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ATT_1_Proposed_Resolution_to_Adopt_EIR.pdf

City Council Meeting Agenda
August 26, 2024

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ATT_1_Proposed_Resolution_to_Adopt_EIR.pdf
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August 26, 2024
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General Plan 2045 and Zoning Code Update Project vii SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Table 4.4-1 Previously Recorded Archaeological Resources within the City .......................... 4.4-10 Table 4.5-1 Estimated Existing Operational Energy Demand ................................................... 4.5-4 Table 4.5-2 Estimated Culver City General Plan 2045 Operational Energy Demand1 ........... 4.5-20 Table 4.7-1 Description of Identified GHGs .............................................................................. 4.7-3 Table 4.7-2 Atmospheric Lifetimes and GWPs ......................................................................... 4.7-4 Table 4.7-3 State of California Greenhouse Gas Emissions ...................................................... 4.7-5 Table 4.7-4 Estimated Existing Culver City Operational GHG Emissions (2019) ..................... 4.7-12 Table 4.7-5 Estimated Statewide Greenhouse Gas Emissions Reductions in the 2022 Scoping Plan ......................................................................................................... 4.7-19 Table 4.7-6 Major Climate Legislation and Executive Orders Enacted Since the 2017 Scoping Plan ......................................................................................................... 4.7-19

Table 4.7-7 Unmitigated Annual Greenhouse Gas Emissions ................................................ 4.7-46 Table 4.7-8 Consistency with Applicable Scoping Plan Greenhouse Gas Reduction Strategies ............................................................................................ 4.7-53

Table 4.7-9 Consistency with Applicable 2020–2045 SCAG RTP/SCS Actions and Strategies ............................................................................................................. 4.7-70 Table 4.9-1 Receiving Waters for Urban Runoff in Culver City ................................................. 4.9-5 Table 4.10-1 Existing Land Uses in Planning Area (2020) ......................................................... 4.10-4 Table 4.10-2 General Plan 2045 Projections by Land Use ...................................................... 4.10-14 Table 4.10-3 Consistency of the Project with Applicable Goals of the 2020 RTP/SCS ........... 4.10-18 Table 4.12-1 HUD External Noise Exposure Standards for New Residential Construction ...... 4.12-8 Table 4.12-2 Construction Vibration Damage Criteria ............................................................. 4.12-8 Table 4.12-3 Indoor Groundborne Vibration Impact Criteria for General Assessment ............ 4.12-9 Table 4.12-4 Noise and Land Use Compatibility Matrix ......................................................... 4.12-10 Table 4.12-5 State interior and Exterior Noise Standards ...................................................... 4.12-11 Table 4.12-6 Summary of Short-Term Noise Measurements ................................................. 4.12-15 Table 4.12-7 Summary of Long-Term Noise Measurements .................................................. 4.12-16 Table 4.12-8 Existing Roadway Noise Levels .......................................................................... 4.12-18 Table 4.12-9 Construction Equipment Noise Levels ............................................................... 4.12-25 Table 4.12-10 Future Roadway Noise Levels ............................................................................ 4.12-26 Table 4.12-11 Vibration Source Amplitudes for Construction Equipment ............................... 4.12-35 Table 4.12-12 Cumulative Traffic Noise Impacts ...................................................................... 4.12-41 Table 4.13-1 Housing Units 2000–2020 .................................................................................... 4.13-2 Table 4.13-2 Household Size 2000–2019 .................................................................................. 4.13-3 Table 4.13-3 Culver City Jobs-Housing Ratio .......................................................................... 4.13-11 Table 4.14-1 Culver City Fire Department Station Equipment and Personnel ......................... 4.14-2 Table 4.14-2 CCFD Response Times .......................................................................................... 4.14-4 Table 4.14-3 CCPD Population, Officer, and Crime Comparison (2023) ................................... 4.14-8 Table 4.14-4 Culver City 2021 Crime Statistics ....................................................................... 4.14-10 Table 4.14-5 Capacity of CCUSD Schools ................................................................................ 4.14-12 Table 4.15-1 Park and Open Space Classifications ................................................................... 4.15-2 Table 4.15-2 Parks in the Planning Area ................................................................................... 4.15-3 Table 4.15-3 Current Park Service ............................................................................................ 4.15-5 Table 4.16-1 General Plan Update Buildout VMT Metrics ..................................................... 4.16-24 Table 4.16-2 Cumulative VMT Metrics ................................................................................... 4.16-29 Table 4.18-1 Culver City Service Area Total Projected Water Demand .................................... 4.18-4 Table 4.18-2 LADWP Total Projected Water Demand .............................................................. 4.18-4 Table 4.18-3 Projected Normal Year Water Supply and Demand for Culver City Service Area ...................................................................................................................... 4.18-5

Table 4.18-4 Single Dry Year Water Supply and Demand for Culver City Service Area ............ 4.18-5 Contents

General Plan 2045 and Zoning Code Update Project viii SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Table 4.18-5 Five Consecutive Dry Years Water Supply and Demand through 2045 for Culver City Service Area ....................................................................................... 4.18-6 Table 4.18-6 LADWP Service Area Reliability Assessment for Average Weather Year ............. 4.18-7 Table 4.18-7 LADWP Service Area Reliability Assessment for Single Dry Year ......................... 4.18-8 Table 4.18-8 LADWP Service Area Reliability Assessment for Multiple Dry Years (Year 5 of 5) ......................................................................................................... 4.18-9 Table 4.18-9 General Plan Update 2045 Water Demand Projections .................................... 4.18-43 Table 4.18-10 Projected Wastewater Generation .................................................................... 4.18-47 Table 4.18-11 Estimated Solid Waste Generation .................................................................... 4.18-49 Table 5-1 Comparison of Population, Housing Units, and Jobs ................................................ 5-8 Table 5-2 Comparison of the Impacts of the Project and Alternatives .................................. 5-94

Appendices
A. Notice of Preparation, Initial Study, and Scoping Comments and Responses A-1 NOP and Recirculated NOP
A-2 Initial Study
A-3 Scoping Comments from NOP and Recirculated NOP
B. Air Quality Worksheets
C. Biological Resources Database Search Results
D. Energy Data
E. Greenhouse Gas Emissions Worksheets
F. Noise Measurement Data and Worksheets
G. Traffic Data CEQA Transportation Analysis Memorandum G-1 CEQA Transportation Analysis Memorandum
G-2 VMT Traffic Data
H. Native American Consultation

General Plan 2045 and Zoning Code Update Project ES-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

EXECUTIVE SUMMARY

As the lead agency, the City of Culver City (City) has prepared this Draft Program Environmental Impact Report (Draft PEIR) to provide information about the potential environmental impacts associated with the update to the General Plan, Picture Culver City: General Plan 2045 (General Plan 2045 or General Plan Update) and the associated Zoning Code Update that is necessary to implement the General Plan Update. The General Plan Update and the Zoning Code Update are collectively referred to as the Project. This Draft PEIR has been prepared in conformance with CEQA (California Public Resources Code [PRC] Section 21000 et seq.), and the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.) and the City’s procedures for implementing CEQA. The principal State CEQA Guidelines sections governing content of this document are Sections 15120 through 15132 (Contents of an EIR), and Section 15168 (Program EIR). The State Clearinghouse Number is 2022030144.

This chapter of the Draft PEIR is prepared pursuant to State CEQA Guidelines Section 15123, which requires that an EIR include a brief summary of the Draft EIR. Per Section 15123, the summary shall contain a brief description of the Project’s proposed actions and consequences, including identification of each significant effect and proposed mitigation measures and alternatives that would reduce or avoid those effects, a description of the areas of controversy known to the lead agency, and identification of issues to be resolved, including the choice among alternatives and whether or how to mitigate the significant effects.

ES.1 Project Location
Culver City is located in the western area of Los Angeles County. The City comprises about five square miles and is bounded by the City of Los Angeles to the north, west, and south, and by unincorporated areas of Los Angeles County along its eastern boundary. Culver City is situated approximately five miles east of the Pacific Ocean, five miles north of Los Angeles International Airport (LAX), and eight miles west of downtown Los Angeles. Interstate 405 (I-405) runs in a north-south direction in the western part of the city and Interstate 10 (I-10) runs in an east-west direction just outside of the city to the north. State Route 90 (SR-90) intersects Culver City from the west and ends at Slauson Avenue.

The General Plan Planning Area includes the city of Culver City and its unincorporated Sphere of Influence (SOI). The SOI includes land within unincorporated portions of Los Angeles County located adjacent to the City. The SOI is located to the east of the City boundary in the Baldwin Hills area of Los Angeles County, west of La Cienega Boulevard.

ES.2 Proposed Project
The Project, as defined by the CEQA Guidelines, is the adoption and implementation of a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Executive Summary

General Plan 2045 and Zoning Code Update Project ES-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Code to implement the General Plan Update. The General Plan Update would provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its SOI, through the planning horizon year of 2045. Together with the Zoning Ordinance and related sections of the Municipal Code, the 2045 General Plan would serve as the basis for planning-related decisions made by City staff, the Planning Commission, and the City Council.

By law, a general plan must be an integrated, internally consistent statement of City policies.

Government Code Section 65302 requires that a general plan include the following seven elements: Land Use, Circulation, Housing, Conservation, Open Space, Noise, and Safety. The Project includes incorporation of the City’s recently adopted 2021-2029 Housing Element Update, which provided an update to the previous 2013-2021 Housing Element.

Senate Bill (SB) 1000 and Government Code Section 65302 require that since disadvantaged communities have been identified within the City, the Plan must also address Environmental Justice either as a standalone element or integrating related goals, policies, and objectives throughout other elements. The General Plan Update includes a Community Health and Environmental Justice element. Additional elements may be included as well, at the discretion of the City. The General Plan Update includes six optional elements: Governance and Leadership; Arts, Culture, and Creative Economy; Economic Development; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction; and Infrastructure.

