Project and incorporated into these findings as fully set forth herein, reduces the potential transportation impacts of the Project. These project design features were considered in the analysis of potential impacts.

12. Utilities and Service Systems – Water Supply and Infrastructure As set forth in Draft EIR Section 4.14.1, Utilities and Service Systems – Water Supply, pages

4.14.1-25 through 4.14.1-39, and Appendices O and P, the Project, either during construction, operation, or cumulative condition, would not require or result in the construction of new water facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. In addition, sufficient water supply is available to serve the Project construction, Project operation, and in the cumulative condition. As such, impacts related to water infrastructure and to water supply would be less than significant. (A) Project Design Features
The City finds that Project Design Feature WAT-PDF-1, which is incorporated into the Project and incorporated into these findings as fully set forth herein, reduces the potential water supply impacts of the Project. This project design feature was considered in the analysis of potential impacts.

14. Utilities and Service Systems – Wastewater

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As set forth in Draft EIR Section 4.14.2, Utilities and Service Systems – Wastewater, pages

4.14.2-8 through 4.14.2-14 and Appendix P, the Project, either during construction, operation, or cumulative condition, w ould not require or result in the construction of new wastewater facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. In addition, sufficient wastewater capacity is available to serve the Project construction wastewater demand, Project operation wastewater demand, and in the cumulative condition. As such, impacts related to wastewater infrastructure and to wastewater treatment capacity would be less than significant.

15. Utilities and Service Systems – Solid Waste
As set forth in Draft EIR Section 4.14.23, Utilities and Service Systems – Solid Waste, pages

4.14.3-12 through 4.14.3-19 and Appendix P, the Project, either during construction, operation, or cumulative condition, would not requ ire or result in the construction of new solid waste facilities or expansion of existing facilities, the construction of which could cause significant environmental effects. In addition, sufficient solid waste capacity is available to serve the Project construction solid waste demand, Project operation solid waste demand, and in the cumulative condition. As such, impacts related to solid waste infrastructure and to solid waste capacity would be less than significant.

16. Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities
As set forth in Draft EIR Section 4.14.4, Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities, pages 4.14.4 -10 through 4.14.4 -16, Project construction and operation, including in the cumulative condition, would not require or result in an increase in demand for electricity, natural gas or telecommunications facilities that exceeds available supply or distribution infrastructure capabilities that could result in the construction of new energy facilities or expansion of existing facilities, the construction of which could cause significant effects. Therefore, Project impacts would be less than significant during construction and operation.

VII. ENVIRONMENTAL IMP ACTS FOUND TO BE LESS THAN SIGNIFICANT AFTER

MITIGATION
The following impact areas were concluded by the Draft EIR to be less than significant with the implementation of mitigation measures described in the Final EIR. Based on that analysis and other evidence in the administrative record relating to the project, the City finds and determines that mitigation measures described in the Final EIR reduce potentially significant impacts identified for the following environmental impact categories to below th e level of significance.

Pursuant to PRC Section 21081, the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid each of the following significant effects on the environment.

1. Air Quality – Construction Emissions (Regional; No Overlap) (A) Impact Summary

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Project construction has the potential to generate air emissions through the use of heavy-duty construction equipment and vehicle trips by construction workers traveling to and from the Project Site. In addition, fugitive dust emissions would result from demolition and construction activities. Mobile source emissions, primarily NO X, would result from the use of construction equipment, such as dozers, loaders, and cranes. During the bu ilding finishing phase, paving, and the application of architectural coatings (e.g., paints) would potentially release VOCs. The assessment of construction air quality impacts considers each of these potential sources.

Construction emissions can vary sub stantially from day to day, depending on the level of activity, the specific type of operation, and, for dust, the prevailing weather conditions.

The emissions levels in Table 4.2 -6 of the Draft EIR represent the highest daily emissions projected to occur during each year of construction. As presented therein, construction-related daily maximum regional construction emissions (i.e., combined on-site and off-site emissions) without mitigation would not exceed the SCAQMD daily significance thresholds for VOC , CO, SOX, PM 10, or PM 2.5. Maximum unmitigated construction emissions would exceed the SCAQMD daily significance threshold for NO X as a result primarily from heavy -duty trucks required for on -road soil hauling and from concrete trucks delivering concrete to the Project Site from concrete suppliers. Therefore, prior to mitigation, regional construction emissions resulting from the Project would result in a significant short -term impact. However, mitigation measures would reduce impacts to a less -than-significant level. Therefore, regional construction emissions resulting from the Project would result in a less-than-significant impact with incorporation of mitigation measures.

With respect to the Project’s short -term construction-related air quality emissi ons, SCAQMD has developed strategies to reduce criteria pollutant emissions outlined in the AQMP pursuant to the federal CAA mandates. Construction of the Project would comply with SCAQMD Rule 403 fugitive dust control requirements, SCAQMD Rule 1113 for architectural coatings, and the ATCM to limit heavy -duty diesel motor vehicle idling to no more than five minutes at any location. Given that the Project’s construction -related air emissions would exceed the SCAQMD’s regional significance thresholds for NOX, short-term construction impacts would be potentially significant without mitigation.
(B) Project Design Features
No specific project design features are proposed with regard to air quality. (C) Mitigation Measures
AQ-MM-1: Construction Equipment Features: The Project shall implement the following construction equipment features for equipment operating at the Project Site. These features shall be included in applicable bid documents, and successful contractor(s) must demonstrate the ability to supply such equipment.

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construction phases. The inventory shall include the horsepower rating, engine production year, and certification of the specified Tier standard. A copy of each suc h unit’s certified tier specification, best available control technology (BACT) documentation, and CARB or SCAQMD operating permit shall be maintained on -site at the time of mobilization of each applicable unit of equipment. Off-road diesel-powered equipment equal to or greater than 50 horsepower that will be used during any portion of the construction activities shall meet or exceed the Tier 4 Final standards.

Such equipment will be outfitted with Best Available Control Technology (BACT) devices, includi ng a CARB -certified Level 3 Diesel Particulate Filter or equivalent. Alternate construction equipment may be used if the construction contractor can document that the equipment would achieve the same or greater NOx reductions compared to Tier 4 Final stan dards.

Construction contractors supplying heavy duty diesel equipment greater than 50 horsepower shall be encouraged to apply for SCAQMD SOON funds. Information including the SCAQMD website shall be provided to each contractor which uses heavy duty diese l for on -site construction activities
• During demolition, site preparation, and grading and excavation activities, the contractor shall provide notification and documentation that haul truck drivers have received training regarding idling limitations specified in Title 13 California Code of Regulations, Section 2485. During construction, trucks and vehicles in loading and unloading queues shall have their engines turned off after 5 minutes when not in use, to reduce vehicle emissions.
• Contractors shall maintain and operate construction equipment so as to minimize exhaust emissions. All construction equipment must be properly tuned and maintained in accordance with the manufacturer’s specifications. The contractor shall keep documentation on -site demonstrating that the equipment has been maintained in accordance with the manufacturer’s specifications. Tampering with construction equipment to increase horsepower or to defeat emission control devices shall be prohibited.
• Construction activities shall be di scontinued during an Air Quality Index (AQI) of 151 or more (unhealthy level). A record of any AQI at an unhealthy level and of discontinued construction activities as applicable shall be maintained by the Contractor on-site.
(D) Finding
Pursuant to PRC Secti on 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding construction air quality emissions – regional emissions.

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(E) Rationale for Finding
As shown in Table 4.2.9 of the Draft EIR, implementation of the Mitigation Measure AQ-MM-1 described above would serve to reduce construction emissions for all pollutants and maximum regional NOX emissions would be reduced below SCAQMD’s regional construction significance threshold.
(F) Reference
Section 4.2, Air Quality, of the Draft EIR and Appendix B (Air Quality and Greenhouse Gas Emissions).

2. Cultural Resources – Archaeological Resources
(A) Impact Summary
As detailed in Section 4.3, Cultural Resources, of the Draft EIR, no known archaeological resources were identified within the Project Site. However, the records search through the California Historical Resources Information System-South Central Coastal Information Center (CHRIS-SCCIC) yielded the identification of one historic -period archaeological resource (CA- LAN-4829) within close proximity to the Project Site consisting of 13 features, including the remnants of two wells/cisterns, structural remnants, two metal tanks, and eight refuse deposits dating from the 1880s to the 1920s. Additionally, recent construction projects in Culver City have yielded the identification of two prehistoric metate artifacts and three isolated historic - period artifacts (consisting of glass bottle containers) within the 0.50-mile radius of the Project Site. These resources were found within disturbed fill sediments at properties that had a similar land use history as the Project Site.

The land use history research identified historic land uses in the southern portion of the Project Site, including a two -story structure originally called the Green Mill (and subsequently the Cotton Club House and Zuccas Opera House), which featured a round three -foot deep concrete pool, a restaurant and club for dining and dancing dating to the period between 1924 to at least 1949. This portion of the Project Site is currently developed with surface parking, which is unlikely to have been subject to deep excavations that would have disp laced or destroyed buried archaeological resources.

Based on these findings, the northern portion of the Project Site is assigned a low sensitivity for historic-period archaeological resource since no known previous uses existed in this area; however, the potential for historic -period archaeological resourc es in the southern portion of the Project Site is considered moderate to high. Also, the potential to encounter prehistoric archaeological resources is moderate across the entire Project Site; therefore, impacts to previously unknown buried historic and p rehistoric archaeological resources are considered potentially significant.
(B) Project Design Features
No project design features are applicable.
(C) Mitigation Measures

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CUL-MM-1: Prior to the issuance of a demolition permit, the Applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archaeology (Qualified Archaeologist) to oversee an archaeological monitor who shall be present during initial Project construction work such as demolition, clearing/grubbing, grading, trenching, or related moving of soils within the Project Site (collectively, ground disturbing activities); provided, however, that ground disturbing activities shall not include any moving of soils after they have been initially disturbed or displaced by Project-related construction. The Qualified Archaeologist shall determine the frequency of monitoring based on the rate of excavation and grading activities, proximity to known archaeological resources, the materials being excavated (younger alluvium vs. older alluvium), and the depth of excavation, and if found, the abundance and type of archaeological resources encountered. The frequency of monitoring can be reduced to part-time inspections or ceased entirely if determined appropriate by the Qualified Archaeologist.

Prior to commencement of excavation activities, an Archaeological and Cultural Resources Sensitivity Training shall be given for construction personnel. The training session shall be carried out by the Qualified Archaeologist and shall focus on how to identify archaeological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event.

CUL-MM-2: In the event that historic or prehistoric archaeological resources (e.g., bottles, foundations, refuse dumps, etc.) are unearthed, ground-disturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluated. After consulting with the Applicant, the Qualified Archeologist shall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety considerations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where construction activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area.

All archaeological resources unearthed by Project construction activities shall be evaluated by the Qualified Archaeologist. If the Qualified Archaeologist determines the find to constitute a “historical resource” pursuant to CEQA Guidelines Section 15064.5(a) or a “unique archaeological resource” pursuant to Public Resources Code Section 21083.2(g), the Qualified Archaeologist shall coordinate with the Applicant and the City of Culver City and/or City of Los Angeles depending on the location/jurisdiction where the resource is located to develop a reasonable and feasible treatment plan that would serve to reduce impacts to the resources. The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and Public Resources Code Sections 21083.2(b) for unique archaeological resources. The treatment plan shall include measures regarding the curation of the recovered resources that may include curation at

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a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the resources, they may be donated to a local school or historical society in the area (such as the Culver City Historical Society) for educational purposes.

If the Applicant does not accept a particular recommendation determined to be reasonable and feasible by the Qualified Archaeologist, the Applicant may request mediation by a mediator agreed to by the Applicant and the City of Culver City or City of Los Angeles, depending on the location/jurisdiction where the resource is located. The mediator must have the requisite professional qualifications and experience to mediate such a dispute. The City shall make the determination as to whether the mediator is at least minimally qualified to mediate the dispute. After making a reasonable effort to mediate this particular dispute, the City may: (1) require the recommendation be implemented as originally proposed by the Qualified Archaeologist; (2) require the recommendation, as modified by the City, be implemented in a manner that is at least as equally effective to mitigate a potentially significant impact; (3) require a substitute recommendation be implemented that is at least as equally effective to mitigate a potentially significant impact; or (4) not require the recommendation be implemented because it is not necessary to mitigate any significant impacts. The Applicant shall pay all costs and fees associated with the mediator.

CUL-MM-3: The Qualified Archaeologist shall prepare a final report and appropriate California Department of Parks and Recreation Site Forms at the conclusion of archaeological monitoring. The report shall include a description of resources unearthed, if any, treatment of the resources, results of the artifact processing, analysis, and research, and evaluation of the resources with respect to the California Register of Historical Resources and CEQA. The report and the Site Forms shall be submitted b y the Applicant to the City of Culver City and/or City of Los Angeles depending on the location/jurisdiction where the resource is located, the South Central Coastal Information Center, and representatives of other appropriate or concerned agencies to signify the satisfactory completion of the Project and required mitigation measures.
(D) Finding
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding archaeological resources.
(E) Rationale for Finding
As set forth in Mitigation Measures CUL -MM-1 through CUL -MM-3, a qualified archaeologist shall be retained to perform periodic inspections of excavation an d grading activities of the Project Site. Impacts related to archaeological resources during Project construction would be

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reduced to less than significant with implementation of the above mitigation measures.

Monitoring of the Project Site during ground disturbing activities by a professional archaeologist would result in the identification and assessment of significant or unique archaeological resources, as well as the implementation of appropriate measures in accordance with CEQA. (F) Reference
Section 4.3, Cultural Resources, of the Draft EIR, as well as Appendix D of the Draft EIR, Archaeological Resources Assessment Report and Final EIR Chapter 3, Revisions, Clarifications, and Corrections to the Draft EIR.

3. Geology and Soils – Paleontological Resources
(A) Impact Summary
As discussed in Section 4.5, Geology and Soils, of the Draft EIR, Geologic mapping indicates that the surface of the Project Site is underlain by Holocene -age alluvium (Qa), which have a low sensitivity for paleontological resource s due to the young age of the deposits and are unlikely to preserve fossil resources. However, these sediments increase in age with depth, such that the deeper layers of this unit have a higher potential to preserve paleontological resources. Moreover, numerous paleontological resources have been recovered from deeper deposits during construction of three development projects in the immediate vicinity of the Project Site in association with the Lakewood Formation—a geological unit which consists of a Pleistocene-age alluvium deposited in both marine and non -marine settings, which is considered to have high potential for encountering paleontological resources. In particular, these projects yielded the identification of more than 200 fossil specimens from these deposits that were encountered at depths between 15 feet below ground surface (bgs) to 41 feet bgs.

In addition, the paleontological records search conducted through the Natural History Museum of Los Angeles County (NHMLAC) also indicates that older (Pleistocene-age) geologic units in the vicinity of the Project Site have produced paleontological resources (including fossil specimens of horse, camel, mammoth, pond turtle, ground sloth, mastodon, mammoth, camel, turkey, saber-toothed cat, horse, deer, sharks, bony fish, and rays), including resources located within approximately 0.6 and 2 miles from the Project Site at depths between 6 and 13 feet bgs and unknown depths. Given the identification of numerous fossil specimens at depth during construction projects in the immediate vicinity, the positive results of NHMLAC records search, and since excavations for the Project would extend to depths of about 50 feet bgs, the potential to encounter buried paleontological resources during construction of the Project is considered high. Therefore, as the Project could directly or indirectly destroy unique paleontological resources, impacts on buried paleontological resources are considered potentially significant. (B) Project Design Features
No specific project design features are proposed with regard to paleontological resources. (C) Mitigation Measures
GEO-MM-1: Prior to the issuance of grading permits, the Applicant shall retain a qualified paleontologist meeting the Society of Vertebrate Paleontology (SVP)

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Standards (Qualified Paleontologist). The Qualified Paleontologist shall provide technical and compliance oversight of all work as it relates to paleontological resources, shall attend the Project kick-off meeting, and Project progress meetings, and shall be responsible for monitoring and overseeing paleontological monitors (meeting SVP standards) that will observe grading and excavation activities.

GEO-MM-2: Paleontological monitoring shall be conducted during construction excavations into undisturbed older alluvial sediments that exceed 10 feet in depth. Monitoring shall consist of visually inspecting fresh exposures of rock for larger fossil remains and, where appropriate, collecting and wet screening sediment samples of promising horizons for smaller fossil remains. If significant vertebrate fossils are found by screening, it will be necessary to collect a 6,000- pound sample for screening, per SVP Guidelines (2010). The sample can be collected by construction machinery and stockpiled and processed in a safe location on-site or transported to another site for processing. The frequency of monitoring inspections shall be determined by the Qualified Paleontologist and shall be based on the rate of excavation and grading activities, the materials being excavated, and the depth of excavation, and if found, the abundance and type of fossils encountered. Full-time monitoring can be reduced to part-time inspections, or ceased entirely, if determined adequate by the Qualified Paleontologist. If a potential fossil is found, the Qualified Paleontologist shall have authority to temporarily stop excavation activity or to temporarily divert or redirect grading and excavation activities in the area of the exposed fossil to facilitate evaluation of the discovery. An appropriate buffer area shall be established by the Qualified Paleontologist around the find where construction activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area. At the Qualified Paleontologist’s discretion, and to reduce any construction delay, the grading and excavation contractor shall assist in removing rock/sediment samples for initial processing and evaluation.

If preservation in place is not feasible, the Qualified Paleontologist shall implement a paleontological salvage program to remove the resources from their location.

GEO-MM-3: Any significant fossils recovered during Project-related excavations shall be prepared to the point of identification. The residue form sediment samples shall be dried and sorted with a binocular dissecting microscope. Both macrofossils and vertebrate microfossils shall be prepared to the point of identification, identified, and curated into an accredited repository. The Qualified Paleontologist shall prepare a final report summarizing the results of the monitoring and salvaging efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall accompany the specimens to the accredited repository. The report shall also be submitted by the Applicant to the City of Culver City and/or City of Los Angeles, depending on the location/jurisdiction where the resource is located, to

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signify the satisfactory completion of the Project and required mitigation measures.
(D) Finding
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding paleontological resources. (E) Rationale for Finding
Implementation of Mitigation Measures GEO -MM-1 through GEO -MM-3 would require retention of a Qualified Paleontologist meeting the SVP Standards in order to provide technical and compliance oversight, construction worker paleontol ogical resources sensitivity training, and paleontological resources monitoring. Impacts related to paleontological resources during Project construction would be reduced to less than significant with implementation of the above mitigation measures. The Project would have no impacts to paleontological resources during operation as there would be no continuous groundbreaking and excavation activities during Project operation.
(F) Reference
Section 4.5, Geology, of the Draft EIR, as well as Appendix G (Paleontological Resources Assessment Report) and Final EIR Chapter 3, Revisions, Clarifications, and Corrections to the Draft EIR.

4. Hazards and Hazardous Materials – Hazardous Materials and Upset Conditions (A) Impact Summary
As detailed in Section 4.7, Hazards and Hazardous Materials, of the Draft EIR, the Project includes the excavation of soil to construct three levels of underground parking garages under each building. Soil vapor, groundwater, indoor air, and outdoor air samples were collected and analyzed for chemicals of potential concern identified for the Phase I ESA. Testing revealed the presence of Perchloroethene (PCE) in sub-slab soil vapor samples in the northern portion of the Project Site (beneath Venice Bouleva rd buildings) at concentrations above its vapor intrusion screening level for commercial land use. Follow‐up indoor air sampling did not identify PCE or other VOCs at concentrations above their respective screening levels for commercial land use, although PCE was detected at measurable concentrations in indoor air samples. The presence of PCE in soil vapor has the potential to exceed environmental screening levels, but is unlikely to exceed the multiple orders of magnitude higher than OSHA construction wo rker respiratory standards. Although PCE was not detected at concentrations above its indoor air screening level, PCE was detected above detection limits and only a limited number of samples were collected as part of the screening -level soil vapor survey; higher concentrations of PCE may be present in soil vapor in areas not sampled. Based on the presence of PCE in soil vapor, this is a potentially significant impact.
(B) Project Design Features

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No specific project design features are proposed with regard to hazards and hazardous materials.
(C) Mitigation Measures
HAZ-MM-1: Health and Safety Plan. Before the start of ground-disturbing activities, including grading, trenching, or excavation, or structure demolition on parcels within the Project Site, the Applicant for the specific work proposed shall require that the construction contractor(s) retain a qualified professional to prepare a site-specific health and safety plan (HASP) in accordance with federal Occupational Safety and Health Administration regulations (29 CFR 1910.120) and California Occupational Safety and Health Administration regulations (8 CCR Section 5192).

The HASP shall be implemented by the construction contractor to protect construction workers, the public, and the environment during all ground- disturbing and structure demolition activities. HASPs shall be submitted to Culver City and the City of Los Angeles building departments and any applicable oversight regulatory agency for review before the start of demolition and construction activi ties and as a condition of the grading, construction, and/or demolition permit(s). The HASP shall include, but not be limited to, the following elements:
• Designation of a trained, experienced site safety and health supervisor who has the responsibility and authority to develop and implement the site HASP.
• A summary of all potential risks to demolition and construction workers and maximum exposure limits for all known and reasonably foreseeable site chemicals.
• Specified personal protective equipment and deco ntamination procedures, if needed.
• The requirement to prepare documentation showing that HASP measures have been implemented during construction (e.g., tailgate safety meeting notes with signup sheet for attendees).
• A requirement specifying that any site w orker who identifies hazardous materials has the authority to stop work and notify the site safety and health supervisor.
• Emergency procedures, including the route to the nearest hospital. • Procedures to follow if evidence of potential soil or groundwater contamination is encountered (such as soil staining, noxious odors, debris or buried storage containers). These procedures shall be followed in accordance with hazardous waste operations regulations and specifically

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include, but not be limited to, immediat ely stopping work in the vicinity of the unknown hazardous materials release; notifying the city within which the contamination is encountered and the regulatory agency overseeing site cleanup, if any; and retaining a qualified environmental firm to perform sampling and remediation, if warranted.

HAZ-MM-2: Soil and Groundwater Management Plan. In support of the HASP described in Mitigation Measure HAZ-MM-1, the contractor conducting excavation and disposal of fill and soil shall develop and implement a soil and groundwater management plan (SGMP) for the management of soil, soil gas, and groundwater before any ground-disturbing activity to manage contaminated materials, if encountered. The SGMP shall include the following, at a minimum:
• Site description, in cluding the hazardous materials that may be encountered.
• Roles and responsibilities of on -site workers, supervisors, and the regulatory agency.
• Training for site workers focused on the recognition of and response to encountering hazardous materials or unknown structures, e.g., underground storage tanks (USTs).
• Notification requirements in the event of discovery of unknown structures or contamination.
• Protocols for the materials (fill, soil, and dewatering effluent) testing, handling, removing, transporting, and disposing of all excavated materials and dewatering effluent in a safe, appropriate, and lawful manner.
• Reporting requirement to the overseeing regulatory agency, if any contamination is found that requires agency oversight, documenting that site activities were conducted in accordance with the SGMP.

The SGMP shall be submitted to Culver City and the City of Los Angeles Building Departments for review to inform their permit approval process before the start of demolition and construction activities and as a condition of the grading, construction, and/or demolition permit(s). The contract specifications shall mandate full compliance with all applicable federal, state, and local regulations related to the identification, transportation, and disposal of hazardous materials.

The SGMP shall include measures to remove and/or treat/remediate the impacted soils and groundwater in a manner that is protective of human health and the environment and compatible with office use, in compliance with all applicable regulatory standards, under supervision of a qualified environmental professional. The SGMP shall describe measures for (i) management of excavated soils and groundwater, (ii) characterization of soils to determine

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whether they qualify as hazardous waste unde r regulations such as 22 C.C.R.

Section 66262.11 or other regulations identified in the SGMP or otherwise identified by the oversight agencies, and (iii) off -site disposal of excavated soils and disposal of dewatered groundwater in compliance with all appl icable regulations. The SGMP shall also provide measures for the evaluation of vapor intrusion risk at the Project site, and if necessary, modification of the Project design and/or installation of a vapor intrusion mitigation system consistent with the procedures and performance standards set forth in DTSC’s October 2011 Vapor Intrusion Mitigation Advisory or as otherwise determined applicable by the oversight agency (i.e., applicable city building departments) at the time of construction. For example, as part of the vapor intrusion evaluation, at least two rounds of indoor and garage air sampling shall be conducted post -construction and prior to operation and occupancy of the Project to confirm that future workers and valet parking personnel are protected and potential human health risks due to vapor intrusion are at or below target risk levels established by DTSC, as applicable. Sampling activities shall include collection of samples when the HVAC system is on and off and also when the parking garage venti lation system is on and off. Given that benzene is a component of gasoline and will be present in the garage due to the parked cars, the air sampling activities shall focus on PCE to confirm that residual PCE in soil vapor does not pose a significant vapo r intrusion risk to workers and valet parking personnel. These air sampling activities will aid in the evaluation of the efficacy of the liner and the garage itself to mitigate vapor intrusion. These sampling activities will also help evaluate if any preferential pathways (e.g., utility conduits and elevator shaft) need to be addressed. In the event the indoor air data indicate that risks are above target DTSC risk levels, as applicable, after pathways are sealed, the garage’s ventilation system shall be adjusted to reduce vapor intrusion levels below acceptable risk levels, as applicable.

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Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding hazardous materials.
(E) Rationale for Finding
To ensure the proper management of hazardous material and to reduce the risk of potential impacts to the public or the environment, the Project would be required to implement Mitigation Measure HAZ -MM-1, which requires the preparation and implementation of a site -specific HASP in accordance with federal and State OSHA regulations, and Mitigation Measure HAZ - MM-2, which requires the preparation and implementation of a SGMP prior to and during Project construction. Groundwater management is included because three levels of below grade parking would be constructed, which would encounter groundwater known to be contaminated. The implementation of these mitigation measures would reduc e impacts to a less than significant level.
(F) Reference
Section 4.7, Hazards and Hazardous Materials, of the Draft EIR as well as Appendix H (Phase I ESA) and Final EIR, Section 3, Revisions, Clarifications and Corrections to the Draft EIR.

5. Hydrology – Water Quality
(A) Impact Summary
As discussed in Section 4.7, Hazards and Hazardous Materials, of the Draft EIR, benzene, toluene, ethylbenzene, xylenes, and naphthalene, all components of fuel, were detected in groundwater generally in the southern/southeastern portion of the Project Site at concentrations above drinking water standards (also referred to as maximum contaminant levels (MCLs). Compliance with applicable National Pollutant Discharge Elimination System (NPDES) permitting requir ements and Los Angeles Regional Water Quality Control Board (LARWQCB) Waste Discharge requirements (WDRs) for discharges of groundwater from construction and project dewatering to surface waters in coastal watersheds of Los Angeles County, or any other appropriate WDR permits identified by the LARWQCB, would require the discharger to test for any suspected pollutants and either treat the pollutants such that the dewatering effluent water quality is acceptable for the receiving waters or arrange for an alternate disposal method. Compliance with an appropriate WDR permit would include monitoring, treatment if appropriate, and proper disposal of any encountered groundwater in accordance with applicable water quality standards. Nonetheless, if contaminated soi ls or groundwater are encountered during construction excavation activities and not properly handled or disposed of, there could potentially be adverse impacts to surface or groundwater quality. As such, this is considered a potentially significant impact. (B) Project Design Features
No specific project design features are proposed with regard to hydrology and water quality. (C) Mitigation Measures

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HAZ-MM-2: Soil and Groundwater Management Plan. In support of the HASP described in Mitigation Measure HAZ-MM-1, the contractor conducting excavation and disposal of fill and soil shall develop and implement a soil and groundwater management plan (SGMP) for the management of soil, soil gas, and groundwater before any ground-disturbing activity to manage contaminated materials, if encountered. The SGMP shall include the following, at a minimum:
• Site description, including the hazardous materials that may be encountered.
• Roles and responsibilities of on-site workers, supervisors, and the regulatory agency.
• Training for site workers focused on the recognition of and response to encountering hazardous materials or unknown structures, e.g., underground storage tanks (USTs).
• Notification requirements in the event of discovery of unknown structures or contamination.
• Protocols for the materials (fill, soil, and dewatering effluent) testing, handling, removing, transporting, and disposing of all excavated materials and dewatering effluent in a safe, appropriate, and lawful manner.
• Reporting requirement to the overseeing regulatory agency, if any contamination is found that requires agency oversight, documenting that site activities were conducted in accordance with the SGMP.

The SGMP shall be submitted to Culver City and the City of Los Angeles Building Departments for review to inform their permit approval process before the start of demolition and construction activities and as a condition of the grading, construction, and/or demolition permit(s). The contract s pecifications shall mandate full compliance with all applicable federal, state, and local regulations related to the identification, transportation, and disposal of hazardous materials.

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design and/or installation of a vapor intrusion mitigation system consistent with the procedures and performance standards set forth in DTSC’s October 2011 Vapor Intrusion Mitigation Advisory or as otherwise determined applicable by the oversight agency (i.e., applicable city building departments) at the time of construction.

For work that would encounter groundwater, as part of the SGMP, contractors shall include a groundwater dewatering control and disposal plan specifying how groundwater (dewatering effluent) will be handled and disposed of in a safe, appropriate, and lawful manner. The groundwater portion of the SGMP shall include the following, at a minimum:
• The locations at which groundwater dewatering is likely to be required. • Test methods to analyze groundwater for hazardous substances. • Appropriate treatment and/or disposal methods.
• Discussion of discharge to a publicly owned treatment works or the stormwater system, in accordance with any regulatory requirements the treatment works may have, if this effluent disposal option is to be used. (D) Finding
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding hydrology – water quality. (E) Rationale for Finding
Excavation activities during construction could encounter contaminated soils or groundwater, which if n ot properly handled or disposed of, could potentially result in adverse impacts to surface or groundwater quality. As such, construction -related impacts related to violations of water quality standards or waste discharge requirements would be potentially s ignificant.

Implementation of Mitigation Measure HAZ -MM-2, Soil and Groundwater Management Plan, would reduce this impact to less than significant.
(F) Reference
Section 4.7, Hazards and Hazardous Materials, as well as Section 4.8, Hydrology and Water Quality, of the Draft EIR and Appendix I (Hydrology Report).

6. Tribal Cultural Resources
(A) Impact Summary
As detailed in Section 4.13, Tribal Cultural Resources, of the Draft EIR, due to the Project Site being located in the vicinity of old/ancient roads (that could have been possibly used as prehistoric trade routes) and Ballona Creek, the Project Site’s location in the general vicinity of

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an unnamed village (located approximately 0.30 miles southeast), and given recent discoveries during other construction projects in the vicinity, the Project Site appears to have a moderate to high potential for encountering previously unknown tribal cultural resources during construction. As a result, there is potential that the Project could cause a substantial adverse change in the significance of a tribal cultural resource as described in PRC Section 21084.2.

Accordingly, impacts on tribal cultural resources are considered potentially significant. (B) Project Design Features
No specific project design features are proposed with regard to tribal cultural resources. (C) Mitigation Measures
TCR-MM-1: Prior to the issuance of a demolition permit for the Project, the Applicant shall retain a Native American Monitor from the Gabrieleño Band of Mission Indians – Kizh Nation (Kizh Nation or Tribe). The Native American Monitor shall be present during the following construction activities that have the potential for encountering tribal cultural resources: demolition, pavement removal, clearing/grubbing, drilling/augering, potholing, grading, trenching, excavation, tree removal or other ground disturbing activity associated with the Project, whether on the Project Site or in connection with Project off-site improvements (collectively “ground disturbing activities”). Notwithstanding the foregoing, Native American monitoring shall not be required for any moving of soils after they have been initially disturbed or displaced by Project-related construction.

The Applicant shall prepare a monitoring agreement with the Kizh Nation that outlines the roles and responsibilities of the Native American Monitor and shall submit this agreement to the City of Culver City and City of Los Angeles prior to the issuance of demolition permit for the Project.

Prior to commencement of ground disturbing activities, a Tribal Cultural Resources Sensitivity Training session shall be held for those construction personnel who will be directly involved in the ground disturbing activities. The training session shall be carried out by the Native American Monitor and shall focus on how to identify tribal cultural resources that may be encountered during ground disturbing activities and the procedures to be followed in such an event. If the Native American Monitor is not present at the Project Site on any given workday, the ground disturbing activities may continue if the workers involved in such activities attended the training session.

Native American monitoring shall conclude no later than conclusion of ground disturbing activities.

TCR-MM-2: The Native American Monitor shall complete daily monitoring logs that provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil

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types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs shall identify and describe any discovered tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the Applicant and the City of Culver City and/or City of Los Angeles upon written request to the Tribe.

The Applicant shall not be deemed to be out of compliance with this measure if the Native American Monitor fails to complete or submit any such monitoring logs.

TCR-MM-3: In the event of a discovery of potential tribal cultural resources at the Project Site, the Qualified Archaeologist identified in Mitigation Measure CUL- MM-1 (after consultation with the Native American Monitor) shall have the authority to temporarily divert, redirect, or halt ground-disturbance activities to allow identification, evaluation, and potential recovery of such potential resources. After consulting with the Native American Monitor and the Applicant, the Qualified Archaeologist shall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety considerations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where ground-disturbing activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area.

Within three (3) business days of such discovery, a meeting shall take place between the Applicant, the Qualified Archaeologist, the Tribe, and the City of Culver City and/or City of Los Angeles depending on the location/jurisdiction where the resource is located to discuss the significance of the find and whether it qualifies as a tribal cultural resource pursuant to Public Resources Code Section 21074(a). If, as a result of the meeting and after consultation with the Tribe, the Applicant, and the Qualified Archaeologist, the City of Culver City and/or City of Los Angeles determines, based on substantial evidence, that the resource is in fact a tribal cultural resource, the Qualified Archaeologist shall develop a reasonable and feasible treatment plan, with input from the Tribe as necessary, and with the concurrence of the appropriate City’s Planning Director.

The treatment measures in the treatment plan shall be in compliance with any applicable federal, State, or local laws, rules or regulations. The treatment plan shall also include measures regarding the curation of the recovered resources.

If the Applicant does not accept a particular recommendation determined to be reasonable and feasible by the Qualified Archaeologist (including, but not limited to, the size of the buffer set forth above), the Applicant, or its successor, may request mediation by a mediator agreed to by the Applicant and the City of Culver City and/or City of Los Angeles. The mediator must have the requisite professional qualifications and experience to mediate such a dispute. The City of Culver City and/or City of Los Angeles shall make the determination as to

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whether the mediator is at least minimally qualified to mediate the dispute.

After making a reasonable effort to mediate this particular dispute, the City may:
(1) require the recommendation be implemented as originally proposed by the Archaeologist; (2) require the recommendation, as modified by the City, be implemented as it is at least as equally effective to mitigate a potentially significant impact; (3) require a substitute recommendation be implemented that is at least as equally effective to mitigate a potentially significant impact to a tribal cultural resource; or (4) not require the recommendation be implemented because it is not necessary to mitigate any significant impacts to tribal cultural resources. The Applicant shall pay all costs and fees associated with the mediator.

The Applicant may recommence ground disturbance activities inside of the specified radius of the discovery site only after it has complied with all of the recommendations developed and approved pursuant to the process set forth in the above paragraphs.

The recovered Native American resources may be placed in the custody of the Tribe, who may choose to use them for their educational purposes, or they may be curated at a public, non-profit institution with a research interest in the materials. If neither the Tribe nor an institution accepts the resources, they may be donated to a local school or historical society in the area for educational purposes.

Notwithstanding the above paragraph, any information determined to be confidential in nature by the City of Culver City and/or City of Los Angeles Attorney’s office, shall be excluded from submission to the SCCIC or the general public under the applicable provisions of the California Public Records Act, California Public Resources Code Section 6254(r).
(D) Finding
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding tribal cultural resources. (E) Rationale for Finding
In the event unknown tribal cultural resources are unearthed during construction of the Project, with implementation of Mitigation Measures TRC -MM-1 through TRC -MM-3, potentially significant impacts on tribal cultural resources would be reduced to a less than significant level.

Cumulative impacts regarding tribal cultural resources were determine d to be less than significant without mitigation.
(F) Reference

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Section 4.13, Tribal Cultural Resources, of the Draft EIR as well as Appendix D of the Draft EIR, Archaeological Resources Assessment Report and Final EIR, Section 3, Revisions, Clarifications and Corrections to the Draft EIR.

VIII. ENVIRONMENTAL IMPACTS FOUND TO BE SIGNIFICANT EVEN AFTER

MITIGATION
The following impact areas were concluded by the Draft EIR to remain significant and unavoidable following implementation of all feasible mitigation measures described in the Final EIR. Consequently, in accordance with CEQA Guidelines Section 15093, a Statement of Overriding Considerations has been prepared (see Section XI of these Findings).

1. Air Quality – Construction Emissions (Regional; Overlap) (A) Impact Summary
During 2025, there will be period of time where Building 1 is operational and Building 2 is still under construction. The emissions are presented in Table 4.2-7. The Project’s overlapping operational and construction emissions of NOX in 2025 would exceed the SCAQMD thresholds of significance. Emissions of other criteria pollutants would be below SCAQMD thresholds.

The NO X emissions result primarily from heavy -duty trucks from overlapping construction of Building 2 while Building 1 is operational. Therefore, the Project’s temporary impact related to overlapping operational and construction regional NO X emissions would be p otentially significant.
(B) Project Design Features
No specific project design features are proposed with regard to air quality. (C) Mitigation Measures
AQ-MM-1: Construction Equipment Features: The Project shall implement the following construction equipment features for equipment operating at the Project Site. These features shall be included in applicable bid documents, and successful contractor(s) must demonstrate the ability to supply such equipment.