ES.3 Areas of Controversy and Issues to Be Resolved
Section 15123 of the State CEQA Guidelines states that an PEIR shall identify areas of controversy known to the lead agency, including issues raised by the agency and the public during the scoping process.

The City received comment letters from public agencies and the public during public review period in response to the Notice of Preparation of an Environmental Impact Report (NOP) and Recirculated NOP. In general, the comment letters recommended that the Project take into consideration potential impacts related to the following environmental resources:
transportation, including transit, walkability, access, and vehicle miles travelled (VMT); air quality; greenhouse gas emissions; biological resources; cultural and tribal cultural resources; and public utilities and services.
[Note to City: To be updated after end of scoping comment period and review of comments] ES.4 Significant and Unavoidable Environmental
Impacts
State CEQA Guidelines Section 15126 requires that an EIR describe any significant impacts that cannot be avoided, even with implementation of feasible mitigation measures. As indicated in Chapter 4, Environmental Impact Analysis, of this Draft PEIR, the Project would result in significant unavoidable impacts associated with air quality, cultural resources (historical Executive Summary

General Plan 2045 and Zoning Code Update Project ES-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
resources), noise, transportation (VMT), and water supply, which are discussed in more detail below and are summarized in Chapter 6, Other CEQA Considerations.

Air Quality
The Project would result in a potentially significant impact related to a conflict with or obstruction of the applicable air quality plan due to growth that could exceed demographic assumptions for Culver City. While implementation of mitigation would serve to reduce the severity of the effects, the impacts would remain significant and unavoidable.

The Project would result in a potentially significant impact related to a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment during construction and operation due to regional emissions that could exceed the SCAQMD significance thresholds. While implementation of mitigation would serve to reduce the severity of the effects, the impacts would remain significant and unavoidable.

The Project would result in a potentially significant impact related to exposure of sensitive receptors to substantial pollutant concentrations during construction and operation due to localized emissions and toxic air contaminant emissions that could exceed the applicable significance thresholds. While implementation of mitigation would help to reduce the severity of the effects, the impacts would remain significant and unavoidable.

Cultural Resources
The Project could cause a substantial adverse change in the significance of a historical resource pursuant CEQA Guidelines Section 15064.5 as it is reasonable to assume that some historical resources would be demolished or altered in an adverse manner over the lifetime of the General Plan Update. While implementation of mitigation would serve to reduce the severity of the effects, the impacts would remain significant and unavoidable.

In addition, future development in the Planning Area, including growth anticipated under the proposed General Plan Update, and larger Los Angeles County region throughout the 2045 planning horizon, could result in a substantial adverse change in the significance of historical resources, thus resulting in a potentially significant cumulative impact. Even with implementation of proposed General Plan Update policies, as well as applicable local, state, and federal laws and MM-CUL-1, the Project’s contribution to this potentially significant cumulative impact would be cumulatively considerable.

Noise
The Project would result in a potentially significant impact, as construction noise and traffic noise generated during the construction and operation of future development projects could exceed the significance thresholds. While implementation of mitigation would help to reduce the severity of noise during construction, the impacts during this phase would remain significant and unavoidable; no feasible mitigation is available to reduce the severity of traffic noise during operation, and thus impacts during this phase would continue to be significant and unavoidable.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The Project would result in a potentially significant impact, as vibration generated during the construction of future development projects could exceed the significance thresholds. While implementation of mitigation would reduce the severity of vibration during construction, the impact during this phase would remain significant and unavoidable.

In addition, the Project’s contribution to cumulative construction and operational noise and vibration impacts would be cumulatively considerable.

Transportation
The Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) in that the average daily VMT per Capita, Daily VMT per Employee, and total VMT per service population generated by the Project would exceed 15 percent below the corresponding City Baseline. As no feasible mitigation is available, the impact would continue to be significant and unavoidable.

Water Supply
Sufficient water supplies to serve the Project and reasonably foreseeable future development during normal, single dry, and multiple dry years would not be available. Despite a range of activities being undertaken by multiple agencies to ensure reliable water supplies, no additional mitigation beyond these actions would be feasible, and thus the impact would continue to be significant and unavoidable.

In addition, future development allowed under the Project would contribute to an increased cumulative demand for water supply. Impacts associated with future development allowed under the Project would be cumulatively considerable.

ES.5 Summary of Project Alternatives
CEQA Guidelines section 15126.6(a) states that an EIR must describe and evaluate a reasonable range of alternatives to a project that would feasibly attain most of the project’s basic objectives but avoid or substantially lessen any identified significant adverse environmental effects of the project. An EIR is not required to consider every conceivable alternative to a project or alternatives that are infeasible. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.

Chapter 5, Alternatives, of this Draft PEIR presents the alternatives analysis as required by CEQA for the Project. The discussion includes the methodology used to select alternatives to the Project for detailed CEQA analysis, with the intent of developing potentially feasible alternatives that could avoid or substantially lessen the significant impacts identified while still meeting most of the Project’s basic objectives. Based on the screening process, the following alternatives were selected for detailed analysis in this Draft PEIR:
• Alternative 1 – No Project Alternative
• Alternative 2 – Concentrated Growth Alternative
• Alternative 3 – Modified Mixed Use High Designation
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Detailed descriptions of the alternatives are presented below. Their associated environmental impacts are discussed further in Chapter 5, Alternatives.

Alternative 1 – No Project Alternative
Consistent with Section 15126.6(e)(2) of the State CEQA Guidelines, the No Project Alternative represents what would be reasonably expected to occur in the foreseeable future if the Project were not adopted and the City’s current General Plan and Zoning Code remain in effect. Future development under Alternative 1, the No Project Alternative, would be the continuation of growth in the city guided by the City’s adopted 1996 General Plan and the current Zoning Code.

Under the No Project Alternative, the current land use designations in the adopted General Plan as amended to date and existing goals and policies would remain in place. Future development in the Planning Area would continue to be subject to existing policies, regulations, development standards, and land use designations of the adopted General Plan. No amendments would occur to areas identified for change under the Project. Policies concerning topics such as transportation, economic development, parks, open space, the environment, climate change, environmental justice, health, and housing would also remain unchanged.

Specifically, since no new land use or zoning designations would be created under this alternative, the City would not comprehensively update its Land Use Element or Land Use Map to increase densities or intensities across the city. Without increasing the residential densities within the city, the City would not be able to fully meet its current and future RHNA allocations through 2045.
1 In addition, under this alternative, the City would have to continue to process General Plan and zoning amendments on a project-by-project basis for projects that conflict with the existing 1996 General Plan, which results in land use changes at the parcel level instead of being comprehensively updated through the planning process for the General Plan.

The 1996 General Plan projected approximately 41,330 residents and approximately 56,743 jobs by the planning horizon of 2010.
2 Since the planning horizon of 2010 has passed, the No Project Alternative growth projections are based on the socio-economic data (SED) assumptions from the Southern California Association of Governments (SCAG) 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). SCAG developed demographic and economic forecasts of population, households, and employment at the regional and county levels and then incorporated local land use data and existing housing and employment data to allocate growth at the jurisdiction (e.g., city) and Transportation Analysis Zone (TAZ) levels. SCAG worked with the individual jurisdictions during this process to ensure accurate projections for each jurisdiction using their current General Plans and land use maps. The SCAG 2045 forecast for Culver City is a population of 41,546 residents with a total of 18,017 households and 64,041 jobs.

1 City of Culver City Housing, October 2021-2029, Appendix B, Table B-5. 2 Note that the existing 1996 General Plan does not project households.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Alternative 2 – Concentrated Growth Alternative
Alternative 2, the Concentrated Growth Alternative, would be similar to the Project but would result in a different land use distribution strategy than the Project. Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. Therefore, under Alternative 2, the goals, policies, and implementation actions contained within the proposed General Plan elements would be applicable. Alternative 2 also includes all of the mobility improvements as proposed for the Project throughout the planning horizon of 2045. As with the Project, a Zoning Code Update for Alternative 2 would provide the development standards to implement the General Plan Update.

The Concentrated Growth Alternative is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045. Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project.

Figure 5-1, Land Use Alternatives Conceptual Comparison, illustrates the conceptual land use plan for Alternative 2. The overall land use pattern under Alternative 2 would be similar to that for the Project. Alternative 2 would result in the activation and concentration of new mixed-use growth along commercial corridors and in existing non-residential districts in combination with moderate densification across the Planning Area. Specifically, commercial corridors in the city, such as Washington Boulevard and Sepulveda Boulevard, would be upzoned to allow for higher densities. For example, more area in Fox Hills would be designated as Mixed Use High (MUH) thereby allowing more density in the area. In addition, areas along Sepulveda Boulevard that are designated Mixed Use Corridor 2 (MUC 2) under the Project would be designated Mixed Use Medium (MUM) thereby allowing greater density along the corridor. Areas along Jefferson under Alternative 2 would have less Industrial Mixed Use on Jefferson compared with the Project. Under Alternative 2 along Washington Boulevard In the southern portion of the city would be Mixed Use Corridor 2, allowing greater density compared with the Project.

In addition, as with the Project, Alternative 2 identified opportunity sites. Most properties fronting major corridors, such as Jefferson, Sepulveda, Washington, and Culver Boulevards, as well as all non-residential portions of Fox Hills were considered as opportunity sites. Compared to the Project, the opportunity sites under the Concentrated Growth Alternative would result in greater residential densities and non-residential intensities along the corridors. Implementation of this alternative could result in greater amounts of mixed-use development throughout the city on corridors compared to the Project.

Alternative 3 – Modified Mixed Use High Designation
Alternative 3, the Modified Mixed Use High Designation Alternative, would be similar to the Project but would result in a reduction of residential units and commercial uses in the areas designated as Mixed Use High compared with the Project. The Modified Mixed Use High Designation Alternative is projected to result in approximately 61,170 residents, 27,340 housing units, and 84,090 jobs in Culver City by 2045. Thus, Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. The overall land use pattern under Alternative 3 would be similar to that for the Project. As with the Project, Alternative 3 would accommodate growth through infill development and redevelopment with growth occurring along corridors. Alternative 3 would incorporate mixed-use development on opportunity sites and in the industrial areas. However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum floor area ratio (FAR) would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. In addition, with the reduction of residences there would be a reduction in the amount of incidental commercial floor area, thereby resulting in the reduction of approximately 210 jobs compared with the Project.

Under Alternative 3, the goals, policies, and implementation actions contained within the proposed General Plan elements would be applicable. Alternative 3 would include all of the mobility improvements as proposed for the Project throughout the planning horizon of 2045. As with the Project, a Zoning Code Update for Alternative 3 would provide the development standards to implement the General Plan Update.

ES.6 Summary of Environmental Impacts
Pursuant to Section 15123(b)(1) of the State CEQA Guidelines, Table ES-1, Summary of Project Impacts and Mitigation Measures, briefly describes the Project impacts and the mitigation measures recommended to eliminate or reduce the impacts. The residual impact after mitigation is also identified. Detailed discussions of each of the identified impacts and mitigation measures, including pertinent support data, can be found in the specific topic sections in Chapter 4, Environmental Impact Analysis, of this Draft PEIR.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE ES-1

SUMMARY OF PROJECT IMPACTS AND MITIGATION MEASURES
Environmental Impacts Mitigation Measures Level of Significance

4.1 Aesthetics
Scenic Vistas (Impact AES-1): While there are no designated scenic vistas in the Planning Area, there are long-range views and view corridors which could be impacted during construction and operation of future development that would occur under the General Plan Update. However, future development would be required to comply with the goals and policies of the General Plan Update that protect scenic vistas as well as with all applicable laws, regulations, and standards related to scenic vistas. Therefore, impacts related to a substantial adverse effect on a scenic vista would be less than significant.

N/A Less than Significant
Scenic Quality (Impact AES-2): The Project would not conflict with applicable zoning and other regulations governing scenic quality and impacts would be less than significant.

N/A Less than significant
Light and Glare (Impact AES-3): The Project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. Therefore, impacts would be less than significant.

N/A Less than significant

4.2 Air Quality
Air Quality Management Plan (Impact AIR-1): The Project would result in a potentially significant impact related to a conflict with or obstructing implementation of the applicable air quality plan due to growth that could exceed demographic assumptions for Culver City. While implementation of mitigation measures would serve to reduce the severity of the effects, impacts would remain significant and unavoidable.

Implement MM AQ-1 through MM AQ-5 Significant and Unavoidable Criteria Pollutants (Impact AIR-2): The Project would result in a potentially significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment during construction and operation due to regional emissions that could exceed the SCAQMD significance thresholds. While implementation of mitigation measures would serve to reduce the severity of the effects, impacts would remain significant and unavoidable.

MM AQ-1. Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of NOX, CO, PM10 and/or PM2.5 shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off-Road New Diesel Engine Emission Standards for construction equipment with more than 50 horsepower, unless it can be demonstrated to the Culver City Department of Building and Safety that such equipment is not available. Project sponsors should also consider including zero emissions (ZE) or zero net emissions (ZNE) technologies where appropriate and feasible or higher tier standard diesel equipment as it becomes developed and feasible. Any emissions control device used by the contractor shall achieve emissions reductions that are no less Significant and Unavoidable
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine, as defined by CARB regulations.

Prior to construction, the project engineer shall ensure that all plans for construction phases (e.g., demolition, grading) that would exceed the SCAQMD significance thresholds clearly show the requirement for USEPA and/or CARB Tier 4 or higher emissions standards for construction equipment over 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the construction site for verification by the Culver City Department of Building and Safety. The construction equipment list shall state the makes, models, and numbers of construction equipment on-site. Equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with Section 2449 of the California Code of Regulations, Title 13, Article 4.8, Chapter 9.

MM AQ-2. Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of volatile organic compounds (VOCs) as a result of VOC off-gassing emissions from architectural coatings and industrial maintenance coatings shall require the construction contractor to use SCAQMD Low-VOC and/or Super- Compliant VOC architectural coatings and industrial maintenance coatings such that daily volume of coatings applied would not result in emissions that exceed the SCAQMD significance threshold for VOC, unless it can be demonstrated to the City Department of Building and Safety that such coatings for a required application are not available.

During construction, the construction contractor shall maintain a list of all architectural coatings and industrial maintenance coatings in use on the construction site and the daily volumes of coatings applied for verification by the Culver City Department of Building and Safety.

MM AQ-3. Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the General Plan and Zoning Code Update area, show on the building plans that all major appliances (dishwashers, refrigerators, clothes washers, and dryers) to be provided/installed are Energy Star–certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star or equivalent appliances shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance MM AQ-4. Applicants for new residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the City Planning Area, indicate on the building plans that the feature below has been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• For multifamily dwellings, electric vehicle charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the CALGreen Code (or its successor code).

MM AQ-5. Applicants for new non-residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the City Planning Area, indicate on the building plans that the features below have been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
• Facilities shall be installed to support future electric vehicle charging at each nonresidential building with 30 or more parking spaces.

Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance Substantial Pollutant Concentrations (Impact AIR-3): The Project would result in a potentially significant impact related to exposure of sensitive receptors to substantial pollutant concentrations during construction and operation due to localized emissions and toxic air contaminant emissions that could exceed the applicable significance thresholds. Implementation of mitigation measures would help to reduce the severity of the impacts. However, impacts would remain significant and unavoidable.

Implement MM AQ-1 and MM AQ-3 Significant and Unavoidable MM AQ-6. Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one- quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential localized project construction-related air quality impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing localized significance thresholds (LST) air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the Planning Department.

MM AQ-7. Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one- quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential health risk impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing health risk impacts. If health risk impacts are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City’s Planning Department.

4.3 Biological Resources
Candidate, Sensitive, or Special Status Species (Impact BIO-1): The Project has the potential to impact existing habitats and associated special-status species within the Planning Area during construction and operation of future development. However, with implementation of Mitigation Measures BIO-1 and BIO-2, the Project would result in less than significant impacts related to special-status species.

MM BIO-1: Baseline Biological Assessment. The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats.

The impact analysis will aid in determining any direct, indirect, and cumulative biological impacts from construction and operations, as well Less than Significant with
Mitigation
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance as specific mitigation or avoidance measures necessary to offset significant impacts associated with future projects. The Biological Assessment shall include the following information:
a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region [State CEQA Guidelines, § 15125(c)].
b. A thorough, recent, floristic-based assessment of special status plants and natural communities, following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018);
c. Floristic, alliance- and/or association-based mapping and vegetation impact assessments conducted at the project site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment (Sawyer et al, 2008). Adjoining habitat areas shall be included in this assessment where site activities could lead to direct or indirect impacts off-site. Habitat mapping at the alliance level will help establish baseline vegetation conditions;
d. A complete, recent assessment of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species (Fish & Game Code, §§ 3511, 4700, 5050 and 5515). Species to be addressed should include all those which meet the CEQA definition of endangered, rare or threatened species (State CEQA Guidelines, § 15380); and, e. Identification of focused surveys for special-status plants and/or wildlife that could be directly or indirectly impacted by the project, which shall be conducted in the appropriate season prior to any habitat disturbance.

f. Identification of any aquatic habitats such as rivers, streams, and lakes and their associated natural plant communities/habitats. This includes any culverts, ditches, storm channels that may transport water, sediment, pollutants, and discharge into rivers, streams, and lakes.
g. Avoidance and minimization measures (such as preconstruction wildlife clearance surveys) to fully avoid and otherwise protect sensitive biological resources from Project- related construction and operational impacts shall be identified and implemented. If impacts cannot be avoided, appropriate mitigation measures to offset potential special-status species and habitat impacts shall be identified and implemented.

Executive Summary

General Plan 2045 and Zoning Code Update Project ES-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance MM BIO-2: Nesting Bird Surveys. Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any vegetation removal within the Project site. The nesting bird surveys shall be conducted at appropriate nesting times and concentrate on potential roosting or perch sites. Pre-construction surveys shall be conducted by a qualified biologist no more than 7 days prior to the beginning of any Project- related activity likely to impact raptors and migratory songbirds. If construction activities are delayed or suspended for more than 7 days during the breeding season, the surveys shall be repeated. If nesting raptors and migratory songbirds are identified, the following minimum no disturbance buffers shall be implemented: 100 feet around active passerine (perching birds and songbirds) nests, 300 feet around active raptor nests. These buffers should be maintained until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival.

Riparian Habitat or Sensitive Natural Habitat (Impact BIO-2): The General Plan Update and Zoning Code Update would have no adverse effect on any riparian habitat or sensitive natural community due to the lack of any such habitat within the Planning Area.

N/A No Impact
State or Federally Protected Wetlands (Impact BIO-3): The Project would not have a substantial adverse effect on state or federally protected wetlands or waters. Project impacts would be less than significant.

N/A Less than Significant
Wildlife Corridors or Wildlife Nursery Sites (Impact BIO-4): The Project would not substantially interfere with movement of native resident or migratory fish or wildlife species or with established wildlife corridors due to the lack of wildlife movement corridors within the Planning Area. In addition, the Project would not impede the use of wildlife nursery sites with implementation of Mitigation Measure MM BIO-2 for migratory birds.

Therefore, Project impacts would be less than significant with mitigation incorporated.

MM BIO-2
Less than Significant with
Mitigation
Tree Preservation Policy or Ordinance (Impact BIO-5): The Project would not conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance, within the Planning Area. Therefore, impacts would be less than significant.