Construction features shall include the following:
• During plan check, the Project’s representative shall make available to the lead agency and South Coast Air Quality Management District (SCAQMD) a comprehensive inventory of all off-road construction equipment, equal to or greater than 50 horsepower, that shall be used during any of the construction phases. The inventory shall include the horsepower rating, engine production year, and certification of the specified Tier standard. A copy of each such unit’s certified tier specification, best availabl e control technology (BACT) documentation, and CARB or SCAQMD operating permit shall be maintained on -site at the time of mobilization of each applicable unit of equipment. Off-road diesel-powered equipment equal to or greater than 50 horsepower that will be used during any portion of the

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construction activities shall meet or exceed the Tier 4 Final standards.

Such equipment will be outfitted with Best Available Control Technology (BACT) devices, including a CARB -certified Level 3 Diesel Particulate Filter or equivalent. Alternate construction equipment may be used if the construction contractor can document that the equipment would achieve the same or greater NOx reductions compared to Tier 4 Final standards.

4. During demolition, site preparation, and grading and excavation activities, the contractor shall provide notification and documentation that haul truck drivers have received training regarding idling limitations specified in Title 13 California Code of Regulations, Sect ion 2485. During construction, trucks and vehicles in loading and unloading queues shall have their engines turned off after 5 minutes when not in use, to reduce vehicle emissions.
• Contractors shall maintain and operate construction equipment so as to minimize exhaust emissions. All construction equipment must be properly tuned and maintained in accordance with the manufacturer’s specifications. The contractor shall keep documentation on -site demonstrating that the equipment has been maintained in accordance with the manufacturer’s specifications. Tampering with construction equipment to increase horsepower or to defeat emission control devices shall be prohibited.

5. Construction activities shall be discontinued during an Air Quality Index (AQI) of 151 or more (unhealthy level). A record of any AQI at an unhealthy level and of discontinued construction activities as applicable shall be maintained by the Contractor on-site.
(D) Finding
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterati ons have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Air Quality Construction Emissions (Regional; Overlap). (E) Rationale For Finding
The Project’s mitigated regional o verlapping construction and operational emissions are summarized in Table 4.2-10 of the Draft EIR. The Project would result in potentially significant overlapping construction and operational regional NO X emissions above the regional significance thresholds. Mitigation Measure AQ-MM-1 would be required to reduce overlapping construction-related NOX emissions that would be concurrent with the partial buildout regional operational emissions. In addition, there are no feasible mitigation measures to reduce

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operational source emission of NO X. With implementation of feasible mitigation to reduce construction emissions, regional emissions from overlapping construction and operations would remain above the regional significance threshold for NO X. As shown in Table 4.2-10 of the Draft EIR, the mitigated construction emissions in 2025 (i.e., when construction would overlap with operations) would by itself exceed the operational emissions threshold. Mitigation Measures AQ-MM-1 already includes the most stringent emi ssions standards adopted by the State (i.e., Tier 4 Final emissions standards). CARB staff is in the process of developing potential amendments to the off-road diesel engine standards, in what is referred to as the Tier 5 rulemaking, which is intended to reduce NO X and particulate matter emissions from new, off‐road compression -ignition engines compared to the adopted Tier 4 Final emission standards. However, CARB has not formally drafted any proposed amendments nor initiated the formal rule-making process. CARB anticipates to bring a proposal to the CARB Governing Board in 2024 and anticipates implementation of the Tier 5 standards for new equipment in 2028. This timeline renders the potential use of Tier 5 equipment as infeasible. There are no feasible mitigation measures that would reduce the overlapping construction and operational emissions to below the operational significance threshold. Therefore, short -term and temporary impacts related to regional NOX overlapping construction and operations emissions would be significant and unavoidable after implementation of feasible mitigation measures.

There would also be a cumulatively considerable net increase of NO X emissions which would result in a significant and unavoidable impact.
(F) Reference
Section 4.2, Air Quality and Appendix B, Air Quality and Greenhouse Gas Emissions Calculations of the Draft EIR as well as Final EIR Section 3, Revisions, Clarifications and Corrections, to the Draft EIR.

2. Noise
(A) Impact Summary
(i) Project-Level On-Site Construction Noise
As shown in Table 4.10-10 of the Draft EIR, construction noise levels are estimated to reach a maximum of 88.6 dBA Leq at the nearest sensitive receptors (namely R2 within the City of Culver City limits), as well as exceed the lowest amb ient noise-based threshold of 72.0 dBA.

At R1, which is located within the City of Los Angeles, the maximum construction noise level would be 80.7 dBA Leq, which would exceed the 75.0 dBA limit in the City of Los Angeles Noise Ordinance and would exceed th e lowest ambient noise -based threshold of 67.6 dBA.

Construction noise level projected at R3 (within the City of Culver City limits) would reach 82.0 dBA and exceed the ambient noise-based threshold of 69.0 dBA. Construction noise projected at R4 (within the City of Culver City limits) would reach 67.4 dBA and exceed the ambient noise- based threshold of 64.6 dBA.

As shown in Table 4.10 -10 of the Draft EIR, construction activities would result in temporary increases in ambient noise (greater than 5 dBA Leq over ambient levels) at most of the studied sensitive receptors prior to implementation of measures to reduce the construction noise.

Project construction would result in noise levels greater than 5 dBA Leq over ambient levels

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during multiple phases of activity at R1, R2, R3 and R4. When construction activity extends to the evening or nighttime hours, the ambient -based threshold would be exceeded at off -site receiver locations. When daytime ambient noise levels are lower compared to the corresponding evening hours at the same location, the lower daytime ambient noise level is used as the threshold for significance determination.

Based on the results of the analysis, it can be assumed that ambient noise at certain residential uses to the north, west, and south would be significantly impacted by Project construction. The level of impact at each residential area would vary due to varying distances to Project construction and the presence of intervening structures such as existing buildings.

CCMC noise regulations state that construction activity shall be prohibited, except between the hours of 8:00 a.m. and 8:00 p.m. Mondays through Fridays; 9:00 a.m. and 7:00 p.m.

Saturdays; 10:00 a.m. and 7:00 p.m. Sundays. LAMC Section 41.40 prohibits construction between the hours of 9:00 p.m. and 7:00 a.m. Monday through Friday, 6:00 p.m. and 8:00 a.m. on Saturday, and at any time on Sunday (i.e., construction is allowed Monday through Friday between 7:00 a.m. and 9:00 p.m.; and Saturdays and National Holidays between 8:00 a.m. to 6:00 p.m.). In the event construction occurs outside of the permitted hours without approval from the respective jurisdiction, as applicable, a significant impact would occur. However, it is anticipated that the Project would seek approval from the respective jurisdiction, as applicable, to initiate construction as early as 7:00 a.m. and end as late as 10:00 p.m. During these extended construction hours (i.e., 7:00 a.m. to 8:00 a.m. and 8:00 p.m. to 10:00 p.m.) noise levels could still nonetheless exceed the thresholds as shown in Table 4.10-10 of the Draft EIR, and for this reason, would be considered potentially significant impacts.

As Project construction would result in temporary increases in ambient noise that would exceed thresholds o f significance at all studied receptors, construction noise impacts would be potentially significant, and mitigation measures would be required. (ii) Cumulative On-Site Construction Noise
Six of the related projects (Related Project Nos. 5, 8, 9, 11, 14, and 15 ) are located within approximately 1,000 feet of the Project Site and could contribute to cumulative construction noise impacts from on-site construction activities to off-site sensitive receptors if they are under construction at the same time as the Proj ect. Each of these related projects are required to comply with the noise standards and ordinances of the City of Culver City and City of Los Angeles, as applicable. Exact construction schedules for these related projects are not known.

It is not possib le to predict whether construction of these related projects would overlap with construction of the Project. Therefore, it is conservatively assumed that construction of these related projects could occur at the same time as the Project. Because the Project would result in potentially significant construction noise impacts prior to mitigation measures, cumulative on-site noise from the Project and related projects could result in potentially significant cumulative construction noise impacts at similar off -site receptors and receivers between the Project Site and the nearest related project sites.

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(iii) Cumulative Off-Site Construction Noise
As shown in Table 4.10-11 of the Draft EIR, the Project would not result in any significant off - site construction noise imp acts due to construction trips. The roadway in the vicinity of the Project Site that would have off-site construction noise levels from Project construction trucks closest to the significance threshold would be Cattaraugus Avenue south of Venice Boulevard, which would have a maximum of up to 63 Project truck trips per hour (heavy -duty concrete, vendor, and haul trucks from overlapping Project construction activities), which would generate a combined Existing plus Project Construction Traffic noise level of approximately 67.9 dBA Leq (an increase of 4.3 dBA from the Existing baseline traffic noise level 63.5 dBA Leq). Related projects contributing an additional 8 heavy -duty truck trips per hour on the same roadway segment at the same time as the Project woul d generate a combined noise level of approximately 68.5 dBA L eq. This cumulative noise level would be equal to the significance threshold of (63.5 + 5 =) 68.5 dBA on Cattaraugus Avenue south of Venice Boulevard in the vicinity of the Project Site. Theref ore, related projects contributing more than 8 truck trips concurrently with the Project would result in a cumulatively considerable contribution to off-site construction noise and impacts would be significant. It is conservatively assumed that truck traffic from multiple related projects could potentially overlap on some days and generate noise in excess of the significance threshold. Therefore, given that it is possible that the Project and related projects could contribute to cumulative off-site construction traffic noise levels and could exceed a significance threshold with sufficiently high cumulative traffic levels, cumulative off - site construction traffic noise impacts would be potentially significant. (iv) Vibration – Off-Site Construction (Human Annoyance) Per Federal Transit Authority guidance, the significance criterion for human annoyance is 72 VdB for sensitive uses, including residential, hotel and theater uses. It should be noted that buses and trucks rarely create vibration that exceeds 70 VdB at 50 feet from the receptor unless the road surface is not smooth. To provide a conservative analysis, the estimated vibration levels generated by construction trucks traveling along the anticipated haul route(s) were assumed to be within 25 feet of the se nsitive use (residential and hotel use) along Venice Boulevard, Washington Boulevard, S. Robertson Boulevard, and National Boulevard.

Temporary vibration levels could reach approximately 72 VdB periodically as heavy -duty construction trucks, including haul trucks and concrete trucks, pass sensitive receptors along the anticipated haul route(s). Therefore, the residential uses along National Boulevard, Washington Boulevard, S. Robertson Boulevard, and Venice Boulevard (between the Project Site and I-10), would be exposed to ground -borne vibration up to 72 VdB, which would be at the 72-VdB significance criteria from the heavy -duty construction trucks. As such, potential vibration impacts with respect to human annoyance that would result from temporary and intermittent off-site vibration from heavy-duty construction trucks traveling along the anticipated haul route(s) would be significant.
(v) Vibration – Cumulative Off-Site Construction (Human Annoyance) Due to rapid attenuation characteristics of groundborne vibration, only related projects located adjacent to the same sensitive receptors would result in cumulatively considerable vibration impacts. It is unusual for groundborne vibration from sources such as rubber-tired trucks to be

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perceptible, even in locati ons close to major roads, unless the road surface is rough with uneven spaces. Several related projects are in locations that could potentially lead construction traffic, including truck traffic near sensitive vibration receptors. Should construction of the Project and related projects overlap, there is a potential for cumulative vibration impacts to sensitive vibration receptors. Construction of the Project, both on -site and off-site, would not result in significant vibration impacts related to structural damage. However, the Project would result in vibration impacts related to human annoyance. As such, should construction traffic of the Project and related projects overlap, potential vibration impacts with respect to human annoyance that would result from temporary and intermittent off-site vibration from construction trucks traveling along the anticipated haul route(s) would be significant. Therefore, cumulative off-site construction vibration impacts would be potentially significant. (B) Project Design Features
NOI-PDF-1: Project Construction Schedule. Prior to issuance of a building permit, notice of the Project construction schedule will be provided to abutting property owners and occupants. Evidence of such notification will be provided to the appropriate department of City of Culver City and City of Los Angeles. The notice will identify the commencement date and proposed timing for all construction phases (demolition, grading, excavation/shoring, foundation, rough frame, plumbing, roofing, mechanical and electrical, and exterior finish).

NOI-PDF-2: Use of Impact Pile Driver. The Project will not require or allow the use of impact pile drivers. Lower noise- and vibration-generating vibratory pile drivers and drills will be used.

NOI-PDF-3: Construction Rules Sign. During all phases of construction, a “Construction Rules Sign” that includes contact names and telephone numbers, with 24-hour availability, of the Applicant, Property Owner, construction contractor(s) will be posted on the Property in a location that is visible to the public. In addition, appropriate staff person at both City of Los Angeles and City of Culver City will be notified for such incidences. These names and telephone numbers will also be made available to adjacent property owners and occupants to the satisfaction of the appropriate department (Planning Manager and/or Building Official) of both cities.

NOI-PDF-4: Compliance with Noise Element. The following noise standards from Policy 2.A of the City of Culver City’s General Plan Noise Element will be complied with at all times:
a) No construction equipment will be operated without an exhaust muffler, and all such equipment will have mufflers and sound control devices (i.e., intake silencers and noise shrouds) that are no less effective than those provided on the original manufacturer supplied equipment; b) All construction equipment will be properly maintained to minimize noise emissions;

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c) If any construction vehicles are serviced at an on -site location, the vehicle(s) will be setback from any street and other property lines so as to maintain a distance of at least 100 feet from the public right -of-way and from Noise Sensitive Receptors;
d) Noise levels from stationary sources (i.e., mechanical equipment, ventilators, and air conditioning units) will be minimized by proper selection of equipment and the installation of parapets or other acoustical shielding as approved by the Planning Manager;
e) The Project will not allow any delivery truck idling for more than 5 minutes in the loading area. Signs will be posted prohibiting such idling.

NOI-PDF-5: Neighborhood Streets. No construction haul trucks, including concrete trucks, will be allowed to travel through neighborhood streets that are primarily residential uses.

NOI-PDF-6: Mechanical Equipment Noise. All building mechanical equipment and/or ventilation systems not fully enclosed will be designed to not exceed sound level limits of the noise level requirements of the City of Culver City General Plan Noise Element Regulation of Stationary Noise Sources and City of Los Angeles Municipal Code Section 112.02 through the use of quiet fans, duct silencers, parapets, or similar noise attenuation methods.

NOI-PDF-7: Loading Dock Operating Hours. On-site loading dock operating hours will be limited to 7:00 a.m. to 10:00 p.m.

NOI-PDF-8: Noise Control – Amplified Sound Systems. If the Project installs permanent outdoor amplified sound systems, the systems will be located in the central courtyard such that the sound would be blocked by the propose d on-site building from off-site receivers. No amplified sound systems would be installed in the publicly accessible areas along the Project’s street frontages. Section

9.07.055(B) of the CCMC prohibits the operation of a loud speaker or sound amplifying equipment for the purposes of transmitting messages, giving instructions, or providing entertainment on an ongoing basis which is audible at the subject property line. The systems will be designed so as not to result in a perceivable increase in noise beyo nd the Project Site. Specifically, daytime outdoor amplified sound systems will not result in an increase of 3 dBA L eq over existing ambient noise conditions at the Project property line. Nighttime speaker noise, if it occurs, will comply with the exterior noise standards identified in the Regulation of Stationary Noise Sources (City of Culver City General Plan Noise Element, approved by City Council July 22, 1996) and LAMC Section 112.01, which states that a noise source that causes a noise level increase of 5 dBA over the existing average ambient noise level as measured at an adjacent property line creates a noise violation, respectively, within the City of Culver City and City of Los Angeles jurisdiction. All speakers will have a minimum setback of 25 fee t from the Project property line and will be directed internally and acoustically

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shielded from off-site uses. Under the rare occasion of maximum crowd gathering in the central courtyard with temporary amplified sound systems, the combined sound level from speakers and people conversation shall not exceed the ambient noise level plus 5 dBA at an adjacent property line, which would limit the speaker sound level to a maximum of 90 dBA when measured at a distance of 50 feet from the speakers. A qualified noise consultant will provide written documentation and submitted to appropriate department of City of Culver City and City of Los Angeles that the design of the system(s) complies with the maximum noise levels at the property line of the nearest off-site sensitive receivers. (C) Mitigation Measures
NOI-MM-1: Prior to the commencement of demolition, the Project shall provide a temporary 12-foot-tall construction fence equipped with noise blankets rated to achieve sound level reductions of at least 10 dBA along the northern and western boundaries of the Project Site, between the Project Site and the surrounding residences to the north and west. In addition, a temporary 6-foot- tall construction fence equipped with noise blankets rated to achieve sound level reductions of at least 5 dBA along the southern boundary along Washington Boulevard, between the Project Site and the residences to the south and east of the Project Site. Temporary noise barriers shall be used to block the line-of-sight between the construction equipment and the nearby noise-sensitive receptors during the duration of construction activities to the extent feasible. Standard construction protective fencing with green screen or pedestrian barricades for protective walkways shall be installed along property lines facing streets or commercial buildings. All temporary barriers, fences, and walls shall have gate access as needed for construction activities, deliveries, and site access by construction personnel. At Plan Check at City of Culver City and City of Los Angeles, the Applicant shall provide a study conducted by a noise expert that demonstrates the sound barriers would achieve these required dBA reductions.

NOI-MM-2: Contractors shall ensure that all construction equipment, fixed or mobile, are equipped with properly operating and maintained noise shielding and muffling devices, consistent with manufacturers’ standards. The construction contractor shall keep documentation on -site demonstrating that the equipment has been maintained in accordance with the manufacturers’ specifications. Most of the noise from construction equipment originates from the intake and exhaust portions of the engine cycle. According to FHWA, use of adequate mufflers systems can achieve reductions in noise levels of up to 10 dBA. 1 The contractor
shall use muffler systems that provide a minimum reduction of 8 dBA compared to the same equipment without an installed muffler system, reducing maximum construction noise levels. The contractor shall also keep documentation on -site

1 FHWA, Special Report – Measurement, Prediction, and Mitigation, Chapter 4 Mitigation, last updated June 28, 2017, https://www.fhwa.dot.gov/Environment/noise/construction_noise/special_report/hcn04.cfm20.

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prepared by a noise consultant verifying compliance with this measure. The study will include a fencing/sound barrier plan for City review. (D) Finding
(i) Project-Level On-Site Construction Noise
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alte rations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Project-Level On-Site Construction Noise. (ii) Cumulative On-Site Construction Noise
Pursuant to PRC Section 2108 1(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Cumulative On-Site Construction Noise. (iii) Cumulative Off-Site Construction Noise
Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Cumulative Off-Site Construction Noise. (iv) Vibration – Off-Site Construction (Human Annoyance) Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Vibration – Off-Site Construction (Human Annoyance). (v) Vibration – Cumulative Off-Site Construction (Human Annoyance) Pursuant to PRC Section 21081(a)(1), the City finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid potential significant effects on the environment regarding Vibration – Cumulative Off -Site Construction (Human Annoyance).
(E) Rationale for Finding
(i) Project-Level On-Site Construction Noise
Off-site receptor locations at R1, R2 and R3 have more than two -story buildings in their respective area that they represented, and these buildings have upper floor receivers/units that have outdoor living areas, particularly on the side facing the Project construction areas, that would be exposed to construction noise from the Project Site. Mitigation Measure NOI -MM-1 would provide at least a 10 dBA noise reduction at ground-floor sensitive receptors R1 and R2, and 5 dBA noise reduction at sensitive recep tors R3 and R4. Mitigation Measure NOI -MM-2 requires that muffler systems provide a minimum reduction of 8 dBA compared to the same equipment without an installed muffler system. As shown in Table 4.10 15 of the Draft EIR, construction noise impacts would be reduced by a level that is technically feasible as set forth in Mitigation Measures NOI-MM-1 and NOI-MM-2 and consistent with Policy 2.A of the City of

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Culver City General Plan Noise Element. With implementation of mitigation measures, maximum constr uction noise levels would not increase ambient noise levels at any of the ground-floor noise-sensitive receptor locations above the applicable thresholds of significance.