N/A
Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.4 Cultural Resources
Historical Resources (Impact CUL-1): The Project would cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5. Therefore, even with implementation of Mitigation Measure MM CUL-1, impacts would remain significant and unavoidable.

MM CUL-1. Prior to development of any project within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Professional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center; a review of pertinent archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified historic resources will be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mitigation for affected historical resources to be implemented prior to their demolition or alteration. Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.

Significant and Unavoidable
Archaeological Resources (Impact CUL-2): Project-related demolition, construction, maintenance, and/or improvement activities would have the potential to cause a potentially significant impact to archaeological resources. Implementation of Mitigation Measure MM CUL-2, standard conditions of approval, and applicable policies in the General Plan Update would reduce impacts to archaeological resources to a less than significant level.

MM CUL-2. Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a qualified archaeologist, defined as an individual meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology, to conduct an archaeological resources assessment. This assessment shall include a records search at the South Central Coastal Information Center; a Sacred Lands File search at the Native American Heritage Commission; and a pedestrian field survey of the project site.

If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for eligibility in the California Register and local register. If a resource is determined to be eligible and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, archaeological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the archaeological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.

Less than Significant with
Mitigation
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.5 Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources (Impact ENG-1): The Project would result in a less than significant impact related to the wasteful, inefficient, or unnecessary consumption of energy resources during construction and/or operation.

N/A Less than Significant
Conflict with State or Local Renewable Energy Plan (Impact ENG-2):

The Project would result in a less than significant impact related to conflicting or obstructing a state or local plan for renewable energy or energy efficiency during construction and/or operation.

N/A Less than Significant

4.6 Geology and Soils
Geologic Hazards (Impact GEO-1): The Project would accommodate growth and development within areas potentially subject to surface rupture within an Alquist-Priolo fault zone, strong seismic shaking, seismic-related ground failure and landslides. However, implementation of the Project would include goals and policies that require adherence to all applicable laws, regulations, and standards related to seismic hazards and would require site-specific geotechnical investigations to address localized geologic hazards. Therefore, impacts would be less than significant.

N/A Less than Significant
Soil Erosion or Loss of Topsoil (Impact GEO-2): The Project would not result in substantial soil erosion or the loss of topsoil. Therefore, impacts related to soil erosion or loss of topsoil would be less than significant.

N/A Less than Significant
Unstable Soils (Impact GEO-3): While some future development under the Project could be located on a geologic unit or soil that is unstable or could become unstable, consistency with all appliable geotechnical and engineering regulations in the CBC and CMCC as well as with the goals and policies of the General Plan Update would minimize risks associated with on- or off-site landslides, lateral spreading, subsidence, liquefaction, or collapse. Therefore, impacts related to unstable soils would be considered less than significant.

N/A Less than Significant
Expansive Soils (Impact GEO-4): While some future development under the Project could be located on expansive soils, compliance with all appliable geotechnical and engineering regulations in the CBC and CMCC as well as consistency with the goals and policies of the General Plan Update would minimize risks associated with expansive soils or subsidence. Therefore, impacts related to expansive soils would be considered less than significant.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance Paleontological Resources (Impact GEO-5): Specific project-related demolition, construction, maintenance, and/or improvement activities would have the potential to cause a potentially significant impact to paleontological resources. Implementation of Mitigation Measure MM GEO-1 and applicable policies in the General Plan would reduce impacts to paleontological resources to a less than significant level.

MM-GEO-1. Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a Qualified Paleontologist, defined as an individual meeting the Society of Vertebrate Paleontology (SVP) Standard, to conduct a site-specific paleontological resources assessment. This assessment shall include a records search at the Natural History Museum of Los Angeles County and/or other appropriate facilities, geologic map and scientific literature review, and a pedestrian field survey (if deemed appropriate by the Qualified Paleontologist). If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for significance pursuant to CEQA, SVP, and/or a local register. If a resource is determined to be significant and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, paleontological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the paleontological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.

Less than Significant with
Mitigation

4.7 Greenhouse Gas
Generate GHG Emissions (Impact GHG-1): The Project would result in a less than significant impact related to GHG emissions.

N/A Less than Significant
Conflict with GHG Reduction Plan, Policy, or Regulation (Impact GHG-2): The Project would result in a less than significant impact related to conflicts with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

N/A Less than Significant

4.8 Hazards and Hazardous Materials
Routine Use, Transportation, and Disposal of Hazardous Materials (Impact HAZ-1): The Project would be required to comply with requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD. Therefore, the Project would result in a less than significant impact related to the routine use, transport, or disposal of hazardous materials.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance Accident and Upset Conditions (Impact HAZ-2): The Project would be required to comply with State law and implement federal, State, and local General Plan Update policies during construction activities, which would ensure that future development allowed under the General Plan Update would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment. Therefore, the Project would result in a less than significant impact related to accident and upset conditions.

N/A Less than Significant
Emit Hazardous Materials Within One-Quarter Mile of a School (Impact HAZ-3): The Project would be required to comply with existing federal, State, and local regulations related to hazardous materials, which would ensure that future development allowed under the General Plan Update would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Therefore, the Project would result in a less than significant impact related to emitting hazardous materials within one-quarter mile of a school.

N/A Less than Significant
Hazardous Materials Sites (Impact HAZ-4): The Project would be required to comply with requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD, which would ensure that future development on a contaminated site does not create a significant hazard to the public or the environment. Therefore, the Project would result in a less than significant impact related to hazardous materials sites.

N/A Less than Significant
Impairment or Interference with Emergency Response Plan (Impact HAZ-5): The Project would not interfere with implementation of the Culver City MJHMP or operations of CCFD, LACFD, CCPD, LACSD, or other agencies that would respond in the event of a disaster or major emergency in Culver City. Therefore, the Project would result in a less than significant impact related to impairment or interference with an emergency response plan.

N/A Less than Significant
Wildland Fire Hazards (Impact HAZ-6): The Project would be required to adhere to building codes and review by CCFD to reduce fire hazards, which would ensure that people or structures are not exposed, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. Therefore, the Project would result in a less than significant impact related to wildland fire hazards.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.9 Hydrology and Water Quality
Violate Water Quality Standards or Waste Discharge Requirements (Impact HYD-1): The Project would contain goals and policies to protect water quality. Construction and operation of future development that would occur under the Project would be required to comply with all applicable laws, regulations, and standards related to water quality and waste discharge. Therefore, the Project would result in less than significant impacts related to violating water quality standards or waste discharge requirements.

N/A Less than Significant
Groundwater Supplies and Groundwater Recharge (Impact HYD-2):

The Project would not deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level.

Therefore, the Project would result in less than significant impacts related to groundwater supplies, the groundwater table level, and aquifer volumes.

N/A Less than Significant
Substantially Alter Drainage Patterns (Impact HYD-3): The Project would not substantially alter the existing drainage pattern of the Planning Area in a manner that would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows. Therefore, impacts related to drainage patterns would be less than significant.

N/A Less than Significant
Release of Pollutant From Inundation by Flood, Tsunami, or Seiche (Impact HYD-4): The risk of release of pollutants as a result of inundation from being located in a flood, tsunami, or seiche zone would be considered extremely low for the Planning Area; therefore, impacts related to the risk of release of pollutants due to inundation from a flood, tsunami, or seiche would be less than significant.

N/A Less than Significant
Conflict with a Water Quality Control Plan or Sustainable Groundwater Management Plan (Impact HYD-5): The Project would not conflict with a water quality control plan or sustainable groundwater management plan and impacts would be less than significant.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.10 Land Use and Planning
Physically Divide a Community (Impact LU-1): The Project would not physically divide an established community. Therefore, the Project would result in a less than significant impact.

N/A Less than Significant
Consistency with Applicable Land Use Plans (Impact LU-2): The Project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Therefore, the Project would result in a less than significant impact.

N/A Less than Significant

4.11 Mineral Resources
Known Mineral Resource, Locally-Important Mineral Resource Recovery Site (Impacts MIN-1 and MIN-2): Since the Planning Area is not within an identified MRZ for significant mineral resources, future growth resulting from implementation of the Project would not impact regionally important aggregate material resources. In addition, the Project would not change the land use designation resulting in future development within the City’s portion of the IOF and thus, would not result in the loss of the regionally- or locally-important oil and gas resources.

Therefore, impacts to mineral resources would be less than significant.

N/A Less than Significant

4.12 Noise
Temporary or Permanent Increase in Ambient Noise Levels (Impact NOI-1): The Project would result in a potentially significant impact during construction and operation of future development projects that could exceed the significance thresholds. Implementation of mitigation would help to reduce the severity of the impacts; however, impacts could still exceed the significance thresholds and impacts would be significant and unavoidable.

MM NOI-1: Construction Noise. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) shall submit a noise study to the City Planning Department for review and approval prior to issuance of a grading or building permit. The study shall include noise-reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards as applicable to construction (i.e., CCMC Chapter 9.07). All noise-reduction measures approved by City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during construction activities. Potential noise-reduction measures may include, but are not limited to, one or more of the following, as applicable to the project:
• Install temporary sound barriers for construction activities that occur adjacent to occupied noise-sensitive receptors.
• Equip construction equipment with effective mufflers, sound- insulating hoods or enclosures, vibration dampers, and other Best Available Control Technology (BACT).
• Limit non-essential idling of construction equipment to no more than five minutes per hour.

Significant and Unavoidable
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance This mitigation measure shall not apply and is superseded once a Citywide noise ordinance goes into effect that establishes construction noise standards for noise-reduction measures that ensures project construction noise compliance with the Culver City Noise Ordinance standards for development projects within the City.