However, with respect to on-site construction equipment noise, noise barriers have a technical limitation with regard to height. It is not feasible to install a construction noise barrier of sufficient height that would block the line-of-sight for all noise-sensitive receptor locations, such as upper floor areas of the sensitive resident ial units, due to technical limitations including barrier foundation needs and wind load capacities. As such, as shown in Table 4.10-15 of the Draft EIR, noise levels at the upper floors of receptor locations at R1, R2 and R3 would exceed the significant noise impact threshold after implementation of the prescribed mitigation measures. Accordingly, these impacts would be significant and unavoidable. (ii) Cumulative On-Site Construction Noise
After implementation of mitigation, the Project would result in signi ficant and unavoidable construction noise impacts. Any additional construction noise from the related projects that could combine with the Project’s construction noise, would further increase the extent of the Project’s significant and unavoidable impacts . Therefore, the Project’s contribution to cumulative construction noise would be cumulatively considerable and would represent a significant and unavoidable impact.
(iii) Cumulative Off-Site Construction Noise
The Project would result in less than significant off-site construction noise impacts. However, the related projects could generate construction truck trips, when added to the Project’s construction vehicle trips, that could generate noise in excess of the significance threshold.

Therefore, the Project’ s contribution to cumulative off -site construction noise would be cumulatively considerable and would represent a significant and unavoidable impact. No additional feasible mitigation measures are available for the Project to implement to further reduce impacts. Residential land uses comprise the majority of existing sensitive uses within the Project Site area that could be impacted by the increase in traffic generated noise levels.

Construction of sound barriers would be inappropriate for residential la nd uses that face the roadway as it would be impractical and create aesthetic and access concerns. Therefore, given that it is possible that the Project and related projects could contribute to cumulative off -site construction traffic noise levels and could exceed a significance threshold with sufficiently high cumulative traffic levels, cumulative off -site construction traffic noise impacts would be temporarily significant and unavoidable.
(iv) Vibration – Off-Site Construction (Human Annoyance) Traffic travelling on public roadways, including haul trucks on the haul routes, is beyond the control of the proposed Project. In addition, Project -related heavy-duty construction trucks would be restricted to the designated haul routes (Venice Boulevard, Washington B oulevard, National Boulevard, and La Cienega Boulevard) and avoid other neighborhood streets, so that this potential impact is minimized. No feasible or practical mitigation measures are available to reduce vibration impact associated with haul trucks, an d off-site construction related haul trucks traveling on public roadways would remain significant and unavoidable.

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(v) Vibration – Cumulative Off-Site Construction (Human Annoyance) Cumulative impacts regarding off-site construction groundborne vibration would be potentially significant without mitigation. However, no feasible mitigation measures are available for off - site construction truck route vibration impacts, the impact would remain significant and unavoidable.
(F) Reference
Draft EIR Section 4.10, Noise, a s well as Final EIR Chapter 3, Revisions, Clarifications, and Corrections, to the Draft EIR and Appendix K (Noise Calculation Worksheets), and Appendix M (Transportation Impact Study).

IX. ALTERNATIVES TO THE PROJECT
CEQA requires that an EIR analyze a reasona ble range of feasible alternatives that could substantially reduce or avoid the significant impacts of a project while also meeting the project’s basic objectives. An EIR must identify ways to substantially reduce or avoid the significant effects that a project may have on the environment (PRC Section 21002.1). Accordingly, the discussion of alternatives shall focus on alternatives to a project or its location, which are capable of avoiding or substantially reducing any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly. The Draft EIR evaluated a reasonable range of four alternatives to the Project in detail, which include the (1) No Project/No Build Alternative; (2) Zoning -Compliant Alternative; (3) Reduced Project Alternative; and (4) Alternate Project Access Alternative. In accordance with CEQA requirements, the alternatives to the Project include a “No Project” alternative and alternatives capable of eliminating the significant adverse impacts of the project.

These alternatives and their impacts, which are summarized below, are more fully described in Section 5 of the Draft EIR.

1. Summary of Findings
Based upon the following analysis, the City finds, pursuant to CEQA Guidelines Section 15096(g)(2), that no feasible alternative or mitigation measure will substantially lessen any significant effect of the project, reduce the significant unavoidable impacts of the project to a level that is less th an significant, or avoid any significant effect the project would have on the environment.

2. Project Objectives
An important consideration in the analysis of alternatives to the Project is the degree to which such alternatives would achieve the objectives of the Project. As more thoroughly described in Section 2, Project Description, of the Draft EIR, pages 2-5 – 2-6, both the City and Applicant have established specific objectives concerning the Project, which are incorporated by reference herein and discussed further below.

3. Project Alternatives Analyzed

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(A) Alternative 1 – No Project/No Build Alternative
The No Project Alternative for a development project on an identifiable property consists of the circumstance under which the project does not proceed. CEQA G uidelines Section 15126.6(e)(3)(B) states in part that, “in certain instances, the No Project Alternative means ‘no build’ wherein the existing environmental setting is maintained.” Accordingly, for purposes of this analysis, Alternative 1, the No Project/No Build Alternative, assumes that the Project would not be approved and existing on-site uses would remain as under the existing conditions. The Project Site is currently improved with single-story warehouses that have been converted into retail, office, and surface and enclosed parking lots serving the existing uses on the Project Site. On the Culver City Parcel, the approximately 9,739 -sf building is currently used for storage and the 9,082 -sf building is currently vacant. On the Los Angeles Parcel, the approximately 86,226 -sf warehouse building has been partitioned into six separate spaces consisting of 51,500 sf of office and 34,726 sf of retail. Under this alternative, the occupied areas on the Project Site would continue to operate as under exist ing conditions. In addition, as it can be reasonably assumed that the vacant 9,082 -sf building could be occupied in the future, under this alternative this building is assumed to be re -occupied by office uses, which was the use of the building prior to becoming vacant. The 9,739-sf building on the Culver City Parcel would continue to be occupied by storage uses. No new construction would occur. (i) Impact Summary
The No Project/No Build Alternative would avoid the Project’s significant and unavoidable Project-level and cumulative regional air quality emissions, Project -level and cumulative on - site construction noise, cumulative off -site construction noise (construction vehicles), and Project-level and cumulative off -site construction (human annoyance) vibrati on (construction vehicles) impacts. Impacts associated with the remaining environmental issues would be less than those of the Project.
(ii) Finding
Alternative 1 would avoid the Project’s significant and unavoidable environmental impacts.

However, Alternative 1 would not meet the Project’s underlying purpose, or achieve most of the Project objectives. The City finds, pursuant to PRC Section 21081(a)(3), that specific economic, legal, social, technological, or other considerations, including considerations identified in Section XIII of these findings (Statement of Overriding Considerations), make infeasible the No Project/No Build Alternative, as described in the Draft EIR. (iii) Rationale for Findings
Alternative 1 assumes that no new development would occur on the Project Site. The on-site uses on the Los Angeles Parcel would continue to operate similar to existing conditions and the vacant 9,082 sf building on the Culver City Parcel would be re -occupied with office uses.

Alternative 1 would avoid the Project’s sig nificant and unavoidable environmental impacts.

While Alternative 1 would include the occupancy of the vacant building on the Project Site, Alternative 1 does not propose redevelopment of the Project Site and would not meet most of the Project objectives.

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(iv) Reference
Section 5, Alternatives, of the Draft EIR.
(B) Alternative 2 – Zoning-Compliant Alternative
With development under the Zoning -Compliant Alternative (Alternative 2), the Project Site would be developed in accordance with the existing Industrial Gener al (IG) and East Washington Overlay ( -EW) Zone on the Culver City Parcel and C2 -2D-CPIO (Commercial, Height District 2, Community Plan Implementation Overlay) zone, CPIO, and Expo TNP on the Los Angeles Parcel. The IG and -EW Zone both allow for office uses, including creative office and multimedia production. The C2 Zone permits a wide variety of commercial uses, including office uses and multimedia production. The “2D” designation following the C2 zone designates the Los Angeles Parcel as Height Distri ct 2 with a “D” Development Limitation that requires compliance with the West Adams -Baldwin Hills-Leimert CPIO, which includes regulations on permitted uses, floor area, height, setbacks, parking, and landscape. Similar to the Project, this alternative would include creative office uses.

Alternative 2 would develop a total of 491,842 sf of office uses on the Project Site compared to the Project’s proposed 536,000 sf of office uses, for an eight percent reduction in total building sf. To comply with the 43-foot height limit of the existing zoning, Building 1 on the Culver City Parcel would feature a three -story building instead of the four -story building contemplated under the Project. The reduced building would include 122,842 sf of office, 44,158 sf less than the 167,000 sf in Building 1 under the Project. Other than the reduced height and square footage, the setbacks and general massing of Building 1 would remain the same under Alternative 2. Building 2 on the Los Angeles Parcel would feature the same total building area, number of stories, and maximum height as under the Project: 369,000 sf of office, configured in a five-story building, with a maximum building height of 75 feet. Alternative 2 would include a similar publicly accessible amenity area as the Project. However, the massi ng of Building 2 would be materially different than under the Project to strictly comply with the existing zoning.

Unlike the Venice Boulevard frontage under the Project, which features an uninterrupted façade with a deeply recessed entryway, the Venice Boulevard frontage in Alternative 2 would be set back a maximum of two feet from the property line, and the street -facing façade would feature a 20-foot passageway effectively dividing Building 2 into two separate buildings, each with approximately 240 feet of frontage on Venice Boulevard. The Venice Boulevard frontage would also be built to a maximum height of 55 feet, rather than the 56 feet proposed in the Project. The National Boulevard frontage of Building 2 would observe a 15 -foot dedication.

The Venice Boulevard and National Boulevard building facades would be massed vertically from these setbacks, unlike the varied massing proposed under the Project. Levels three and four would be massed to observe the 5 -foot step back from the Helms Building that applies above 30 feet. To recapture the lost building area resulting from the 20-foot passageway along Venice Boulevard, each level of Building 2 would increase in overall depth toward the central courtyard. However, Building 2 would provide the require d open space under the CPIO. To be consistent with the tower massing requirements under the CPIO, the fifth level would be reduced to a significantly smaller floorplate and would be located toward the center of the Los Angeles parcel, away from Venice Bou levard. Finally, to comply with the mid -block Paseo

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requirements of the Expo TNP, a publicly accessible pedestrian connection would be provided along portion of Building 2 adjacent to the Helms alley.

While the number of vehicle parking spaces provided wo uld be reduced from 1,216 spaces under the Project to 1,095 spaces under Alternative 2, this alternative would still require a three- level subterranean garage under both Building 1 and Building 2 and would require a maximum excavation depth of 50 feet, similar to the Project. However, the footprint of the subterranean parking garages would be reduced, which would in turn would reduce the amount of required soil excavation. Proposed circulation and loading dock locations would be similar under the Project and Alternative 2.

As with the Project, Alternative 2 would require the demolition of the existing buildings and associated paved surface parking areas on the Project Site. Although only an eight percent reduction in sf is proposed under Alternative 2, gi ven the reduced density and sf, the overall duration and intensity of construction under Alternative 2 would be incrementally less than that of the Project.
(i) Impact Summary
Alternative 2 would involve less development compared to the Project, and would redu ce, but not eliminate, the Project’s significant unavoidable impacts related to Project -level and cumulative regional air quality emissions, Project -level and cumulative on -site construction noise, cumulative off -site construction noise (construction vehic les), and Project -level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts.

All other impacts would be less than or similar to those of the Project. (ii) Finding
Alternative 2 would not avoid the Project’s signific ant and unavoidable impacts. Moreover, while Alternative 2 would meet several of the Project objectives, it would meet other objectives to a lesser extent than the Project. The City finds, pursuant to PRC Section 21081(a)(3), that specific economic, legal, social, technological, or other considerations, including considerations identified in Section XIII of these findings (Statement of Overriding Considerations), make infeasible Alternative 2, as described in the Draft EIR. (iii) Rationale for Finding
Alternative 2 would involve less development compared to the Project, and would reduce, but not eliminate, the Project’s significant unavoidable impacts related to Project-level and cumulative regional air quality emissions, Project-level and cumulative on-site construction noise, cumulative off-site construction noise (construction vehicles), and Project-level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts.

All other impacts would be less than or similar to those of the Project. Alternative 2 is considered to be consistent with the following objectives:
• Develop an integrated Project in both the City of Culver City and City of Los Angeles with consistent land use regulations and design parameters.

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• Provide a pedestria n-oriented design that enhances pedestrian circulation and experiences around the Project Site.
• Support environmental sustainability and reduce energy consumption and water demand through sustainable building design and building features.

While Alternative 2 would provide similar office uses as the Project, it would provide these uses within a reduced building size, reduced occupancy, and with less parking per employee. As such, Alternative 2 would meet the following objectives, but to a lesser extent than the Project:
• Support City and regional goals and policies to reduce vehicle miles traveled and associated GHG and regional pollutant emissions by increasing employee density in proximity to transit, including the Metro “E” Line and numerous bus routes. • Provide high quality office space to attract and retain desirable innovative entertainment, media, and/or technology companies, including a secure site that fulfills such companies’ needs for security and privacy.
• Provide an amount of parking that satisfies anticipated demand on the Project Site but does not undercut transit usage.
• Strengthen the area’s economic vitality by attracting and retaining highly skilled workers. • Generate additional municipal revenues in the form of increased property and business license taxes, as well as increased sales taxes from increased economic activity from the additional jobs.
• Complement and improve the visual character of the area through a high level of architectural design, landscape features, and open space amenities. (iv) Reference
Section 5, Alternatives, of the Draft EIR.
(C) Alternative 3 – Reduced Project Alternative
Under the Reduced Project Alternative (Alternative 3), the Project would see a 25 percent reduction in density and sf. With this reduction, Alterna tive 3 would include a total of 402,000 sf of creative office uses compared to the Project’s proposed 536,000 sf of creative office uses.

Specifically, Building 1 on the Culver City Parcel would include 125,250 sf, a reduction of 41,750 sf as compared to 167,000 sf in Building 1 under the Project. Building 2 on the Los Angeles Parcel would include 276,750 sf, a reduction of 92,250 sf as compared to 369,000 sf in Building 2 under the Project. The height of Building 1 would remain unchanged under Alternative 3 and would reach a maximum of 56 feet, although the fourth level of Building 1 would be significantly reduced as compared to the Project. As Building 2 would consist of four stories instead of five stories as under the Project, the height of Building 2 would be reduced to a maximum of 56 feet, from the maximum of 75 feet proposed under the Project. Alternative 3 would include a similar publicly accessible amenity area as the Project.

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While the number of vehicle parking spaces provided by Alternative 3 would be reduced from 1,216 spaces under the Project to 911 spaces under Alternative 3, this alternative would still require a three -level subterranean garages under both Building 1 and Building 2 and would require a maximum excavation depth of 50 feet. H owever, the footprint of the subterranean parking garages would be reduced, which would in turn reduce the amount of required soil excavation. Proposed circulation and loading dock locations would be similar under the Project and Alternative 3.

As with th e Project, Alternative 3 would require the demolition of the existing buildings and associated paved surface parking areas on the Project Site. Given the reduced density and sf, the overall duration and intensity of construction under Alternative 3 would be less than that of the Project.
(i) Impact Summary
Alternative 3 would involve less development compared to the Project, and would reduce, but not eliminate, the Project’s significant unavoidable impacts related to Project -level and cumulative regional air q uality emissions, Project -level and cumulative on -site construction noise, cumulative off -site construction noise (construction vehicles), and Project -level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts.

All other impacts would be less than or similar to those of the Project. (ii) Finding
Alternative 3 would involve less development compared to the Project, and would reduce, but not eliminate, the Project’s significant unavoidable impacts related to Project -level and cumulative regional air quality emissions, Project -level and cumulative on -site construction noise, cumulative off -site construction noise (construction vehicles), and Project -level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts.

All other impacts would be less than or similar to those of the Project. Moreover, while Alternative 3 would most of the Project objectives, it would meet other objectives to a lesser extent than the Project. The City find s, pursuant to PRC Code Section 21081(a)(3), that specific economic, legal, social, technological, or other considerations, including considerations identified in Section XIII of these findings (Statement of Overriding Considerations), make infeasible Alternative 3, as described in the Draft EIR. (iii) Rationale for Findings
Alternative 3 would involve less development compared to the Project, and would reduce, but not eliminate, the Project’s significant unavoidable impacts related to Project-level and cumulative regional air quality emissions, Project-level and cumulative on-site construction noise, cumulative off-site construction noise (construction vehicles), and Project-level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts.

All other impacts would be less than or similar to those of the Project. As described above, Alternative 3, Reduced Project Alternative, would develop similar uses as the Project but buildings proposed on the project site would be reduced by 25 percent. Specifically, Alternative 3 would develop a total of 402,000 sf of creative office uses compared to the

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Project’s proposed 536,000 sf of creative office uses. Alternative 3 is considered to be fully consistent with the following objectives:
• Develop an integrated Project in both the City of Culver City and City of Los Angeles with consistent land use regulations and design parameters. • Provide an amount of parking that satisfies anticipated demand on the Project Site but does not undercut transit usage.
• Complement and improve the visual character of the area through a high level of architectural design, landscape features, and open space amenities. • Provide a pedestrian -oriented design that enhances pedestrian circulation and experiences around the Project Site.
• Support environmental sustainability and reduce energy consumption and water demand through sustainable building design and building features.

While Alternative 3 would provide similar office uses as the Project, it would provide these uses within a reduced building size and reduced occupancy. As such, Alternative 3 would meet the following objectives, but to a lesser extent than the Project:
• Support City and regional goals and policies to reduce vehicle miles traveled and associated GHG and regional pollutant emissions by increasing employee density in proximity to transit, including the Metro “E” Line and numerous bus routes. • Provide high quality office space to attract and retain desirable innovative entertainment, media, and/or technology companies, including a secure site that fulfills such companies’ needs for security and privacy.
• Strengthen the area’s economic vitality by attracting and retaining highly skilled workers. • Generate additional municipal revenues in the form of increased property and business license taxes, as well as increased sales taxes from increased economic activity from the additional jobs.
(iv) Reference
Section V, Alternatives, of the Draft EIR.
(D) Alternative 4 – Alternate Project Access Alternative Under the Alternate Project Access Alternative (Alternative 4), the design, use programming and configurations of Buildings 1 and 2 proposed under the Project would r emain the same.

However, the difference in Alternative 4 compared to the Project is the addition of a traffic signal at the intersection of Venice Boulevard and the proposed driveway along Venice Boulevard, located at the eastern edge the northern Project Site boundary, and the removal of office - related vehicular access on Washington Boulevard (the Washington Boulevard driveway would continue to serve as emergency access). As the required demolition, building sf, heights, land

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use uses, amenity areas, and proposed subterranean parking would be the same under Alternative 4 and the Project, it is assumed that the overall duration and intensity of construction under Alternative 4 would be similar to that of the Project.

Given that the on -site Project characte ristics would be essentially the same under both Alternative 4 and the Project, it can be concluded that impacts related to aesthetics, air quality, cultural resources, energy, geology and soils, GHG emissions, hazards and hazardous materials, hydrology an d water quality, land use and planning, public services, tribal cultural resources, and utilities and service systems would be similar to those of the Project and no further analysis is required. The proposed signal along Venice Boulevard would not materially impact the analysis and conclusions of these issue areas. However, the proposed signal would affect trip distribution and intersection volumes, which may impact noise and transportation impacts.
(i) Impact Summary
Alternative 4 proposes a similar development as the Project and, as such, would result in similar impacts as the Project including significant and unavoidable impacts with respect to on -site construction noise and on -site construction vibration (pursuant t o the threshold for human annoyance).
(ii) Finding
Alternative 4 would not avoid any of the Project’s significant and unavoidable impacts. The City finds, pursuant to PRC Code Section 21081(a)(3), that specific economic, legal, social, technological, or othe r considerations, including considerations identified in Section XIII of these findings (Statement of Overriding Considerations), make infeasible Alternative 4, as described in the Draft EIR.
(iii) Rationale for Findings
Alternative 4 would not eliminate the Project’s significant and unavoidable impacts with respect to on-site construction noise and on -site construction vibration (pursuant to the threshold for human annoyance). Alternative 4 includes the same building density and sf proposed under the Project wi th the addition of the installation of a traffic signal at the intersection of Venice Boulevard and the proposed driveway along Venice Boulevard. As Alternative 4 would be substantially similar to the Project, all Project Objectives would be met to the sa me degree as the Project.
(iv) Reference
Section 5, Alternatives, of the Draft EIR.

4. Project Alternatives Considered and Rejected
As set forth in CEQA Guidelines Section 15126.6(c), an EIR should identify any alternatives that were considered for analysis, but rejected as infeasible, and briefly explain the reasons for their rejection. According to the CEQA Guidelines, among the factors that may be used to eliminate an alternative from detailed consideration are the alternative’s failure to meet most of

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the basic project objectives, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts. Alternatives to the Project that were considered and rejected as infeasible include the following:

A. Alternative Off-Site Location
CEQA does not require that analysis of alternative sites always be included in an EIR.

However, if all the surrounding circumstances make it reasonable to consider an alternative site, then an alternative location should be considered and analyzed in the EIR. Per CEQA Guidelines Section 15126.6(f)(2), in making the decision to include or exclude analysis of an alternative site, the “key question and first step in analysis is whether any of the significant effects of the project would be av oided or substantially lessened by putting the project in another location. Only locations that would avoid or substantially lessen any of the significant effects of the project need to be considered for inclusion in the EIR.” If no feasible alternative locations exist, the EIR must disclose the reasons for this conclusion. According to CEQA Guidelines Sections 15126.6(f)(1) and (f)(2), among the factors that may be considered when addressing the feasibility of an alternative site are general suitability, economic viability, availability of infrastructure, general plan consistency, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site. The above is in light of the fact that, per CEQA Section 15126.6(a) , “An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project.”
The Project’s significant and unavoidable impacts, including construction -related Project-level and cumulative air quality emissions (as it relates to regional NOX emissions), Project-level and cumulative on-site construction noise, off-site construction noise (construction vehicles), and Project-level and cumulative off -site construction (human annoyance) vibration (construction vehicle) impacts would be expected to occur if the Project were developed at other available locations in the area as the emissions and noise generation would be similar to the Project and would impact potential nearby sensitive receptors similarly. Therefore, moving the location of the Project to another site would not necessarily reduce the nature and extent of such impacts.

Accordingly, given the nature of the Project’s significant unavoidable impacts, evaluation of an alternate location was not pursued as it would be likely to shift these impacts to another location rather than helping to avoid or substantially lessen the significant effects of the Project.

In addition to considering whether an alternative site would avoid or substantially lessen impacts, various factors may be considered when addressing the feasibility of an alternative site. Factors con sidered may include general suitability, economic viability, availability of infrastructure, general plan consistency, and whether the proponent can reasonably acquire, control, or otherwise have access to the alternative site.

The Project Site is located within a High Quality Transit Area (HQTA) and Transit Priority Area (TPA), and in close proximity to multiple transit options, including the Los Angeles County Metropolitan Transportation Authority (Metro) “E” Line Culver City Station, which is suitable for a high-density office project compared to a location that is not within a HQTA and TPA. An off-site location would likely not meet a key Project Objective to support City and regional goals and

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policies to reduce VMT and associated GHG and regional poll utant emissions by increasing employee density in close proximity to transit, including the “E” Line and numerous bus routes, to the same extent as the Project. While certain off-site locations may be in close proximity some transit options, the Project Site is directly across from the Metro “E” Line Culver City Station and as such, it is an ideal location for a high-density office project seeking to support City and regional goals and policies to reduce operational vehicle miles traveled (VMT) and associated GHG and regional pollutant emissions. Available building sites of a size to accommodate the scale and density of the Project within the HQTA and TPA are scarce.

In addition, the Applicant does not have ownership or control of any other suitable site w ith similar transit options, or the foreseeable ability to acquire an alternative site within a reasonable timeframe in the local project vicinity. Therefore, the flexibility to develop a similar project on the same or similar scale at another location in proximity to similar public transit is not feasible.

For the reasons stated above, an off -site location alternative is not expected to meaningfully reduce the significant and unavoidable impacts of the Project, would likely not meet a key Project objective to reduce VMT and GHG emissions, and a feasible alternate location for the Project has not been identified. Accordingly, an off-site alternative has not been carried forward for further analysis.

B. Alternatives to Eliminate Significant Noise and Vibration Impacts During Construction
The Project would result in significant and unavoidable impacts related to Project -level and cumulative on -site construction noise impacts, cumulative off -site construction noise (construction vehicles) impacts, and Project-level and cumulative off-site construction (human annoyance) vibration (construction vehicles). No additional mitigation measures are available to reduce these impacts to a less than significant level.

Alternatives, including those that would reduce construction duration or Project scale/intensity, were considered to substantially reduce or avoid these significant and unavoidable impacts.

Based on the thresholds upon which the construction noise and vibration analysis is based, a substantial reduction in the intensity of the peak construction activities would be necessary to reduce construction -related impacts to a less -than-significant level. In addition, significant construction noise and vibration impacts within the Project Site would be expected to occu r with most reduced development scenarios because construction activities are inherently disturbing, and the peak construction activity would be similar. Thus, reducing temporary construction noise and vibration impacts below a level of significance at ad jacent uses would not be feasible while still achieving the Project’s objectives. Furthermore, any reduction in the intensity of construction activities would increase the overall duration of the construction period.

Therefore, alternatives to eliminate the Project’s short-term noise and vibration impacts during construction were rejected as infeasible based on the inability to avoid significant environmental impacts under a reasonable construction schedule.

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C. Reduced Concrete Pour Alternative
Project construction activities would result in significant and unavoidable construction-related air quality impacts when construction activities overlap with operational activities. Also, the Project would result in short -term significant and unavoidable cumulative construction-related noise impacts. A large contributor to these impacts is the concrete trucks needed for building foundations. To construct portions of a building foundation, concrete must be continuously poured in a strategic manner over a short period of time considering its drying time and need to properly cure without cracking and provide proper building support. Breaking up the concrete pours for specific sections over multiple days in a given area is not a feasible option to properly construct a building foundation, as such breaks in the concrete pours would not provide a stable foundation built to applicable building code and regulatory requirements. Thus, reducing or eliminating the number of concrete trucks in a given construction phase is not a feasible alternative to reduce the Project’s significant and unavoidable Project -level and cumulative construction-related regional air quality impacts when construction activities overlap with operational activities and significant and unavoidable cumu lative construction-related noise impacts.

D. Residential/Mixed-Use Alternative
An alternative with residential uses only or a mixed-use alternative with some residential uses was considered for development on the Project Site. However, developing the Pro ject Site solely with residential uses or a mixed -use residential project would not meet the underlying purpose of the Project to provide a creative office campus for innovative entertainment, media, and/or technology companies. Furthermore, a residential use or a mixed -use residential project would not meet most of the Project’s basic objectives or would meet them to a lesser extent as the Project such as those focused on: supporting City and regional goals and policies to reduce VMT and associated GHG and regional pollutant emissions by increasing employee density in proximity to transit, including the “E” Line and numerous bus routes; providing high quality office space to attract and retain desirable innovative entertainment, media, and/or technology companies; strengthening the area’s economic vitality by attracting and retaining highly skilled workers; and generating additional revenues in the form of increased property and business license taxes, as well as increased sales taxes from increased economic activity from the additional jobs. Additionally, a residential -only or mixed -use residential alternative would, similar to the Project, result in construction-related significant and unavoidable impacts associated with construction air quality and noise. Accordingly, a residential only or mixed-use residential alternative has not been carried forward for further analysis.

5. Environmentally Superior Alternative
Section 15126.6(e)(2) of the CEQA Guidelines indicates that an analysis of alternatives to a project shall identify an Environmentally Superior Alternative among the alternatives evaluated in an EIR. The CEQA Guidelines also state that should it be determined that the No Project Alternative is the Environmentally Superior Altern ative, the EIR shall identify another Environmentally Superior Alternative among the remaining alternatives.

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The comparative impacts of the Project and the Project alternatives are summarized in Table 5-2, Comparison of the Impacts of the Project and Alternatives in the Draft EIR. Of the alternatives analyzed in the Draft EIR, Alternative 1, the No Project/No Build Alternative, would be considered the environmentally superior because it would not involve new development and assumes on -site uses would continue to operate similar to existing conditions, with the exception of the vacant areas on the Project Site, which are assumed to continue to be vacant.

Alternative 1 would not meet most of the Project Objectives, would only partially meet three of the Project Objectives, and would avoid all of the Project’s potentially significant impacts and would have reduced impacts compared to the Project. However, because Alternative 1 has been identified as the environmentally superior alternative, identificatio n of another environmentally superior alternative is required.

Alternative 2, the Zoning -Compliant Alternative, and Alternative 3, the Reduced Project Alternative, would both involve less development compared to the Project, and both alternatives would red uce, but not eliminate, the Project’s significant unavoidable impacts related to Project -level and cumulative regional air quality emissions, Project -level and cumulative on -site construction noise, cumulative off -site construction noise (construction vehicles), and Project-level and cumulative off-site construction (human annoyance) vibration (construction vehicles) impacts. In addition, Alternative 4, Alternate Project Access Alternative, proposes a similar development as the Project and, as such, would results in similar significant and unavoidable impacts. However, Alternative 3 is considered the environmentally superior alternative, as it would reduce the magnitude of overall impacts compared to the Project to a greater extent than Alternative 2 as it would require less building construction and shortened building height for Building 2.

However, because Alternative 3 would develop a smaller office development, the number of employees would be reduced. As such, Alternative 3 would meet to a lesser extent than the Project the Project Objectives related to increasing employee density in proximity to transit; providing a high -quality office space to attract and retain desirable innovative companies; strengthening the area’s economic vitality by attracting and retaining highly skilled workers; and increased sales taxes from increased economic activity from the additional jobs.

X. Significant Irreversible Environmental Changes
Section 15126.2(c) of the CEQA Guidelines indicates that an EIR should evaluate any significant irreversible environmental changes that would occur should the proposed project be implemented. The types and level of development associated with the Project would consume limited, slowly renewable, and non -renewable resources. This consumption would occur during construction of the Project and would continue throughout its operational lifetime.

Project development would require a commitment of resources that would include: (1) building materials; and (2) energy resources (e.g., fossil fuels) fo r electricity, natural gas, and transportation.

Project construction would require the consumption of resources that are non-replenishable or may renew so slowly as to be considered non-renewable. These resources would include the following construction s upplies: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel and stone; metals such as steel,

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copper, and lead; petrochemical construction materials such as plastics; and water.

Furthermore, nonrenewable fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment. Project operation would continue to expend nonrenewable resources that are currently consumed within the City (i.e., electricity and natural gas, petroleum-based fuels required for vehicle-trips, fossil fuels, and water). Fossil fuels would represent the primary energy source associated with both construction and ongoing operation of the Project, and the existing, finite supplies of these natural resources would be incrementally reduced.

The analysis of Project impacts on energy in Section 4.4, Energy, of the Draft EIR, provides a discussion of State efforts to reduce emissions and energy consumption, which also requires concurrent reductions in the consumption of non -renewable resources. As analyzed therein, the Project would result in a less -than-significant energy impacts due to wasteful, inefficient, and unnecessary consumption of energy resources during construction or oper ation. The Project’s energy requirements would not significantly affect local and regional supplies or capacity. The Project’s electricity and natural gas usage would be consistent with future usage projections for the region. Electricity generation cap acity and supplies of natural gas as well as transportation fuels would be sufficient to meet the needs of the Project construction and operational activities. Construction of the Project would utilize fuel -efficient trucks and equipment consistent with federal and State regulations, such as fuel efficiency regulations in accordance with CARB’s Pavley Phase I and II standards (at a minimum through the model year 2020 standards depending on the outcome of the SAFE Vehicles Rule court challenge), the anti-idling regulation in accordance with CCR, Title 13, Section 2485, and fuel requirements in accordance with CCR, Title 17, Section 93115, as well as the In-Use Off-Road Diesel-Fueled Fleets regulation. The Project would also comply with Title 24 standards an d applicable CALGreen Building Code requirements.

In addition, the Project would be consistent with the State’s Assembly Bill (AB) 32 GHG reduction target and would result in a less -than-significant impact with respect to consistency with applicable plans, policies, or regulations to reduce GHG emissions. The Project would not conflict with applicable strategies outlined in CARB’s Climate Change Scoping Plan, SCAG’s 2020–2045 RTP/SCS, Culver City’s Green Building Program and City of Los Angeles Green Building Code, L.A.’s Green New Deal/Sustainability pLAn 2019, and the City’s Green Building Code.

Continued use of such non -renewable resources would be on a relatively small scale and consistent with regional and local growth forecasts in the area, as well as State and local goals for reductions in the consumption of such resources. Furthermore, the Project would not affect access to existing resources, nor interfere with the production or delivery of such resources.

The Project Site contains no energy resources that would be precluded from future use through Project implementation. The Project’s irreversible changes to the environment related to the consumption of nonrenewable resources would not be significant.

XI. Growth Inducing Impacts
Section 15126.2(d) o f the CEQA Guidelines requires a discussion of the ways in which a proposed project could induce growth. This includes ways in which a project would foster

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economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment.

The Project would include up to 536,000 sf of new floor area, including Building 1, which would include 167,000 sf of office uses and Building 2, which would include 369,000 sf of office uses.

The Project would not include any new residential development, and, thus, would not generate a direct increase in residential population. However, the Project would have the potential to generate indirect population growth in the Project vicinity, as a result of the new employ ees generated by the Project.

During construction, the number of employees is estimated to vary on a day-to-day basis over the course of Project construction. However, the work requirements of most construction projects are highly specialized such that construction workers remain at a job site for the time in which their specific skills are needed to complete a particular phase of the construction process. Thus, Project-related construction workers would not be anticipated to relocate their household’s place of residence as a consequence of working on the Project. Therefore, given the availability of construction workers, the Project would not be considered growth inducing from a short -term employment perspective, but rather, the Project would provide a p ublic benefit by providing new employment opportunities during the construction period.

Development of the Project would generate an increase of 2,400 employees. The estimate of up to 2,400 new employees generated by the Project would be within SCAG’s emp loyment growth assumptions for both the City of Culver City and City of Los Angeles. While the Project could result in indirect population growth associated with employees moving to the Project area, any such growth would represent a fraction of Culver Ci ty’s and Los Angeles’ projected household growth by SCAG, well within their projected growth for each City. Furthermore, the Project would not have indirect effects on growth through such mechanisms as the extension of roads and infrastructure, because th e Project would utilize the existing transportation and utility infrastructure to serve the Project. The Project would include office uses that would be compatible with adjacent uses and would not increase or induce residential density growth on the Project Site. The Project’s only off-site infrastructure improvements would consist of tie-ins to the existing utility main-lines already serving the Project area. The Project would not require the construction of off -site infrastructure that would provide add itional infrastructure capacity for other future development. It would not open inaccessible sites to new development other than existing opportunities for development that are already available.

Therefore, the Project would not spur additional growth other than that already anticipated and would not eliminate impediments to growth. Consequently, the Project would not foster growth inducing impacts.

XIII. STATEMENT OF OVERRIDING CONSIDERATIONS
The EIR identifies unavoidable significant impacts that would result from implementation of the project. PRC Section 21081 and Section 15093(b) of the CEQA Guidelines provide that when a decision of a public agency allows the occurrence of significant impacts that are identified in the EIR, but are not at least subst antially mitigated to an insignificant level or eliminated, the lead agency must state in writing the reasons to support its action based on the EIR and/or

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other information in the record. The CEQA Guidelines require, pursuant to CEQA Guidelines Section 15093(b), that the decision-maker adopt a Statement of Overriding Considerations at the time of approval of a project, if it finds that significant adverse environmental effects have been identified in the EIR that cannot be substantially mitigated to an in significant level or be eliminated. These findings and the Statement of Overriding Considerations are based on the documents and materials that constitute the record of proceedings, including, but not limited to, the Draft EIR, Final EIR, and all technical appendices attached thereto.

Based on the analysis provided in Section 4, Environmental Impact Analysis, of the Draft EIR, implementation of the Project would result in significant impacts that cannot be feasibly mitigated with respect to construction ai r quality, onsite construction noise and offsite construction vibration and cumulative construction air quality, cumulative on -site and offsite construction noise, and cumulative offsite construction vibration.

Accordingly, the City adopts the following St atement of Overriding Considerations. The City recognizes that significant and unavoidable impacts would result from implementation of the Project. Having (i) adopted all feasible mitigation measures, (ii) rejected as infeasible the alternatives to the P roject, (iii) recognized all significant, unavoidable impacts, and (iv) balanced the benefits of the Project against the Project’s significant and unavoidable impacts, the City hereby finds that each of the Project’s benefits, as listed below, outweigh and override all the significant unavoidable impacts.

The below stated reasons summarize the benefits, goals, and objectives of the Project, and provide the detailed rationale for the benefits of the Project. These overriding considerations of economic, social, aesthetic, and environmental benefits for the Project justify adoption of the Project and certification of the completed EIR. Each of the listed Project benefits set forth in this Statement of Overriding Considerations provides a separate and independ ent ground for the City's decision to approve the project despite the Project's identified significant and unavoidable environmental impacts. Each of the following overriding consideration separately and independently (i) outweighs the adverse environment al impacts of the Project, and (ii) justifies adoption of the Project and certification of the completed EIR. In particular, achieving the underlying purpose for the Project would be sufficient to override the significant environmental impacts of the Project.
• The Project will develop a new infill creative office project in close proximity to the transit, including the Metro "E" Line and numerous bus routes, consistent with local and regional goals and polices to reduce vehicle miles traveled and associated greenhouse gas and regional pollutant emissions.
• The Project will incorporate sidewalk and landscape improvements on National and Venice Boulevards that will promote pedestrian access between residential neighborhoods and the Metro Expo “E” Line Culver City Station within the Ivy Station development to the west of National Boulevard.
• The Project will improve the visual character and pedestrian environment along of the Project Site and advance the local and regional transit-oriented development policies by replacing an underutilized site with new, well-designed buildings.