Excessive Groundborne Vibration or Groundborne Noise (Impact NOI-2): The Project would result in a potentially significant impact during construction of future development projects that could exceed the significance thresholds. While implementation of mitigation measures would reduce the severity of the impacts, impacts could still exceed the significance thresholds. Thus, groundborne vibration or groundborne noise during construction would be significant and unavoidable. The Project would result in a less than significant impact related to excessive groundborne vibration or groundborne noise during operation of future development projects.

MM NOI-4.12-2: Construction Vibration. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that are located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) shall submit a vibration impact evaluation to the City Planning Department for review and approval prior to issuance of a grading or building permit. The evaluation shall include a list of project construction equipment and the associated vibration levels and a predictive analysis of potential project vibration impacts. If construction-related vibration is determined to exceed applicable standards, project-specific measures shall be required to ensure project compliance with vibration standards.

All project-specific measures approved by the City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during project construction.

Examples of equipment vibration source-to-receptor distances at which impact evaluation should occur vary with equipment type (based on FTA reference vibration information) and are as follows:
• Jackhammer: 23 feet.
• Dozer, hoe-ram, drill rig, front-end loader, tractor, or backhoe: 43 feet.
• Roller (for site ground compaction or paving): 75 feet. • Impact pile-driving: 280 feet.

This mitigation measure shall not apply and is superseded once a Citywide groundborne vibration ordinance goes into effect that establishes construction groundborne vibration standards for vibration- reduction measures that ensures project construction groundborne vibration compliance with applicable standards for development projects within the City Planning Area.

Significant and Unavoidable
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.13 Population and Housing
Induce Unplanned Population Growth (Impact POP-1): The Project would accommodate regional growth in an orderly manner for the next 25 years and would result in a less significant impact related to inducing unplanned population growth.

N/A Less than Significant
Require Construction of New Housing (Impact POP-2): The Project would increase the overall number of dwelling units in the city as well as include policies that seek to ensure equity and protect diversity in Culver City’s communities and would therefore, result in a less than significant impact related to requiring construction of new housing as a result of displacing substantial numbers of existing people or housing.

N/A Less than Significant 4.14 Public Services
Fire Protection (Impact PS-1.i): The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities as new facilities would be required to comply with existing regulations and Project policies, the concentration of new development would be in areas already well-served by fire protection services, and the Project includes additional policies to reduce fire hazards in the city. Therefore, the Project would result in a less than significant impact related to fire protection facilities.

N/A Less than Significant
Police Protection (Impact PS-1.ii): The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities as new facilities would be required to comply with existing regulations and Project policies, the concentration of new development would be in areas already well-served by police protection services, and the Project includes additional policies to address crime potential in the city. Therefore, the Project would result in a less than significant impact related to police protection facilities.

N/A Less than Significant
Schools (Impact PS-1.iii): The Project would likely result in the need for new or expanded public school facilities due to anticipated population growth and school capacity. However, payment of school impact fees would fully mitigate the impacts of development on school facilities for purposes of CEQA per SB 50. In addition, implementation of CCUSD’s updated Future-Ready Facilities Plan would ensure that there is sufficient capacity to accommodate future public-school students. Therefore, the Project would result in a less than significant impact related to schools.

N/A Less than Significant
Other Public Facilities (Impact PS-1.iv): The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities as new or expanded facilities would be required to comply with existing regulations and Project policies.

Therefore, the Project would result in a less than significant impact related to other public facilities.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.15 Recreation
Deterioration of Existing Recreational Facilities (Impact REC-1): The Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated and would therefore, result in a less than significant impact related to deterioration of existing recreational facilities.

N/A Less than Significant Construction or Expansion of Recreational Facilities (Impact REC-2:

The Project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Therefore, the Project would result in a less than significant impact.

N/A Less than Significant

4.16 Transportation
Conflict with Adopted Circulation Program, Plan, Ordinance, or Policy (Impact TR-1): The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Therefore, the impact would be less than significant.

N/A Less than Significant
Conflict with CEQA Guideline Section 15064.3, Subdivision (b) (Impact TR-2): The Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b). As there are no feasible mitigation measures, the impact would be significant and unavoidable.

No feasible mitigation measures Significant and Unavoidable Incompatible Uses (Impact TR-3): The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) and impacts would be less than significant.

N/A Less than Significant
Inadequate Emergency Access (Impact TR-4): The Project would not result in inadequate emergency access and impacts would be less than significant.

N/A Less than Significant

4.17 Tribal Cultural Resources
Tribal Cultural Resource Significance (Impact TCR-1): The Project would not cause a substantial adverse change in the significance of tribal cultural resources as all future projects would be required to comply with the provisions of SB 18 and AB 52 to incorporate tribal consultation into the CEQA process, which would ensure that tribal cultural resources are properly identified and that mitigation measures are identified to reduce impacts on these resources. Therefore, impacts would be less than significant.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance

4.18 Utilities and Service Systems
New or Expanded Utility Infrastructure (Impact UTL-1): While the Project would not require or result in the relocation or construction of new or expanded water, wastewater treatment, and stormwater drainage facilities, future development under the General Plan Update could require or result in the relocation or construction of new or expanded electric power, natural gas, and telecommunications facilities. However, the construction or relocation of these facilities would not cause significant environmental effects. Therefore, impacts would be less than significant.

N/A Less than Significant
Water Supplies (Impact UTL-2): Sufficient water supplies to serve the Project and reasonably foreseeable future development during normal, single dry, and multiple dry years would not be available. Therefore, the Project would result in potentially significant impact related to water supplies.

No feasible mitigation measures Significant and Unavoidable Wastewater Treatment (Impact UTL-3): The existing wastewater treatment facilities serving the Project would have sufficient capacity to treat the projected wastewater demand generated by the Project.

Therefore, the Project would result in a less than significant impact related to wastewater treatment.

N/A Less than Significant
Solid Waste (Impact UTL-4): The amount of solid waste generated by the Project would not exceed the remaining capacity of existing County landfills and would not impair the attainment of solid waste reduction goals. Therefore, the Project would result in a less than significant impact related to solid waste generation.

N/A Less than Significant
Solid Waste Regulations (Impact UTL-5): The Project would comply with applicable federal, State, and local management and reduction statutes and regulations related to solid waste and therefore, impacts would be less than significant impact.

N/A Less than Significant

4.19 Wildfire
Emergency Response or Evacuation Plans (Impact WF-1): The Project would not substantially impair an adopted emergency response or evacuation plan as development facilitated under the Project would be required to comply with all applicable regulations, plans, and policies related to emergency response plan or emergency evacuation plan.

Therefore, the Project would result in a less than significant impact related to emergency response or evacuation plans.

N/A Less than Significant
Executive Summary

General Plan 2045 and Zoning Code Update Project ES-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Environmental Impacts Mitigation Measures Level of Significance Exacerbate Wildfire Risks (Impact WF-2): Future development that would occur as a result of the General Plan Update and Zoning Code Update would be required to comply with applicable regulations, plans, and policies in place to reduce the risks associated with wildland fires.

Therefore, the Project would result in a less than significant impact related to exacerbating wildfire risks.

N/A Less than Significant Installation or Maintenance of Associated Infrastructure Which Exacerbate Fire Risk (Impact WF-3): Future development allowed under the Project would occur in urbanized and developed areas where existing infrastructure is already in place. In addition, future development allowed under the Project would be reviewed by CCFD as part of the development review process to ensure project compliance with CFC, CBC, and the General Plan and Zoning Code Updates. Therefore, the Project would result in a less than significant impact related to the installation or maintenance of associated infrastructure that could exacerbate fire risk.

N/A Less than Significant
Expose People or Structures to Significant Risks (Impact WF-4):

Future development allowed under the Project would be subject to the applicable regulations and requirements of the City’s Municipal Code as well as policies in the General Plan Update regarding development on unstable geologic soils and controlling stormwater runoff during and after construction. Furthermore, continued implementation of the City’s MJHMP as well as review of development plans by CCFD would ensure that the Project would not expose people or structures to significant risks including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Therefore, impacts would be less than significant.

N/A Less than Significant

General Plan 2045 and Zoning Code Update Project 1-1 SCH No. 2022030144 City of Culver City March 2024
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CHAPTER 1
Introduction
This Draft Program Environmental Impact Report (PEIR) has been prepared in accordance with the California Environmental Quality Act (CEQA) to evaluate the potential environmental impacts of the proposed update to the General Plan, Picture Culver City: General Plan 2045 (General Plan 2045 or General Plan Update) and the associated Zoning Code Update that is necessary to implement the General Plan Update. The General Plan Update and the Zoning Code Update are collectively referred to as the Project. This chapter outlines the purpose and overall approach to the preparation of the Draft PEIR. The City of Culver City (City) is the lead agency responsible for ensuring that the Project complies with CEQA. “Lead agency” is defined by Section 21067 of the State CEQA Guidelines as “the public agency which has the principal responsibility for carrying out or approving a project which may have a significant effect upon the environment”.

1.1 Purpose of the Draft EIR
The primary intent of CEQA is to ensure that public agency decision-makers document and consider the environmental implications of their actions in order to avoid or minimize environmental damage that could result from the implementation of a project wherever feasible, and to balance environmental, economic, and social objectives. In accordance with Section 15121 of the CEQA Guidelines, the purpose of an EIR is to serve as an informational document that:
“…will inform public agency decision-makers and the public generally of the significant environmental effect of a project, identify possible ways to minimize the significant effects, and describe reasonable alternatives to the project.” The purpose of this Draft PEIR is to inform decision-makers and the general public of the potential programmatic environmental impacts resulting from the Project. The City is the Lead Agency under CEQA and is responsible for preparing this Draft PEIR. This Draft PEIR has been prepared in conformance with CEQA (California Public Resources Code [PRC] Section 21000 et seq.), and the State CEQA Guidelines (California Code of Regulations, Title 14, Section 15000 et seq.) and the City’s procedures for implementing CEQA. The principal State CEQA Guidelines sections governing content of this document are Sections 15120 through 15132 (Contents of an EIR), and Section 15168 (Program EIR). This Draft PEIR serves the following purposes:
• To satisfy CEQA requirements for analysis of environmental impacts by including a complete and comprehensive programmatic evaluation of the physical impacts of adopting and implementing the Project;

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General Plan 2045 and Zoning Code Update Project 1-2 SCH No. 2022030144 City of Culver City March 2024
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• To recommend a set of measures to mitigate any significant adverse impacts; • To analyze a range of reasonable alternatives to the Project; • To inform decision-makers and the public of the potential environmental impacts of the Project prior to taking action on the Project, and to assist City officials in reviewing and adopting the General Plan Update and Zoning Code Update; and • To provide a basis for the review of subsequent development projects and public improvements proposed within the Planning Area. Subsequent environmental documents may be tiered from the PEIR.