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• The Project will include 7,120 square feet of publicly accessible, privately maintained amenity area for use by the community.
• The Project will be designed to achieve LEED Gold equ ivalent and will incorporate numerous sustainability features that will reduce energy and water usage and waste and, thereby, reduce associated greenhouse gas emissions and help minimize the impact on natural resources and infrastructure.
• The Project will provide modern, high-quality office space to attract and retain desirable innovative entertainment, media, and/or technology companies. • The Project will create over 400 construction jobs and 2,400 jobs during operation. • The Project will result in new business license, sales, and property tax revenues to the City.

XII. GENERAL FINDINGS

1. The City, acting through the Current Planning Division, is the “Lead Agency” for the Project that is evaluated in the EIR. The City finds that the EIR was prepared in compl iance with CEQA and the CEQA Guidelines. The City finds that it has independently reviewed and analyzed the EIR for the Project, that the Draft EIR, which was circulated for public review, reflected its independent judgment, and that the Final EIR reflect s the independent judgment of the City.

2. The EIR evaluated the following potential project and cumulative environmental impacts: Air Quality; Cultural Resources; Energy; Geology; Greenhouse Gas Emissions; Hazards and Hazardous Materials; Hydrology; Land Use; Noise; Public Services; Transportation; Tribal Cultural Resources; and Utilities. Additionally, the EIR considered Growth Inducing Impacts and Significant Irreversible Environmental Changes. The significant environmental impacts of the Project and the alternatives were identified in the EIR.

3. The City finds that the EIR provides objective information to assist the decision - makers and the public at large in their consideration of the environmental consequences of the Project. The public review p eriod provided all interested jurisdictions, agencies, private organizations, and individuals the opportunity to submit comments regarding the Draft EIR. The Final EIR was prepared after the review period and responds to comments made during the public review period.

4. Textual refinements were compiled and presented to the decision-makers for review and consideration. The City staff has made every effort to notify the decision -makers and the interested public/agencies of each textual change in the variou s documents associated with Project review. These textual refinements arose for a variety of reasons. First, it is inevitable that draft documents would contain errors and would require clarifications and corrections.

Second, textual clarifications were necessitated to describe refinements suggested as part of the public participation process.

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5. The Current Planning Division evaluated comments on environmental issues received from persons who reviewed the Draft EIR. In accordance with CEQA, the Planning Division prepared written responses describing the disposition of significant environmental issues raised. The Final EIR provides adequate, good faith and reasoned response to the comments. The Current Planning Division reviewed the comments received and responses thereto and has determined that neither the comments received nor the responses to such comments add significant new information regarding environmental impacts to the Draft EIR.

The Lead Agency has based its actions on full appraisal of all viewpoints, including all comments received up to the date of adoption of these findings, concerning the environmental impacts identified and analyzed in the EIR.

6. The Final EIR documents changes to the Draft EIR. The Final EIR provides additional information that was not included in the Draft EIR. Having reviewed the information contained in the Draft EIR and the Final EIR and in the administrative record, as well as the requirements of CEQA and the CEQA Guidelines regarding recirculation of Draft EIRs, the City finds that there are no new significant impacts, substantial increase in the severit y of a previously disclosed impact, significant information in the record of proceedings, or other criteria under CEQA that would require recirculation of the Draft EIR, or preparation of a supplemental or subsequent EIR.

7. The Responses to Comments cont ained in the Final EIR fully considered and responded to comments claiming that the Project would have significant impacts or more severe impacts not disclosed in the Draft EIR and include substantial evidence that none of these comments provided substanti al evidence that the Project would result in changed circumstances, significant new information, considerably different mitigation measures, or new or more severe significant impacts than were discussed in the Draft EIR. Specifically, the City finds that:
a. The City has thoroughly reviewed the public comments received regarding the Project and the Final EIR, as it relates to the Project, to determine whether under the requirements of CEQA, any of the public comments provide substantial evidence that woul d require recirculation of the EIR prior to its adoption and has determined that recirculation of the EIR is not required.
b. None of the information submitted after publication of the Final EIR, including testimony at and documents submitted for the publ ic hearings on the Project, constitutes significant new information or otherwise requires preparation of a supplemental or subsequent EIR. The City does not find this information and testimony to be credible evidence of a significant impact, a substantial increase in the severity of an impact disclosed in the Final EIR, or a feasible mitigation measure or alternative not included in the Final EIR. c. The mitigation measures identified for the Project were included in the Draft and Final EIRs. As revised , the final mitigation measures for the Project are described in the Mitigation Monitoring Program (MMP). Each of the mitigation measures identified in the MMP is incorporated into the Project. The City finds that the impacts of the Project have been mitigated to less than significant by the feasible mitigation measures identified in the MMP.

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8. CEQA requires the Lead Agency approving a project to adopt an MMP or the changes to the project which it has adopted or made a condition of project approval to en sure compliance with the mitigation measures during project implementation. The mitigation measures included in the EIR as certified by the City serve that function. The MMP includes all the mitigation measures and project design features adopted by the City in connection with the approval of the Project and has been designed to ensure compliance with such measures during implementation of the Project. In accordance with CEQA, the MMP provides the means to ensure that the mitigation measures are fully en forceable. In accordance with the requirements of PRC Section 21081.6, the City hereby adopts the MMP.

9. In accordance with the requirements of PRC Section 21081.6, the City hereby adopts each of the mitigation measures expressly set forth herein as conditions of approval for the Project.

10. The custodian of the documents or other material which constitute the record of proceedings upon which the City’s decision is based is the Current Planning Division, located at Culver City Hall, 9770 Culver Boulevard, 2nd Floor, Culver City, CA 90232.

11. The City finds and declares that substantial evidence for each and every finding made herein is contained in the EIR, which is incorporated herein by this reference, or is in the record of proceedings in the matter.

12. The City is certifying an EIR for, and is approving and adopting findings for, the entirety of the actions described in these Findings and in the EIR as comprising the Project.

13. The EIR is a project EIR for purposes of environmental analysis of the Project. A project EIR examines the environmental effects of a specific project. The EIR serves as the primary environmental compliance document for entitlement decisions regarding the Project by the City and other regulatory jurisdictions.

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EXHIBIT B

MITIGATION MONITORING PROGRAM

This Mitigation Monitoring Program (MMP), which is provided in Table 4 -1, Mitigation Monitoring Program , below, has been prepared pursuant to Public Resources Code (PRC) Section 21081.6 and CEQA Guidelines Section 15097 (Title 14 of the California Code of Regulations), which require adoption of an MMP for projects where the Lead Agency has adopted mitigation to avoi d significant environmental effects. The City of Culver City (City) is the Lead Agency for the Crossings Campus Project (Project). However, the Project Site includes area within both the City of Culver City and the City of Los Angeles. Therefore, as applicable, the City of Culver City and the City of Los Angeles will be responsible for administering and implementing the MMP. The decision-makers must define specific reporting and/or monitoring requirements to be enforced during Project implementation prior to final approval of the Project. The primary purpose of the MMP is to ensure that the mitigation measures identified in the Initial Study (for Biological Resources), Draft EIR, and Final EIR (designated by the respective environmental issue within Chapte r 4, Environmental Impact Analysis, of the Draft EIR) are implemented, thereby minimizing identified environmental effects.

The MMP also includes project design features identified throughout Chapter 4 the Draft EIR.

Because project design features have been incorporated into the Project, they do not constitute mitigation measures. However, project design features are included in this MMP to ensure their implementation as a part of the Project.

Final clearance shall require all applicable verification as indicated in Table 4 -1. The City of Culver City and City of Los Angeles will have responsibility for monitoring and reporting the implementation of the project design features and mitigation measures, as applicable, within their respective jurisdictions. The project design features and mitigation measures are identified by the impact category and numbered that correspond with the Initial Study, in the case of Biological Resources and the Draft EIR.

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EXHIBIT B
Mitigation Monitoring Program

FINAL EIR - TABLE 4-1

Project Design Feature (PDF)
/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
Aesthetics
AES-PDF-1: Construction
Fencing. Temporary
construction fencing will be
placed along the periphery of
the Project Site to screen
construction activity for new
buildings from view at the street
level. A minimum eight -foot-
high construction fence will be
located along the perimeter of
the active construction sites.

The Project Applicant will
ensure through appropriate
postings and daily visual
inspections that no
unauthorized materials are
posted on any temporary
construction barriers or
temporary pedestrian walkways
that are accessible/visible to the
public and that such temporary
barriers and walkways are
maintained in a visually
attractive manner (i.e., free of
trash, graffiti, peeling postings
and of uniform paint color or
graphic treatment) throughout
the construction period.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Demolition
Permit,
Grading
Permit, and
Ongoing during
Construction
Culver City Public
Works,
Engineering, and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
AES-PDF-2: Screening of
Utilities. Mechanical, electrical,
and roof top equipment
(including Heating, Ventilation,
and Air Conditioning [HVAC]
systems), as well as building
appurtenances (such as rooftop
elevator stops), will be
integrated into the Project’s
architectural design (e.g.,
placed behind parapet walls)
Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Certificate of
Occupancy
Culver City Public
Works,
Engineering, and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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AES-PDF-3: Glare. Glass
used in building façades will be
anti-reflective or treated with an
anti-reflective coating in order to
minimize glare (e.g., minimize
the use of glass with mirror
coatings). Final glazing choices
and trim materials will be
evaluated for glare prior to the
issuance of a building permit.

Construction and operational
lighting will be shielded and
directed downward (or on the
specific on-site feature to be lit)
in such a manner so as to avoid
undue glare or light trespass
onto adjacent or nearby uses.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Certificate of
Occupancy
Culver City Public
Works,
Engineering, and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
Air Quality
AQ-MM-1: Construction
Equipment Features. The
Project shall implement the
following construction
equipment features for
equipment operating at the
Project Site. These features
shall be included in applicable
bid documents, and successful
contractor(s) must demonstrate
the ability to supply such
equipment. Construction
features shall include the
following:
• During plan check, the
Project’s representative
shall make available to
the lead agency and
South Coast Air Quality
Management District
(SCAQMD) a
comprehensive inventory
of all off-road construction
equipment, equal to or
greater than 50
Condition of
Approval
Plan Check
Notes,
Reports,
and Field
Inspections
Prior to
issuance of a
Demolition
Permit,
Grading
Permit, and
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety

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/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
horsepower, that shall be
used during any of the
construction phases. The
inventory shall include the
horsepower rating,
engine production year,
and certification of the
specified Tier standard. A
copy of each such unit’s
certified tier specification,
best available control
technology (BACT)
documentation, and
CARB or SCAQMD
operating permit shall be
maintained on-site at the
time of mobilization of
each applicable unit of
equipment. Off-road
diesel-powered
equipment equal to or
greater than 50
horsepower that will be
used during any portion
of the construction
activities shall meet or
exceed the Tier 4 Final
standards. Such
equipment will be
outfitted with Best
Available Control
Technology (BACT)
devices, including a
CARB-certified Level 3
Diesel Particulate Filter or
equivalent. Alternate
construction equipment
may be used if the
construction contractor
can document that the
equipment would achieve
the same or greater NOx
reductions compared to
Tier 4 Final standards.

Construction contractors
supplying heavy duty
diesel equipment greater
than 50 horsepower shall
be encouraged to apply
for SCAQMD SOON

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/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
funds. Information
including the SCAQMD
website shall be provided
to each contractor which
uses heavy duty diesel
for on-site construction
activities
• During demolition, site
preparation, and grading
and excavation activities,
the contractor shall
provide notification and
documentation that haul
truck drivers have
received training
regarding idling limitations
specified in Title 13
California Code of
Regulations, Section
2485. During
construction, trucks and
vehicles in loading and
unloading queues shall
have their engines turned
off after 5 minutes when
not in use, to reduce
vehicle emissions
• Contractors shall
maintain and operate
construction equipment
so as to minimize exhaust
emissions. All
construction equipment
must be properly tuned
and maintained in
accordance with the
manufacturer’s
specifications. The
contractor shall keep
documentation on-site
demonstrating that the
equipment has been
maintained in accordance
with the manufacturer’s
specifications. Tampering
with construction
equipment to increase
horsepower or to defeat
emission control devices
shall be prohibited.

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/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
• Construction activities
shall be discontinued
during an Air Quality
Index (AQI) of 151 or
more (unhealthy level). A
record of any AQI at an
unhealthy level and of
discontinued construction
activities as applicable
shall be maintained by
the Contractor on-site.

Biological Resources
MM-BIO-1: The Applicant shall
be responsible for the
implementation of mitigation to
reduce impacts to migratory
and/or nesting bird species to
below a level of significance
through one of two ways. Either:
1) Vegetation removal
activities shall be scheduled
outside the nesting season
(September 1 to February
14 for songbirds;
September 1 to January 14
for raptors) to avoid
potential impacts to nesting
birds. This would ensure
that no active nests are
disturbed; or
2) If avoidance of the avian
breeding season (February
15 to August 31 for
songbirds; January 15 to
August 31 for raptors) is not
feasible, then:
a. A qualified biologist
shall conduct a
preconstruction nesting
bird survey within 15
days and again within
72 hours prior to any
ground disturbing
activities (staging ,
grading, vegetation
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys,
and Field
Inspections
Prior to
issuance of a
Demolition
Permit,
Grading
Permit, and
Building
Permit.

Culver City
Planning Division;
Los Angeles
Department of
Building and
Safety and City
Planning

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/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
removal or clearing,
grubbing, etc.). The
survey shall be
conducted to ensure
that impacts to birds,
including raptors,
protected by the MBTA
and/or the California
Fish and Game Code
are avoided. Survey
areas shall include
suitable ne sting habitat
within 200 feet (or up to
300 feet, depending on
topography or other
factors, and 500 feet for
raptors) of construction
site boundaries. This
two-tiered survey
method is intended to
provide the Applicant
with time to understand
the potential issue and
evaluate solutions if
nests are present, prior
to mobilizing
resources. If active
nests are not identified,
no further action is
necessary.
b. If active nests are
identified during pre -
construction surveys,
an avoidance buffer
shall be demarcated for
avoidance using
flagging, staking,
fencing, or another
appropriate barrier to
delineate construction
avoidance until the nest
is determined to no
longer be active by a
qualified biologist (i.e.,
young have fledged or

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Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
no longer alive within
the nest). An active nest
is defined as a structure
or site under
construction or
preparation,
constructed or
prepared, or being used
by a bird for the
purpose of incubating
eggs or rearing young.

Perching sites and
screening vegetation
are not part of the nest.

Given t he high
disturbance level,
general avoidance
buffers include a
minimum 100 -foot
avoidance (for smaller
birds more tolerant of
human disturbance) to a
250-foot avoidance
buffer for passerine and
a 500 -foot avoidance
buffer from active
raptor nests, or reduced
buffer distances
determined at the
discretion of a qualified
biologist familiar with
local nesting birds and
breeding bird behavior
within the Project area.

Construction personnel
shall be informed of the
active nest and
avoidance
requirements. A
biological monitor shall
review the site, at a
minimum of one -week
intervals, during all
construction activities
occurring near active

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Action,
Condition, or
Mechanism
Method of
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Timing of
Verification
Responsible
Persons
nests to ensure that no
inadvertent impacts to
active nests occur. Pre -
construction nesting
bird surveys and
monitoring results shall
be submitted to the
Culver City Planning
Division and City of
Los Angeles Planning
Division via email or
memorandum upon
completion of the pre -
construction surveys
and/or construction
monitoring to
document compliance
with applicable state
and feder al laws
pertaining to the
protection of native
birds. In addition, pre -
construction surveys
and/or construction
monitoring shall also be
submitted to the
California Department
of Fish and Wildlife
(CDFW) within two
months of the
completion of the
monitoring activities.

Cultural Resources
CUL-MM-1: Prior to the
issuance of a demolition permit,
the Applicant shall retain an
archaeologist who meets the
Secretary of the Interior’s
Professional Qualifications
Standards for Archaeology
(Qualified Archaeologist) to
oversee an archaeological
monitor who sha ll be present
during initial Project
construction work such as
demolition, clearing/grubbing,
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys and
Field
Inspections
Prior to
issuance of
Demolition
Permit and
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety, and City
Planning

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/ Mitigation Measure (MM)
Implementing
Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
grading, trenching, or related
moving of soils within the
Project Site (collectively,
ground disturbing activities);
provided, however, that ground
disturbing act ivities shall not
include any moving of soils after
they have been initially
disturbed or displaced by
Project-related construction.

The Qualified Archaeologist
shall determine the frequency of
monitoring based on the rate of
excavation and grading
activities, proximity to known
archaeological resources, the
materials being excavated
(younger alluvium vs. older
alluvium), and the depth of
excavation, and if found, the
abundance and type of
archaeological resources
encountered. The frequency of
monitoring ca n be reduced to
part-time inspections or ceased
entirely if determined
appropriate by the Qualified
Archaeologist.

Prior to commencement of
excavation activities, an
Archaeological and Cultural
Resources Sensitivity Training
shall be given for construction
personnel. The training session
shall be carried out by the
Qualified Archaeologist and
shall focus on how to identify
archaeological resources that
may be encountered during
earthmoving activities and the
procedures to be followed in
such an event.

CUL-MM-2: In the event that
historic or prehistoric
archaeological resources (e.g.,
bottles, foundations, refuse
dumps, etc.) are unearthed,
ground-disturbing activities
shall be halted or diverted away
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys and
Field
Inspections
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;

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After consulting with the
Applicant, the Qualified
Archeologist shall establish an
appropriate buffer area in
accordance with industry
standards, reasonable
assumptions regarding the
potential for additional
discoveries in the vicinity, and
safety consid erations for those
making an evaluation and
potential recovery of the
discovery. This buffer area shall
be established around the find
where construction activities
shall not be allowed to continue.

Work shall be allowed to
continue outside of the buffer
area. All archaeological
resources unearthed by Project
construction activities shall be
evaluated by the Qualified
Archaeologist. If the Qualified
Archaeologist determines the
find to constitute a “historical
resource” pursuant to CEQA
Guidelines Section 15064.5(a)
or a “unique archaeological
resource” pursuant to Public
Resources Code Section
21083.2(g), the Qualified
Archaeologist shall coordinate
with the Applicant and the City
of Culver City and/or City of Los
Angeles depending on the
location/jurisdiction where the
resource is located to develop a
reasonable and feasible
treatment plan that would serve
to reduce impacts to the
resources. The treatment plan
established for the resources
shall be in accordance with
CEQA Guidelines Section
15064.5(f) for historical
resources and Public
Resources Code Sections
21083.2(b) for unique
Los Angeles
Departments of
Building and
Safety and City
Planning

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Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
archaeological resources. The
treatment plan shall include
measures regarding the
curation of the recovered
resources that may include
curation at a public, non -profit
institution with a research
interest in the materials, such
as the Natural History Museum
of Los Angeles County or the
Fowler Museum, if such an
institution agrees to accept the
material. If no institution
accepts the resources, they
may be donated to a local
school or historical society in
the area (such as the Culver
City Historical Society) for
educational purposes.