The Project consists of policies, diagrams, and standards to guide land use and development decisions for the City, as described in greater detail in Chapter 2, Project Description. Chapter 4, Environmental Impact Analysis, of this Draft PEIR contains analysis of all potential environmental impacts expected to result from implementation of the policies and programs provided in the 2045 General Plan Update and the standards and specifications provided in the Zoning Code Update, including those policies that serve to avoid or minimize potentially adverse environmental impacts. In accordance with CEQA requirements, the Draft PEIR also identifies and evaluates mitigation measures in an effort to mitigate potentially significant impacts where feasible. Chapter 5, Alternatives, of this Draft PEIR contains an analysis of alternatives to the Project, including an analysis of the No Project Alternative, which represents the continued implementation of the current General Plan. An environmentally superior alternative has also been identified as part of the alternatives analysis.

1.2 Type of EIR
A program EIR is defined in Section 15168 of the CEQA Guidelines as “An EIR addressing a series of actions that can be characterized as one large project and are related either: (1) Geographically; (2) As logical parts in the chain of contemplated actions; (3) In connection with the issuance of rules, regulations, plans, or other general criteria to govern the conduct of a continuing program; or (4) As individual activities carried out under the same authorizing statutory or regulatory authority and having generally similar environmental impacts which can be mitigated in similar ways”.

Program EIRs can be used as the basic, general environmental assessment from an overall program of future projects, policies, and related implementation actions, such as the Project, intended to be developed or implemented over a 20-year planning horizon. A program EIR has several advantages. First, it provides a basic reference document to avoid unnecessary repetition of facts or analysis in subsequent project-specific assessments. Second, it allows the lead agency to look at the broad, regional impacts of a program of actions before its adoption and eliminates the redundant or contradictory approaches to the consideration of regional and cumulative effects.

As a programmatic document, this Draft PEIR presents an assessment of the potential impacts of the Project across the Planning Area, which includes implementation of the General Plan Update and Zoning Code Update through the year 2045. It does not evaluate project-specific impacts of

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potential future developments that may be proposed by either the City or other entities consistent with the vision of the Project, all of which would be required to comply with CEQA and/or National Environmental Policy Act (NEPA), as applicable.

The preparation of this program-level document does not relieve the sponsors of future development from the responsibility of complying with the requirements of CEQA (and/or NEPA for projects requiring federal funding or approvals). As noted, individual discretionary projects are required to prepare a more precise, project-level analysis to fulfill CEQA and/or NEPA requirements as applicable. The lead agency responsible for reviewing these projects shall determine the level of review needed, and the scope of that analysis will depend on the specifics of the particular project. Pursuant to CEQA Guidelines Section 15152 (Tiering), these projects may, however, use the discussion of impacts in this PEIR as a basis for their assessment of these regional, citywide, or cumulative impacts, provided that the projects are consistent with the General Plan Update and the data and assumptions used in this PEIR remain current and valid.

In accordance with Section 15121 of the State CEQA Guidelines, this Draft PEIR provides information regarding the potential environmental effects associated with the implementation of the General Plan Update and Zoning Code Update and ways to minimize any significant environmental effects through mitigation measures or reasonable alternatives to the Project.

For some effects, significant environmental impacts cannot be mitigated to a level considered less than significant; in such cases, impacts are considered significant and unavoidable. In accordance with Section 15093 of the State CEQA Guidelines, if a public agency approves a project that has significant impacts that are not substantially mitigated (i.e., significant unavoidable impacts where impacts cannot be mitigated to less than significant levels), the agency must state in writing the specific reasons for approving the project, based on the Final PEIR and any other information in the public record for the project. This is known as a “statement of overriding considerations.”
This document analyzes the environmental effects of the Project to the degree of specificity appropriate to the Project, as required under Section 15146 of the State CEQA Guidelines. The analyses focus on the secondary effects that can be expected to follow adoption of the General Plan Update and Zoning Code Update, but will not be as detailed as the analysis required for future specific development projects that may follow. This Draft PEIR discusses both the direct and indirect impacts of this Project, as well as the cumulative impacts associated with other past, present, and reasonably foreseeable future projects.

1.3 Intended Uses of the PEIR
Section 15124(d) of the CEQA Guidelines require EIRs to identify the agencies that are expected to use the EIR in their decision-making, and the approvals for which the EIR will be used. This PEIR will inform the City, in addition to other responsible agencies, persons, and the general public, of the potential environmental effects of the Project and the identified alternatives. The City will use the PEIR as part of its review and approval of the proposed 2045 General Plan Update and Zoning Code Update. The City would review subsequent discretionary

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General Plan 2045 and Zoning Code Update Project 1-4 SCH No. 2022030144 City of Culver City March 2024
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implementation projects for consistency with the PEIR and prepare appropriate environmental documentation pursuant to CEQA provisions for PEIRs and subsequent projects. Subsequent projects under the PEIR may include the following implementation activities: Specific Plans; Development Plans including tentative maps, variances, conditional use permits, and other land use permits; Facility and Service Master Plans, Funding of Public Improvement Projects, Development Agreements, and other permits and approvals necessary for implementation of the Project or other public and private development projects.

This program-level EIR does not evaluate the project-specific impacts of individual developments that may be allowed under the Project. Pursuant to CEQA Section 15152, subsequent projects that are consistent with the General Plan Update may “tier” from this PEIR, relying on the environmental analysis and mitigation measures it contains in order to streamline environmental review or to focus on project-specific environmental effects not considered in this Program EIR, if any. Additionally, subsequent projects that satisfy the requirements of CEQA Section 15182 or 15183 may be eligible for streamlined environmental review.

This PEIR serves as the environmental document for all discretionary actions associated with adoption of the General Plan Update and Zoning Code Update. This PEIR is intended to be the primary reference document in the formulation and implementation of a Mitigation Monitoring and Reporting Program (MMRP) for the Project. This PEIR is also intended to assist other responsible agencies in granting approvals that may be required for implementation of the Project. Federal, State, regional, and local government agencies that may have jurisdiction over development proposals in the Planning Area include the City of Culver City, U.S. Fish and Wildlife Service, U.S. Army Corps of Engineers, California Department of Fish and Wildlife, California Department of Conservation, California Department of Housing and Community Development, California Department of Transportation, State Lands Commission, State Water Resources Control Board, Southern California Association of Governments, South Coast Air Quality Management District, Metropolitan Water District of Southern California, Sanitation Districts of Los Angeles County, County of Los Angeles, Los Angeles Metropolitan Transit Authority, Culver City Unified School District, and the Los Angeles Department of Water and Power.

1.4 EIR Scoping Process

1.4.1 Background
The City initiated the General Plan Update process in 2019 with a series of community outreach events and launch of the project website (pictureculvercity.com). Since that time, City staff and the planning consulting team have completed studies, evaluations, and community outreach events, information on which is available on the project website.

The planning process has been guided by a General Plan Advisory Committee (GPAC), established in 2018, with several meetings of the Planning Commission and the City Council at key stages. The GPAC has 21 members appointed by City Council. Its primary roles are to provide insight to the project team on how to address key issues and understand sensitive community needs; review and provide comments on General Plan Update work products; and inform the community of the process and help to build community support for and engagement with the

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General Plan Update process. Along with the GPAC, a series of topic-specific technical advisory committees (TACs) are exploring innovative ideas and topics for the General Plan Update. These informal TACs cover topics, such as housing; transportation and mobility; quality of life issues, such as sustainability, health, and parks; culture and arts; economic development; and policing and public safety. TAC members are volunteer positions and all who expressed interest were included on one of the TACs in Fall 2020.

The General Plan Update process has gone through multiple steps to culminate into the current draft plan, including:
• Existing Conditions. Review existing policies and reports, identify issues and opportunities. • Listening and Visioning. Develop long-term vision and guiding principles via stakeholder meetings, meetings with City bodies, stakeholder interviews, engagement with the GPAC, engagement with TACs, community workshops, online engagement and surveys, and tactical urbanism demonstration projects.
• Alternatives. Create and refine land use and transportation alternatives, including identifying the community’s preferred land use plan.
• Policy and Plan Development. Develop policies that support the preferred vision. • Draft and Final Program Environmental Impact Report (PEIR). Includes preparing a Draft PEIR for the General Plan Update and responding on comments received on this draft to produce the Final PEIR.
• Housing Element. The Housing Element for the 6th Cycle (2021–2029) was adopted separately by the City Council in August 2022.

In compliance with the State CEQA Guidelines, the City has taken steps to provide opportunities for the public to participate in the environmental process. During the preparation of the Draft PEIR, an effort was made to contact various State, regional, and local government agencies and other interested parties to solicit comments and inform the public of the Project.

1.4.2 Notice of Preparation
Pursuant to the provision of CEQA Guidelines Section 15082, the City circulated a Notice of Preparation of an Environmental Impact Report and Community Meeting/EIR Scoping Meeting (NOP) to State, regional, and local agencies, and members of the public for a 34-day period commencing March 1, 2022 and concluding on April 4, 2022. The purpose of the NOP was to provide formal notice that the City was preparing a Draft PEIR for the General Plan Update, to present the environmental topics preliminarily identified by the City for evaluation in the Draft PEIR, and to solicit input regarding the scope and content of the information to be included in the Draft PEIR.