All archaeological resources
unearthed by Project
construction activities shall be
evaluated by the Qualified
Archaeologist. If the Qualified
Archaeologist determines the
find to constitute a “historical
resource” pursuant to CEQA
Guidelines Section 15064.5(a)
or a “unique archaeological
resource” pursuant to Public
Resources Code Section
21083.2(g), the Qualified
Archaeologist shall coordinate
with the Applicant and the City
of Culver City and/or City of Los
Angeles, depending on the
location/jurisdiction where the
resource is located, to develop
a reasonable and feasible
treatment plan that would serve
to reduce impacts to the
resource(s). The treatment plan
established for the resources
shall be in accordance with
CEQA Guidelines Section
15064.5(f) for historical
resources and Public
Resources Code Sections
21083.2(b) for unique

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/ Mitigation Measure (MM)
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Action,
Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
archaeological resources. The
treatment plan shall include
measures rega rding the
curation of the recovered
resources that may include
curation at a public, non -profit
institution with a research
interest in the materials, such
as the Natural History Museum
of Los Angeles County or the
Fowler Museum, if such an
institution agrees to accept the
material. If no institution
accepts the resources, they
may be donated to a local
school or historical society in
the area (such as the Culver
City Historical Society) for
educational purposes.

After making a reasonable effort
to mediate this particular
dispute, the City may: (1)
require the recommendation be
implemented as originally
proposed by the Qualified
Archaeologist; (2) require the
recommendation, as modified
by the City, be implemented in a
manner that is at least as

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equally effective to mitigate a
potentially significant impact;
(3) require a substitute
recommendation be
implemented that is at least as
equally effective to mitigate a
potentially significant impact; or
(4) not r equire the
recommendation be
implemented because it is not
necessary to mitigate any
significant impacts. The
Applicant shall pay all costs and
fees associated with the
mediator.

Condition of
Approval
Report Prior to
issuance of a
Certificate of
Occupancy
Culver City
Planning Division,
Los Angeles
Departments of
Building and
Safety and City
Planning
Geology and Soils
GEO-MM-1: Prior to the
issuance of grading permits, the
Condition of
Approval
Plan Check
Notes,
Prior to
issuance of
Culver City
Building Safety

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Responsible
Persons
Applicant shall retain a qualified
paleontologist meeting the
Society of Vertebrate
Paleontology (SVP) Standards
(Qualified Paleontologist). The
Qualified Paleontologist shall
provide technical and
compliance oversight of all work
as it relates to paleontological
resources, shall attend the
Project kick -off meeting, and
Project progress meetings, and
shall be responsible for
monitoring and overseeing
paleontological monitors
(meeting SV P standards) that
will observe grading and
excavation activities.

Reports,
Surveys and
Field
Inspections
Grading Permit
and Ongoing
during
Construction
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
GEO-MM-2: Paleontological
monitoring shall be conducted
during construction excavations
into undisturbed older alluvial
sediments that exceed 10 feet
in depth. Monitoring shall
consist of visually inspecting
fresh exposures of rock for
larger fossil remains and, where
appropriate, collecting and wet
screening sediment samples of
promising horizons for smaller
fossil remains. If significant
vertebrate fossils are found by
screening, it will be necessary
to collect a 6,000-pound sample
for screening, per SVP
Guidelines (2010). The sample
can be collected by construction
machinery and stockpiled and
processed in a safe location on-
site, or transported to another
site for processing. The
frequency of monitoring
inspections shall be determined
by the Qualified Paleontolog ist
and shall be based on the rate
of excavation and grading
activities, the materials being
excavated, and the depth of
excavation, and if found, the
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys and
Field
Inspections
Prior to issuant
of Demolition
Permit,
Grading Permit
and Building
Permit and
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety City
Planning

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Responsible
Persons
abundance and type of fossils
encountered. Full -time
monitoring can be reduced to
part-time inspections, or ceased
entirely, if determined adequate
by the Qualified Paleontologist.

If a potential fossil is found, the
Qualified Paleontologist shall
have authority to temporarily
stop excavation activity or to
temporarily divert or redirect
grading and excavatio n
activities in the area of the
exposed fossil to facilitate
evaluation of the discovery. An
appropriate buffer area shall be
established by the Qualified
Paleontologist around the find
where construction activities
shall not be allowed to continue.

Work s hall be allowed to
continue outside of the buffer
area. At the Qualified
Paleontologist’s discretion, and
to reduce any construction
delay, the grading and
excavation contractor shall
assist in removing
rock/sediment samples for
initial processing and
evaluation. If preservation in
place is not feasible, the
Qualified Paleontologist shall
implement a paleontological
salvage program to remove the
resources from their location.

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repository. The Qualified
Paleontologist shall prepare a
final report summarizing the
results of the monitoring and
salvaging efforts, the
methodology used in these
efforts, as well as a description
of the fossils collected and their
significance. The report shall
accompany the specimens to
the accredited repository. The
report shall also be submitted
by the Applicant to the City of
Culver City and/or City of Los
Angeles, depending on the
location/jurisdiction where the
resource is located, to signify
the satisfactory completion of
the Project and required
mitigation measures.

Greenhouse Gas Emissions
GHG-PDF-1: Green Building
Features. The Project will
include the following green
building features:
• The Project buildings will be
designed to meet the
United States Green
Building Council (USGBC)
Leadership in Energy and
Environmental Design
(LEED) Gold Certification
and will be designed and
operated to meet or exceed
the applicable requirements
of the State of California
Green Building Standards
Code, the City of Los
Angeles Green Building
Code and Culver City’s
Green Building Program
Requirements.
• The Project design will
include sustainability
features that will result in
increased energy efficiency
including water efficiency
measures for landscaping
Condition of
Approval
Plan Check
Notes
Prior to
issuance of a
Building Permit
Culver City
Building Safety
Division, Planning
Division; Los
Angeles
Departments of
Building and
Safety and City
Planning

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and rainwater
management, high
efficiency plumbing fixtures,
energy-star labeled
appliances where possible
and energy-efficient and
water conserving HVAC
systems.

Hazards and Hazardous Materials
HAZ-MM-1: Health and Safety
Plan. Before the start of
ground-disturbing activities,
including grading, trenching, or
excavation, or structure
demolition on parcels within the
Project Site, the Applicant for
the specific work proposed shall
require that the construction
contractor(s) retai n a qualified
professional to prepare a site -
specific health and safety plan
(HASP) in accordance with
federal Occupational Safety
and Health Administration
regulations (29 CFR 1910.120)
and California Occupational
Safety and Health
Administration regulati ons (8
CCR Section 5192).

The HASP shall be
implemented by the
construction contractor to
protect construction workers,
the public, and the environment
during all ground-disturbing and
structure demolition activities.

HASPs shall be submitted to
Culver City and the City of Los
Angeles building departments
and any applicable oversight
regulatory agency for review
before the start of demolition
and construction activities and
as a condition of the grading,
construction, and/or demolition
permit(s). The HASP s hall
include, but not be limited to, the
following elements:

Condition of
Approval
Plan Check
Notes, Field
Inspections
Prior to
issuance of a
Demolition or
Grading
Permit;
Construction
(during soil-
disturbing
activities)
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Building and
Safety Department

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• Designation of a trained,
experienced site safety
and health supervisor
who has the responsibility
and authority to develop
and implement the site
HASP.
• A summary of all potential
risks to demolition and
construction workers and
maximum exposure limits
for all known and
reasonably foreseeable
site chemicals.
• Specified personal
protective equipment and
decontamination
procedures, if needed.
• The requirement to
prepare documentation
showing that HASP
measures have been
implemented during
construction (e.g., tailgate
safety meeting notes with
signup sheet for
attendees).
• A requirement specifying
that any site worker who
identifies hazardous
materials has the
authority to stop work and
notify the site safety and
health supervisor.
• Emergency procedures,
including the route to the
nearest hospital.
• Procedures to follow if
evidence of potential soil
or groundwater
contamination is
encountered (such as soil
staining, noxious odors,
debris or buried storage
containers). These
procedures shall be
followed in accordance
with hazardous waste
operations regulations
and specifically include,

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but not be limited to,
immediately stopping
work in the vicinity of the
unknown hazardous
materials release;
notifying the city within
which the contamination
is encountered and the
regulatory agency
overseeing site cleanup,
if any; and retaining a
qualified environmental
firm to perform sampling
and remediation, if
warranted.

HAZ-MM-2: Soil and
Groundwater Management
Plan. In support of the HASP
described in Mitigation Measure
HAZ-MM-1, the contractor
conducting excavation and
disposal of fill and soil shall
develop and implement a so il
and groundwater management
plan (SGMP) for the
management of soil, soil gas,
and groundwater before any
ground-disturbing activity to
manage contaminated
materials, if encountered. The
SGMP shall include the
following, at a minimum:
• Site description, including
the hazardous materials
that may be encountered.
• Roles and responsibilities
of on-site workers,
supervisors, and the
regulatory agency.
• Training for site workers
focused on the
recognition of and
response to encountering
hazardous materials or
unknown structures, e.g.,
underground storage
tanks (USTs).
• Notification requirements
in the event of discovery
Condition of
Approval
Plan Check
Notes, Field
Inspections
Prior to
issuance of a
Demolition or
Grading
Permit;
Construction
(during soil-
disturbing
activities)
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety

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Mechanism
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of unknown structures or
contamination.
• Protocols for the
materials (fill, soil, and
dewatering effluent)
testing, handling,
removing, transporting,
and disposing of all
excavated materials and
dewatering effluent in a
safe, appropriate, and
lawful manner.
• Reporting requirement to
the overseeing regulatory
agency, if any
contamination is found
that requires agency
oversight, documenting
that site activities were
conducted in accordance
with the SGMP.

The SGMP shall be submitted
to Culver City and the City of
Los Angeles Building
Departments for review to
inform their permit approval
process before the start of
demolition and constructi on
activities and as a condition of
the grading, construction,
and/or demolition permit(s). The
contract specifications shall
mandate full compliance with all
applicable federal, state, and
local regulations related to the
identification, transportation,
and disposal of hazardous
materials.

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Responsible
Persons
a qualified environmental
professional. The SGMP shall
describe measures for (i)
management of excavated soils
and groundwater, (ii)
characterization of soils to
determine whether they qualify
as haza rdous waste under
regulations such as 22 C.C.R.

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samples when the HVAC
system is o n and off and also
when the parking garage
ventilation system is on and off.

Given that benzene is a
component of gasoline and will
be present in the garage due to
the parked cars, the air
sampling activities shall focus
on PCE to confirm that residual
PCE in soil vapor does not pose
a significant vapor intrusion risk
to office workers, valet parking
personnel, and workers working
within the parking level 1 office
space. The first round of
sampling should be conducted
before the buildings are
occupied and the garages are in
use. These air sampling
activities will aid in the
evaluation of the efficacy of the
liner and the garage itself to
mitigate vapor intrusion. These
sampling activities will also help
evaluate if any preferential
pathways (e.g., utility conduits
and elevator shaft) need to be
addressed. The second round
of sampling shall be conducted
either 1) after preferential
pathways have been mitigated,
if any are identified based on
the first round of sampling, 2)
during the summer months if
the first round of sampling was
conducted during the fall or
winter and air concentrations
were below screening levels, 3)
or a few months after the first
round if it was conducted during
the spring or summer and air
concentrations were below
screening levels. In the event
the indoor air data indicate that
risks are above target DTSC
risk levels, as applicable, after
pathways are sealed, the
garage’s ventilation system
shall be adjusted to reduce

December 5, 2022 Page 101 2022-R____

The groundwater portion of the
SGMP shall include the
following, at a minimum:
• The locations at which
groundwater dewatering is likely
to be required.
• Test methods to analyze
groundwater for hazardous
substances.
• Appropriate treatment and/or
disposal methods.
• Discussion of discharge to a
publicly owned treatment works
or the stormwater system, in
accordance with any regulatory
requirements the treatment
works may have, if this effluent
disposal option is to be used.

Noise
NOI-PDF-1: Project
Construction Schedule. Prior
to issuance of a building permit,
notice of the Project
construction schedule will be
provided to abutting property
owners and occupants.

Evidence of such notification
will be provided to the
appropriate department of City
of Culver City and City of Los
Angeles. The notice will identify
the commencement date and
proposed timing for all
construction phases
(demolition, grading,
excavation/shoring, foundation,
rough frame, plumbing, roofing,
Condition of
Approval
Plan Check
Notes,
Reports,
and Field
Inspections
Prior to
issuance of a
Building Permit
and Ongoing
during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

December 5, 2022 Page 102 2022-R____

NOI-PDF-2: Use of Impact
Pile Driver. The Project will not
require or allow the use of
impact pile drivers. Lower
noise- and vibration-generating
vibratory pile drivers and drills
will be used.

Condition of
Approval
Plan Check
Notes,
Reports,
and Field
Inspections
Prior to
issuance of a
Building Permit
and Ongoing
during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
NOI-PDF-3: Construction
Rules Sign. During all phases
of construction, a “Construction
Rules Sign” that includes
contact names and telephone
numbers, with 24 -hour
availability, of the App licant,
Property Owner, construction
contractor(s) will be posted on
the Property in a location that is
visible to the public. In addition,
appropriate staff person at both
City of Los Angeles and City of
Culver City will be notified for
such incidences. T hese names
and telephone numbers will
also be made available to
adjacent property owners and
occupants to the satisfaction of
the appropriate department
(Planning Manager and/or
Building Official) of both cities.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Building Permit
and Ongoing
during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
NOI-PDF-4 ( Compliance with
Noise Element): The following
noise standards from Policy 2.A
of the City’s General Plan Noise
Element shall be complied with
at all times:

A. No construction equipment
will be operated without an
exhaust muffler, and all
such equipment will have
mufflers and sound control
devices (i.e., intake
Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Building Permit
and Ongoing
during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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silencers and noise
shrouds) that are no less
effective than those
provided on the original
manufacturer supplied
equipment;
B. All construction equipment
will be properly maintained
to minimize noise
emissions;
C. If any construction vehicles
are serviced at an on -site
location, the vehicle(s) will
be setback from any street
and other property lines so
as to maintain a distance of
at least 100 feet from the
public right-of-way and from
Noise Sensitive Receptors;
D. Noise levels from stationary
sources (i.e., mechanical
equipment, ventilators, and
air conditioning units) will
be minimized by proper
selection of eq uipment and
the installation of parapets
or other acoustical
shielding as approved by
the Planning Manager; and
E. The Project will not allow
any delivery truck idling for
more than 5 minutes in the
loading area. Signs will be
posted prohibiting such
idling.

NOI-PDF-5: Neighborhood
Streets. No construction haul
trucks, including concrete
trucks, will be allowed to travel
through neighborhood streets
that are primarily residential
uses.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Grading Permit
and Ongoing
during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
NOI-PDF-6: Mechanical
Equipment Noise. All building
mechanical equipment and/or
ventilation systems not fully
enclosed will be designed to not
exceed sound level limits of the
noise level requirements of the
City of Culver City General Plan
Noise Element Regulation of
Stationary Noise Sources and
City of Los Angeles Municipal
Code Section 112.02 through
the use of quiet fans, duct
silencers, parapets, or similar
noise attenuation methods.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of
Mechanical
Permit for
subject
mechanical
equipment
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
NOI-PDF-7: Loading Dock
Operating Hours. On-site
loading dock operating hours
will be limited to 7:00 a.m. to
10:00 p.m.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Ongoing during
operation
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
NOI-PDF-8: Noise Control –
Amplified Sound Systems. If
the Project installs permanent
outdoor amplified sound
systems, the systems will be
located in the central courtyard
such that the sound would be
blocked by the proposed on-site
building from off -site receivers.

No amplified sound systems
would be installed in the publicly
accessible areas along the
Project’s street frontages.

Section 9.07.055(B) of the
CCMC prohibits the operation
of a loud speaker or sound
amplifying equipment for the
purposes of transmitting
messages, giving instructions,
or providi ng entertainment on
an ongoing basis which is
audible at the subject property
Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Certificate of
Occupancy
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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line. The systems will be
designed so as not to result in a
perceivable increase in noise
beyond the Project Site.

Specifically, daytime outdoor
amplified sound systems will
not result in an increase of 3
dBA L eq over existing ambient
noise conditions at the Project
property line. Nighttime speaker
noise, if it occurs, will comply
with the exterior noise
standards identified in the
Regulation of Stationary Noise
Sources (City of C ulver City
General Plan Noise Element,
approved by City Council July
22, 1996) and LAMC Section
112.01, which states that a
noise source that causes a
noise level increase of 5 dBA
over the existing average
ambient noise level as
measured at an adjacent
property line creates a noise
violation, respectively, within
the City of Culver City and City
of Los Angeles jurisdiction. All
speakers will have a minimum
setback of 25 feet from the
Project property line and will be
directed internally and
acoustically sh ielded from off -
site uses. Under the rare
occasion of maximum crowd
gathering in the central
courtyard with temporary
amplified sound systems, the
combined sound level from
speakers and people
conversation shall not exceed
the ambient noise level plus 5
dBA at an adjacent property
line, which would limit the
speaker sound level to a
maximum of 90 dBA when
measured at a distance of 50
feet from the speakers. A
qualified noise consultant will
provide written documentation

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Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
and submitted to appropriate
department of City of Culver
City and City of Los Angeles
that the design of the system(s)
complies with the maximum
noise levels at the property line
of the nearest off -site sensitive
receivers.

NOISE-MM-1: Prior to the
commencement of demolition,
the Project shall provide a
temporary 12 -foot-tall
construction fence equipped
with noise blankets rated to
achieve sound level reductions
of at least 10 dBA along the
northern and western
boundaries of the Project Site,
between the Project Site and
the surrounding residences to
the north and west. In addition,
a temporary 6 -foot-tall
construction fence equipped
with noise blankets rated to
achieve sound level reductions
of at least 5 dBA along the
southern boundary along
Washington Boulevard,
between the Project Site and
the residences to the south and
east of the Project Site.

Temporary noise barriers shall
be used to block the line -of-
sight between the construction
equipment and the nearby
noise-sensitive receptors during
the duration of construction
activities to the extent feasible.

Standard construction
protective fencing with green
screen or pedestrian barricades
for protective walkways shall be
installed along property lines
facing streets or commercial
buildings. All temporary
barriers, fences, and walls shall
have gate access as needed for
construction activities,
deliveries, and site access by
Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Demolition
Permit, Verified
at
Preconstruction
Meeting with
City of Culver
City and City of
Los Angeles
and Ongoing
during
Construction.

Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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Timing of
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Responsible
Persons
construction personnel. At Plan
Check at City of Culver City and
City of Los Angeles, the
Applicant shall provide a s tudy
conducted by a noise expert
that demonstrates the sound
barriers would achieve these
required dBA reductions . The
study will include a
fencing/sound barrier plan for
City review.