In order to maintain compliance with the recently adopted housing element and to comply with state law, the city expanded the scope of the project to include the Zoning Code Update, which implements the Housing Element and proposed General Plan Update. As a result, the city issued

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General Plan 2045 and Zoning Code Update Project 1-6 SCH No. 2022030144 City of Culver City March 2024
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a Recirculated NOP for a 33-day period commencing on February 15, 2024 and ending on March 18, 2024.

Both NOPs included notification that a public scoping meeting would be held to further inform public agencies and other interested parties of the Project and to solicit input regarding the Draft PEIR. The City posted the NOPs on the City Planning website along with information regarding the process for providing comments. The NOPs, Initial Study, and comments received during the scoping processes are included in Appendix A of this Draft PEIR (as Appendix A-1, A-2, and A-3, respectively).

1.4.3 Public Scoping Meeting
The City conducted a virtual public scoping meeting on March 24, 2022 at 6:00 p.m. using Zoom.

As a result of the Recirculated NOP, a second virtual public scoping meeting was held on March 7, 2024 at 6:00 p.m. using Zoom. The public scoping meetings provided interested individuals, groups and public agencies the opportunity to provide oral and written comments to the lead agency regarding the scope and focus of the Draft PEIR as described in the NOPs. The meetings included a presentation by the City and their environmental consultant that included an overview of the Project, information regarding the CEQA process and opportunities for public input, issues identified for analysis in the Draft PEIR, and solicitation of oral and written comments on environmental issues and alternatives the public would like to see evaluated in the Draft PEIR.

1.4.4 Comments Received
Comments on the scope and content of the Draft PEIR were received in writing during the 34- day circulation period for the NOP. No verbal or written comments related to the Draft PEIR were received at the virtual scoping meeting, and eight written comment letters responding to the NOP were submitted to the City. Copies of the comment letters received during the NOP circulation period are provided in Appendix A of this PEIR and are summarized in the Executive Summary, in the subsection entitled Areas of Controversy and Issues to be Resolved.

Comments on the scope and content of the Draft PEIR were also received in writing during the 33-day circulation period for the Recirculated NOP. [Note to City: To be added after end of scoping comment period and review of comments] Copies of the comment letters received during the Recirculated NOP circulation period are provided in Appendix A of this PEIR and are summarized in the Executive Summary, in the subsection entitled Areas of Controversy and Issues to be Resolved

1.5 Scope of the PEIR

1.5.1 Baseline and Planning Horizon
For analytic purposes in this Draft PEIR, the baseline year established for existing conditions is 2019 unless otherwise noted and the horizon year representing future conditions is 2045. In cases where current data is not available, the most recent known data is used to depict baseline

1. Introduction

General Plan 2045 and Zoning Code Update Project 1-7 SCH No. 2022030144 City of Culver City March 2024
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conditions. The horizon year of 2045 represents the target year of the Project when projects and programs identified in the General Plan Update are anticipated to be fully implemented.

1.5.2 Environmental Issue Areas
This Draft PEIR assesses the potential environmental impacts that could occur with implementation of the Project. Section 15064 of the CEQA Guidelines states that in evaluating the significance of the environmental effect of a project, the Lead Agency shall consider direct physical changes in the environment which may be caused by the project and reasonably foreseeable indirect physical changes in the environment which may be caused by the project.

The scope of the Draft PEIR includes evaluation of potentially significant environmental issues raised in response to the NOPs and during scoping discussions. As noted above, the NOPs and all comment letters received during the comment period are included in Appendix A. Based on the scoping process, the following environmental issue areas are addressed in detail in this Draft PEIR:
• Aesthetics
• Air Quality
• Biological Resources
• Cultural Resources
• Energy
• Geology and Soils
• Greenhouse Gas Emissions
• Hazards and Hazardous Materials
• Hydrology and Water Quality
• Land Use and Planning
• Mineral Resources
• Noise
• Population and Housing
• Public Services
• Recreation
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
• Wildfire
CEQA Guidelines Section 15128 requires a statement briefly indicating the reasons that various possible significant effects of a project were determined not to be significant and were therefore not discussed in detail in the Draft PEIR. Pursuant to CEQA Guidelines Section 15128 (Effects Not Found to Be Significant) environmental impacts related to agricultural and forestry resources were not considered significant and therefore, are not fully discussed in the Draft PEIR. (See Chapter 6, Other CEQA Considerations, for a brief summary). In addition, Chapter 6 addresses environmental topics required by CEQA that are not covered within the other chapters of this EIR, including: (1) significant unavoidable impacts, (2) irreversible environmental changes, (3) growth inducing impacts, and (4) potential secondary effects.

Consistent with CEQA Guidelines (Section 15126.6[d]), this Draft PEIR includes the assessment of a reasonable range of alternatives to the Project that could feasibly attain most of the Project objectives while avoiding or substantially lessening the environmental effects of the Project.

This analysis is included in Chapter 5, Alternatives.

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1.6 Format of the Draft PEIR
The Draft PEIR includes an Executive Summary, eight Chapters, and appendices, which are organized as follows:

ES, Executive Summary, provides an overview of the entire document in a concise, summarized format. It briefly describes the Project (location and Planning Area), the CEQA review process and focus, identifies effects found to be significant and unavoidable, identifies areas of controversy, provides a summary of the Project alternatives (descriptions and conclusions regarding comparative impacts), and provides a summary of Project impacts, and mitigation measures, and the level of impact significance following implementation of mitigation measures.

Chapter 1, Introduction, describes the purpose and use of the PEIR, provides a brief overview of the Project and the environmental review process, and outlines the organization of the PEIR.

Chapter 2, Project Description, describes the location and Planning Area, objectives, buildout, and the goals, programs, and policies for implementation of the Project.

Chapter 3, Environmental Setting, provides a generalized overview of the existing physical environmental setting in which the Planning Area is located. This overview of the existing physical environment generally serves as the environmental baseline for the analysis of potential environmental impacts under CEQA. This section also includes a discussion of the methodology for analyzing potential cumulative impacts.

Chapter 4, Environmental Impact Analysis, contains the environmental setting, Project and cumulative impact analyses, mitigation measures, and conclusions regarding the level of significance after mitigation for each of the environmental topic areas indicated above.

Chapter 5, Alternatives, evaluates the environmental effects of feasible project alternatives, including the No Project Alternative. This section also identifies the environmentally superior alternative.

Chapter 6, Other CEQA Considerations, includes a discussion of environmental topic areas required by CEQA that are not covered in other chapters. This includes unavoidable adverse impacts, impacts found not to be significant, irreversible environmental changes, potential secondary effects caused by the implementation of the mitigation measures for the Project, and growth inducing impacts.

Chapter 7, References, identifies the references and sources used in the preparation of this PEIR.

Chapter 8, List of PEIR Preparers and Organizations/Persons Contacted, lists the individuals involved in preparation of this PEIR and persons, public agencies, and organizations that were consulted or who contributed to the preparation of this PEIR.

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The environmental analyses in this PEIR are supported by the following appendices:
• Appendix A: Notice of Preparation, Initial Study, and Scoping Comments and Responses – A-1: NOP and Recirculated NOP
– A-2: Initial Study
– A-3: Scoping Comments from NOP and Recirculated NOP
• Appendix B: Air Quality Worksheets
• Appendix C: Biological Resources Database Search Results • Appendix D: Energy Data
• Appendix E: Greenhouse Gas Emissions Worksheets
• Appendix F: Noise Measurement Data
• Appendix G: Traffic Data and VMT Analysis Methodology – G-1: CEQA Transportation Analysis Memorandum
– G-2: VMT Traffic Data
• Appendix H: Native American Consultation

1.7 Public Review of the Draft PEIR
The Draft PEIR is subject to a 45-day review period in which the document is made available to responsible and trustee agencies and interested parties. In compliance with the provision of Sections 15085(a) and 15087(a)(1) of the State CEQA Guidelines, the City, serving as the Lead Agency: (1) published a Notice of Availability (NOA) of a Draft PEIR which indicated that the Draft PEIR was available for review at the City‘s Current Planning Division (9770 Culver Boulevard, Culver City, CA 90232); (2) posted a copy of the NOA and Draft EIR on the City’s website (https://www.culvercity.org/Have-Your-Say/A-Picture-Culver-City-General-Plan-2045); (3) prepared and transmitted a Notice of Completion (NOC) to the State Clearinghouse; (4) sent a NOA to NOP commenters as well as the last known name and address of all organizations and individuals who previously requested such notice in writing. Proof of publication is available at the City. The public comment period begins on [Month XX, XXX], and will end on [Month XX, XXX].

The Draft EIR is available for review online at the City’s Advance Planning Division’s website at:
https://www.culvercity.org/Have-Your-Say/A-Picture-Culver-City-General-Plan-2045. Hardcopies of the Draft EIR are available for review at City Hall, as well as the Culver City Julian Dixon Library.

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General Plan 2045 and Zoning Code Update Project 1-10 SCH No. 2022030144 City of Culver City March 2024
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Any public agency or members of the public desiring to comment on the Draft PEIR must submit their comments in writing or send them via email to the following address prior to the end of the public review period:

Mail: Troy Evangelho, AICP, Advance Planning Manager
City of Culver City Advance Planning Division
9770 Culver Boulevard
Culver City, CA 90232
Phone: (310) 253-5740
Email: [email protected]
Upon the close of the Draft PEIR public review period, the City will evaluate and prepare responses to all written comments related to environmental issues and the adequacy of the Draft PEIR received during the public review period. A Final PEIR will then be prepared. The Final PEIR will consist of the Draft PEIR, any necessary revisions to the Draft PEIR, written comments received during the public circulation period for the Draft PEIR, and City responses to those comments.