NOISE-MM-2: Contractors shall
ensure that all construction
equipment, fixed or mobile, are
equipped with properly
operating and maintained noise
shielding and muffling devices,
consistent with manufacturers’
standards. The construction
contractor shall keep
documentation on -site
demonstrating that the
equipment has been
maintained in accordance with
the manufacturers’
specifications. Most of the noise
from construction equipment
originates from the intake and
exhaust portions of the engine
cycle. According to FHWA, use
of adequate mufflers systems
can achieve reductions in noise
levels of up to 10 dBA. The
contractor shall use muffler
systems that provide a
minimum reduction of 8 dBA
compared to the same
equipment without an installed
muffler system, reducing
maximum construction noise
levels. The contractor shall also
keep documentation on -site
prepared by a noise consultant
verifying compliance with this
measure.

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Demolition
Permit and
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning
Public Services
POL-PDF-1: Project Site
Security and Access During
Condition of
Approval
Plan Check
Notes and
Prior to
issuance of a
Culver City
Building Safety

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Condition, or
Mechanism
Method of
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Timing of
Verification
Responsible
Persons
Construction. During
construction of the Project, the
Project Site will be fenced and
gated with surveillance
cameras to monitor the site
during off hours.

Field
Inspections
Grading
Permit,
Building
Permit, and
Ongoing during
Construction
Division, Building
Safety Inspector;
Police
Department;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety, Public
Works, Fire and
Police
Departments
POL-PDF-2: Project Site
Security and Access During
Operation. During operation of
the Project, access to the
parking structure will be
controlled through gated
entries, and the entry areas will
be well illuminated. Project Site
security would include
controlled keycard access to
office spaces, security lighting
within common areas and
entryways, and closed -circuit
TV monitoring (CCTV).

Condition of
Approval
Plan Check
Notes and
Field
Inspections
Prior to
issuance of a
Certificate of
Occupancy
Culver City
Building Safety
Division, Building
Safety Inspector;
Police
Department;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety, Public
Works, Fire and
Police
Departments
Transportation
TRAF-PDF-1: Construction
Management Plan. A Final
Construction Management Plan
(FCMP) will be prepared by the
Project contractor in
consultation with the Project's
traffic and/or civil engineer. The
FCMP will define the scope and
scheduling of construction
activities covering the entire
Project Si te as well as the
Applicant's proposed
construction site management
responsibilities in order to
ensure that disturbance of
nearby land uses or interruption
of pedestrian, vehicle, bicycle
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys,
and Field
Inspections
Prior to
Demolition,
Grading and
Building
Permits, and
Ongoing during
Construction
Culver City
Building Safety,
Planning, Public
Works, Fire and
Police
Departments; Los
Angeles
Department of
Transportation,
and City Planning

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and public transit are minimized
to the extent feasible. The
FCMP will be subject to review
and approval by appropriate
building officials, city traffic
engineers, civil engineers, and
planning staff for the Cities of
Culver City and Los Angeles, as
required, prior to issuance of
any Project demolition, grading
or excavat ion permit. The
FCMP will also be reviewed and
approved by the respective fire
and police departments.

Prior to commencement of
construction, the contractor will
advise each City’s public works
inspector and building inspector
(inspectors) of the constru ction
schedule. As -needed
construction management
meetings shall be convened
with appropriate Culver City
and/or City of Los Angeles staff
and representatives of
surrounding developments that
may have overlapping
construction schedules with the
Project, to ensure that
concurrent construction
projects are managed in
collaboration with one another.

The FCMP will consider
potential project construction
disruptions to transportation
facilities near the Project Site
and provide effective strategies
to limit the Project’s use of the
public right-of-way (streets and
sidewalks) during peak traffic
periods and will be subject to
adjustment by City staff as
deemed necessary and
appropriate to preserve the
general public safety and
welfare.

Prior to approval of the FCM P
and grading permits, the

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Applicant will conduct one (1)
community meeting pursuant to
the notification requirements of
the City of Culver City
community meeting guidelines,
to discuss and provide the
following information to the
surrounding community:

1. Construction schedule
and hours.

2. Framework for
construction phases.

3. Identify traffic diversion
plan by phase and
activity.

4. Potential location of
construction parking and
office trailers.

5. Truck hauling routes and
material deliveries (i.e.,
identify the potential
routes and restrictions.

Discuss the types and
number of trucks
anticipated and for what
construction activity).

6. Emergency access plan.

7. Demolition plan.

8. Staging plan for the
concrete pours, material
loading and removal.

9. Crane location(s).

10. Accessible Applicant and
contractor contacts during
construction activity and
during off hours (relevant
email address and phone
numbers).

11. Community notification
procedures.

The CMP shall at a minimum
include the following:

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1. The name and telephone
number of a contact
person who can be
reached 24 hours a day
via telephone regarding
construction or
construction traffic
complaints or emergency
situations.

2. An up-to-date list of local
police, fire, and
emergency response
organizations and
procedures for the
coordination of
construction activity,
potential delays, and any
alerts related to
unanticipated road
conditions or delays, with
local police, fire, and
emergency response
agencies. Maps showing
access to and within the
site and to adjacent
properties will be
provided.

3. Construction plans and
procedures to address
community and both the
appropriate Cities of
Culver City and Los
Angeles personnel
notification of key
construction activities;
temporary construction
fencing and maintenance
of construction areas
within public view; noise
and vibration controls;
dust management and
control; and worker
education on required
mitigation measures
included in the Project’s
Mitigation Monitoring
Program and best
practices to reduce

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4. Procedures for the
training and certification
of flag persons.

5. To the extent known,
identification of the
location, times, and
estimated duration of any
roadway closures;
procedures for traffic
detours, pedestrian
protection, reducing
effects on public transit
and alternate
transportation modes;
and plans for use of
protective devices,
warning signs, and
staging or queuing areas.

6. The location of temporary
power, portable toilet and
trash and materials
storage locations.

7. The timing and du ration
of any street, sidewalk
and/or lane closures will
be approved in advance
by either the City of
Culver City or the City of
Los Angeles, depending
on the jurisdiction of the
roadway. As traffic lane,
parking lane, and/or
sidewalk closures are
anticipated, worksite
traffic control plan(s),
approved by the City of
Los Angeles and City of
Culver City, will be
developed and
implemented to route
vehicular traffic,
bicyclists, and
pedestrians around any
such closures. As
applicable at the time of
construction, such

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Responsible
Persons
notices will be made
available in digital format
for posting on each City
website and distribution
via email alerts on
electronic platforms such
as the County of Los
Angeles’ "Gov Delivery"
system. The FCMP will
be updated weekly during
the duratio n of project
construction, as
determined necessary by
the City. The FCMP will
require that review and
approval of any proposed
lane closures include
coordination with the fire
and police departments
of each City to minimize
potential effects on traffic
flow and emergency
response.

8. Provisions that staging of
construction equipment
and materials will be
accommodated within the
Project Site and that
construction worker
parking will be
accommodated on the
Project Site and/or at off -
site locations to be
determined and
disclosed, potentially with
shuttles to and from the
Project Site.

TRAF-PDF-2: Transportation
Demand Management (TDM)
Program. The Project will
implement the following TDM
measures subject to Culver City
Transportation Department and
LADOT review and approval
prior to issuance of the first
Temporary Certificate of
Occupancy (TCO) for the
Project in order to reduce drive-
Condition of
Approval
Approval of
Plan
During Plan
Check and
prior to
issuance of a
Certificate of
Occupancy
Culver City Traffic
Engineering,
Engineering/Public
Works,
Transportation
Department and
Planning Division;
Los Angeles
Department of
Transportation,
and City Planning

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The Project will offer
tailored trip planning
assistance with in -house
TDM coordinators.

Assistance will be
available for all
employees online, by
email, and by phone. The
Project will also host a
virtual kiosk every week
to chat with a team
member and have any
questions answered.
• Marketing and
Communications: The
Project will provide a
comprehensive website
detailing alternative
transportation options
such as carpool, rail,
shuttle, coach, bike, and
options available for
transportation once on
campus. To provide
transportation
information to new
employees, the
Commute Program will
make a presentation at
New Employee
Orientation. The
Commute Program will
also actively m onitor
email lists and group lists
to discuss and
collaborate with
employees on improving
commute programs.

Information
dissemination tools will
include monthly news
updates, web updates,
email templates, lobby
information centers,
communication regarding
service expansions, and

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Condition, or
Mechanism
Method of
Verification
Timing of
Verification
Responsible
Persons
attending internal
employee events.
• Public Transit : The
Project will be served by
an existing fixed -route
intercampus shuttle
program to provide
connections to other
Applicant-occupied
buildings in Culver City
and to public transit. The
Project will also offer a
monthly transit subsidy
which provides a financial
incentive for riding transit
instead of driving to the
Project Site.
• Rideshare: The Project
will provide an online tool
that matches riders with
drivers originating from
similar locales. This will
reduce single occupancy
vehicle trips to and from
the Project.
• Bicycling: In addition to
providing Code -required
bicycle parking and
shower facilities, the
Project will provide a
monthly subsidy to
employees who commute
by bicycle to work, which
can be used to pay for
bicycle, maintenance,
and storage, or towards
upgrading an existing
bicycle or purchasing a
new bicycle. The Project
will also promote cycling
by participating in the
County’s annual Bike to
Work Day , providing
discounts on select
cycling products,
providing a website that
has information on safe
cycling and cycling apps.

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Responsible
Persons
• Walking: The Project will
provide enhanced access
points to the site to
improve pedestrian
connectivity and expand
adherence to th e
Americans with
Disabilities Act (ADA).

Employees will be
educated on local
neighborhood
destinations within
walking distance and will
be encouraged to walk to
events, meetings, and
meals whenever
possible. The areas
surrounding the
walkways and sidewalks
will be well -landscaped
and maintained, with
pedestrian-oriented
lighting to contribute to
the safety of walking at
night.
• Pre-tax Commuter
Benefit: A pre -tax
commuter benefit will be
provided to employees
for commute -related
expenses such as public
transit (after the transit
subsidy), vanpooling, and
parking. The commuter
benefit will supplement
the transit and bicycle
subsidies.
• Commuter Club : A
Commuter Club is an opt-
in program that offers
employees the
opportunity to receive
Commute Program email
updates about schedule
updates, new service,
events, and programs.
• Commute Expert
Program: This program

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Mechanism
Method of
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Timing of
Verification
Responsible
Persons
will provide people using
a commute alternative an
opportunity to meet other
employees who are using
the same mode who can
“mentor” them by
providing answe rs to
questions about using
that mode, stop locations,
routes, or local transit
options.
• Guaranteed Ride Home
Program: The Project will
sponsor a guaranteed
ride home for Project Site
employees who came to
work without their own
car in the event of an
unexpected situation or
emergency when
walking, biking,
carpooling, or taking
transit home will not be
feasible.
• Intercampus Shuttles :

The Project will provide
on-request fixed route
intercampus shuttles
between Apple -occupied
buildings during work
hours as w ell as
commuter shuttles from
select points in and
around the Los Angeles
basin to the Project site
during morning and
evening commute hours.
• Campus Bike Share
Program: A Campus
Bike Share program will
be implemented to
provide a transportation
option betw een other
buildings occupied by the
Applicant. Campus bikes
will be equipped with
GPS tracking and an
electronic rear-wheel lock

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Campus bikes will be
managed and maintained
by a local bike
maintenance vendor.
• On-site Services : The
Project will provide its
employees with on -site
amenities such as a full -
service cafeteria, coffee
bars, and shower
facilities. The offered
services will contribute to
limiting the number of
vehicle trips employees
will need to take off -site
during the day.

Tribal Cultural Resources
TCR-MM-1: Prior to the
issuance of a demolition permit
for the Project, the Applicant
shall retain a Native American
Monitor from the Gabrieleño
Band of Mission Indians – Kizh
Nation (Kizh Nation or Tribe).

The Native American Monitor
shall be present during the
following construction activities
that have the potential for
encountering tribal cultural
resources: demolition,
pavement removal,
clearing/grubbing,
drilling/augering, potholing,
grading, trenching, excavation,
tree removal or other ground
disturbing activi ty associated
with the Project, whether on the
Project Site or in connection
with Project off -site
improvements (collectively
“ground disturbing activities”).

Notwithstanding the foregoing,
Native American monitoring
shall not be required for any
moving of soils after they have
been initially disturbed or
displaced by Project -related
Condition of
Approval
Plan Check
Notes,
Reports,
Surveys and
Field
Inspections
Prior to
issuance of
Demolition
Permit and
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety and City
Planning

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Mechanism
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Timing of
Verification
Responsible
Persons
construction. The Applicant
shall prepare a monitoring
agreement with the Kizh Nation
that outlines the roles and
responsibilities of the Native
American Monitor and shall
submit this agreement to the
City of Culver City and City of
Los Angeles prior to the
issuance of demolition permit
for the Project.

Prior to commencement of
ground disturbing activities, a
Tribal Cultural Resources
Sensitivity Training session
shall be held f or those
construction personnel who will
be directly involved in the
ground disturbing activities. The
training session shall be carried
out by the Native American
Monitor and shall focus on how
to identify tribal cultural
resources that may be
encountered during ground
disturbing activities and the
procedures to be followed in
such an event. If the Native
American Monitor is not present
at the Project Site on any given
workday, the ground disturbing
activities may continue if the
workers involved in such
activities attended the training
session.

Full-time monitoring may be
reduced to part -time
inspections, or ceased entirely,
if determined appropriate by the
Native American Monitor in the
event there appears to be little
to no potential for impacting
tribal cultural resources. Native
American monitoring shall
conclude no later than
conclusion of ground disturbing
activities.

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TCR-MM-2: The Native
American Monitor shall
complete daily monitoring logs
that provide descriptions of the
relevant ground -disturbing
activities, the type of
construction activities
performed, locations of ground -
disturbing activities, soil types,
cultural-related materials, and
any other facts, conditions,
materials, or discoveries of
significance to the Tribe.

Monitor logs shall identify and
describe any discovered tribal
cultural resources, including but
not limited to, Native American
cultural and historical art ifacts,
remains, places of significance,
etc., as well as any discovered
Native American (ancestral)
human remains and burial
goods. Copies of monitor logs
shall be provided to the
Applicant and the City of Culver
City and/or City of Los Angeles
upon writt en request to the
Tribe. The Applicant shall not
be deemed to be out of
compliance with this measure if
the Native American Monitor
fails to complete or submit any
such monitoring logs.

Condition of
Approval
Field
Inspections
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Department of
Building and
Safety and City
Planning
TCR-MM-3: In the event of a
discovery of potential tribal
cultural resources at the Project
Site, the Qualified
Archaeologist identified in
Mitigation Measure CUL -MM-1
(after consultation with the
Native American Monitor) shall
have the authority to
temporarily divert, redirect, or
halt ground -disturbance
activities to allow identif ication,
evaluation, and potential
recovery of such potential
resources. After consulting with
the Native American Monitor
Condition of
Approval
Field
Inspections
Ongoing during
Construction
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,
Engineering and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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Responsible
Persons
and the Applicant, the Qualified
Archaeologist shall establish an
appropriate buffer area in
accordance with industry
standards, reas onable
assumptions regarding the
potential for additional
discoveries in the vicinity, and
safety considerations for those
making an evaluation and
potential recovery of the
discovery. This buffer area shall
be established around the find
where ground -disturbing
activities shall not be allowed to
continue. Work shall be allowed
to continue outside of the buffer
area.

Within three (3) business days
of such discovery, a meeting
shall take place between the
Applicant, the Qualified
Archaeologist, the Tribe, a nd
the City of Culver City and/or
City of Los Angeles depending
on the location/jurisdiction
where the resource is located to
discuss the significance of the
find and whether it qualifies as a
tribal cultural resource pursuant
to Public Resources Code
Section 21074(a). If, as a result
of the meeting and after
consultation with the Tribe, the
Applicant, and the Qualified
Archaeologist, the City of
Culver City and/or City of Los
Angeles determines, based on
substantial evidence, that the
resource is in fact a tribal
cultural resource, the Qualified
Archaeologist shall develop a
reasonable and feasible
treatment plan, with input from
the Tribe as necessary, and
with the concurrence of the
appropriate City’s Planning
Director. The treatment
measures in the treat ment plan

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Timing of
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Responsible
Persons
shall be in compliance with any
applicable federal, State, or
local laws, rules or regulations.

The treatment plan shall also
include measures regarding the
curation of the recovered
resources.

The mediator must have the
requisite professional
qualifications and experience to
mediate such a dispute. The
City of Culver City and/or City of
Los Ange les shall make the
determination as to whether the
mediator is at least minimally
qualified to mediate the dispute.

After making a reasonable effort
to mediate this particular
dispute, the City may: (1)
require the recommendation be
implemented as original ly
proposed by the Archaeologist;
(2) require the
recommendation, as modified
by the City, be implemented as
it is at least as equally effective
to mitigate a potentially
significant impact; (3) require a
substitute recommendation be
implemented that is at least as
equally effective to mitigate a
potentially significant impact to
a tribal cultural resource; or (4)
not require the recommendation
be implemented because it is
not necessary to mitigate any
significant impacts to tribal

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/ Mitigation Measure (MM)
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Action,
Condition, or
Mechanism
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Timing of
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Responsible
Persons
cultural resources. The
Applicant shall pay all costs and
fees associated with the
mediator.

The Applicant may
recommence ground
disturbance activities inside of
the specified radius of the
discovery site only after it has
complied with all of the
recommendations developed
and app roved pursuant to the
process set forth in the above
paragraphs.

The recovered Native American
resources may be placed in the
custody of the Tribe, who may
choose to use them for their
educational purposes, or they
may be curated at a public, non-
profit institution with a research
interest in the materials. If
neither the Tribe nor an
institution accepts the
resources, they may be
donated to a local school or
historical society in the area for
educational purposes.

Utilities and Service Systems
WATER-PDF-1: Water
Conservation. The Project will
implement water conservation
Condition of
Approval
Plan Check
Notes,
Reports,
Prior to
issuance of a
Certificate of
Occupancy
Culver City
Building Safety
Division, Building
Safety Inspector;
Public Works,

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Persons
measures that include, but are
not limited to, the following:
• Fixtures
– High Efficiency
Toilets with a flush
volume of 1.1
gallons per flush, or
less
– Showerheads with
a flow rate of 1.5
gallons per minute,
or less
– All utility, service
and mop sinks will
have a maximum
flow rate of 1.5
gallons per minute
– Condensate drain
water captu re and
reuse for irrigation
– An air cooled / air
source mechanical
cooling system will
be utilized in lieu of
cooling towers.
and Field
Inspections
Engineering, and
Planning Division;
Los Angeles
Departments of
Building and
Safety and City
Planning

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Responsible
Persons
• Landscape and
Irrigation
– California
Friendly® plants or
native plants
– Drip/ Subsurface
Irrigation (Micro -
Irrigation)
– Proper Hydro -
zoning/Zoned
Irrigation (groups
plants with similar
water requirements
together)
– Weather Based
Irrigation
Controllers
• Utilities
– Individual metering
and billing for water
use for every
commercial unit

City Council Meeting AgendaDecember 5, 2022

City Council Meeting Agenda
December 5, 2022