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CHAPTER 2
Project Description

2.1 Introduction
Consistent with Section 15168 of the State CEQA Guidelines, this Draft Program Environmental Impact Report (Draft PEIR) provides a programmatic analysis of the environmental impacts associated with implementation of the goals and policies and the projected buildout of the comprehensive update to the General Plan, Picture Culver City: General Plan 2045 (General Plan 2045 or General Plan Update) and amendments to the City’s Zoning Code that are necessary to implement the General Plan Update. These collectively are referred to as the Project.

California Government Code Section 65300 et seq. mandates that all counties and incorporated cities prepare a general plan that establishes policies and standards for future development, housing affordability, and resource protection. State law encourages cities to keep general plans current through regular updates. The Project includes the first comprehensive update of all nine elements of the Culver City General Plan. Previously, the City’s various General Plan elements have been updated between 1968 and 2014. The General Plan Update would provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its Sphere of Influence (SOI), through the planning horizon year of 2045. Together with the Zoning Ordinance and related sections of the Municipal Code, the 2045 General Plan would serve as the basis for planning-related decisions made by City staff, the Planning Commission, and the City Council.

By law, a general plan must be an integrated, internally consistent statement of City policies.

Government Code Section 65302 requires that a general plan include the following seven elements: Land Use, Circulation, Housing, Conservation, Open Space, Noise, and Safety. Senate Bill (SB) 1000 and Government Code Section 65302 require that since disadvantaged communities have been identified within the City, the Plan must also address Environmental Justice (EJ) either as a standalone element or integrating related goals, policies, and objectives throughout other elements. The General Plan Update includes a Community Health and Environmental Justice element. Additional elements may be included as well, at the discretion of the City. The General Plan Update includes six optional elements: Governance and Leadership; Arts, Culture, and Creative Economy; Economic Development; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction; and Infrastructure. All elements have equal weight, and no one element supersedes another. Cities may amend the general plan four times a year (each amendment may include any number of changes), and cities are encouraged to keep the plan current through regular updates.

2. Project Description
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The Project also includes incorporation of the City’s recently adopted 2021–2029 Housing Element Update, which provided an update to the previous 2013–2021 Housing Element. The Housing Element is one of the State-mandated elements that must be included in the City’s General Plan. State law stipulates that the Housing Element include certain items, such as a Housing Needs Assessment; goals, policies, and objectives regarding housing in City; and implementation programs to work toward achieving those goals. On December 17, 2021, the City adopted a Negative Declaration for the 2021–2029 Housing Element Update, outlining the plan for accommodating the City’s share of the regional housing need. For the SCAG 6th Cycle Housing Element planning period of 2021–2029, the City received a Regional Housing Needs Allocation (RHNA) of 3,341 units. Per State mandate, the City must zone sufficient land for housing affordable to people at all income levels.

This chapter introduces the purposes and objectives of the Project and summarizes specific information describing the General Plan Update. This includes a description of the existing regional and local project setting; an outline of the projected population and employment growth rates, and development patterns through the 2045 planning horizon year; the proposed land use diagram; key data tables; and key policy directions. These aspects of the Project provide the basis for the environmental analysis in Chapter 4, Environmental Impact Analysis.

2.2 Regional Location and Existing Setting

2.2.1 Regional Location
Culver City is located in the western area of Los Angeles County in Southern California, as shown in Figure 2-1, Regional and Project Vicinity. The City comprises about 5 square miles (13 square kilometers) and is bounded by the City of Los Angeles to the north, west, and south, and by unincorporated areas of Los Angeles County along its eastern boundary. Culver City is situated approximately five miles east of the Pacific Ocean, five miles north of Los Angeles International Airport (LAX), and eight miles west of downtown Los Angeles. Interstate 405 (I-405) runs in a north-south direction in the western part of the city and Interstate 10 (I-10) runs in an east-west direction just outside of the city to the north. State Route 90 (SR-90) intersects Culver City from the west and ends at Slauson Avenue.

2.2.2 Planning Area
The General Plan Planning Area, as shown in Figure 2-2, Planning Area, includes the city of Culver City and its unincorporated Sphere of Influence (SOI). The Planning Area includes approximately 3,910 acres of land, including approximately 3,280 acres of land (84 percent) within the City’s jurisdictional boundaries and approximately 630 acres of land (16 percent) in its SOI. The SOI includes land within unincorporated portions of Los Angeles County located adjacent to the City. The SOI is located to the east of the City boundary in the Baldwin Hills area of Los Angeles County, west of La Cienega Boulevard.

Santa Monica
El Segundo
Manhattan
Beach
Lawndale
Gardena
Glendale
Hawthorne
Lynwood
South Gate
Cudahy
Inglewood
Huntington
Park
Maywood
Compton
Vernon
West
Hollywood
Beverly Hills
Bell
Culver
City
Regional Context
° 024 1
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021);
LA Metro (2023); ESRI (2021).

City Limits
Sphere of Influence
Metro Stations
Metro Lines
Freeway/Highway
Regional Parks and Open Space
Waterbody

FIGURE XX
Pacific Ocean
Los Angeles County
§¨¦405
§¨¦105
§¨¦405
§¨¦110
§¨¦5
§¨¦10
§¨¦10
Los Angeles
FIGURE 2
Culver City General Plan 2045
Figure 2-1
Regional and Project Vicinity
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator GreenValleyCir
Planning Area
°0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 1
11User Guide
GreenValleyCir
Planning Area
°0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 1
11User Guide Culver City General Plan 2045
Figure 2-2
Planning Area
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

2.2.3 Existing Setting and Land Uses
The current General Plan includes nine elements, which have been updated between 1968 and 2014, providing the current goals and policies, including land use designations, that govern the Planning Area. The City is generally divided into 15 neighborhoods as shown on Figure 2-3, Planning Area Neighborhoods.

Existing developed land uses in the Planning Area include single family residential (28.8 percent); oil field (13.9 percent); retail and service uses (10.9 percent); and civic and institutional uses, which include places of worship, public and private schools (including West Los Angeles College), libraries, City Hall, police and fire stations, and other public uses (10.5 percent). The existing General Plan Land Use Map is shown in Figure 2-4, Existing General Plan Land Use Map. Table 2-1, Existing General Plan Land Use Designations, provides the current land use designations that apply throughout the Planning Area with the acreage and percentage of land coverage for each designation.

TABLE 2-1

EXISTING GENERAL PLAN LAND USE DESIGNATIONS
Land Use Designation Acres Percentagea
Residential 1,408.1 44.0
Low Density Single Family 733.6 22.9
Low Density Two Family 233.3 7.3
Low Density Three Family 4.3 0.1
Low Density Multiple Family 91.5 2.9
Medium Density Multiple Family 186.0 5.8
Planned Residential Development 159.5 5.0
Commercial 501.1 15.7
Neighborhood Serving Corridor 23.2 0.7
General Corridor 213.4 6.7
Downtown 20.1 0.6
Community Serving Center 21.8 0.7
Regional Center 222.5 7.0
Industrial 226.6 7.1
Industrial 135.6 4.2
Industrial Park 57.7 1.8
Light Industrial 33.4 1.0
Open Space 633.0 19.8
Cemetery 238.6 7.5
Studio 113.2 3.5
Ballona Creek 72.8 2.3
Institutional 3.5 0.1
Total
b 3,196.9 100.0
a The area is calculated for land within the Planning Area. b Totals may not add due to rounding.

SOURCES: City of Culver City, 2019; Raimi + Associates, 2019.

City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2021); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa rkw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Neighborhoods
Blair Hills
Blanco/Culver Crest
Clarkdale
Culver/West
Downtown
Fox Hills
Jefferson
Lucerne/Higuera
McLaughlin
McManus
Park East
Park West
Studio Village
Sunkist Park
Washington Culver
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2021); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County )
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa r kw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Neighborhoods
Blair Hills
Blanco/Culver Crest
Clarkdale
Culver/West
Downtown
Fox Hills
Jefferson
Lucerne/Higuera
McLaughlin
McManus
Park East
Park West
Studio Village
Sunkist Park
Washington Culver
Culver City General Plan 2045
Figure 2-3
Planning Area Neighborhoods
SOURCE: City of Culver City (2021); County of Los Angeles (2021); ESRI (2021).D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 0 0.5 1
Miles
©
SCALE 1:8,500
The City of Culver City makes no representation or warranties of any kind with respect to the accuracy of the information of claims furnished herein, as the data is a compilation of records and information obtained from various sources. The data displayed on this map is for representational purposes only. It is neither a legally recorded map nor a survey and is not intended to be used as such. No part of this map may be reproduced or transmitted in any f orm or by any means, electronic or mechanical, including photocopying and re
cording systems except as expressly permitted in writing by the City of Culver City, Information T echnology Department, Geographic Information Systems. © City of Culver City. All Rights Reserved.

INFORMATION TECHNOLOGY DEPARTMENT

GEOGRAPHIC INFORMATION SYSTEMS
9770 CULVER BLVD
CULVER CITY, CA 90232
TEL: 310-253-5950
August 28, 2007

GENERAL PLAN

LAND USE

ELEMENT MAP
City of
*This version of the Land Use Element Map has been updated as of City Council Resolution No. 99-R105, adopted 13 December 1999, regarding General Plan Land Use Element Map Amendment, GPMA P-1999016 / 12101 Washington Boulevard.
§¨¦405
!(90
§¨¦10

COLLEGE
AV

OREG ON AV

WAGNER ST

LINDBLADE ST
BARMAN
AV

BRADDOCK
DR

WAGNER ST

LINDBLADE ST

ETHELDO AV

BARM AN AV

COOMBSAV

HERBERT ST

EAST BL
HURON
AV

ALETTA AV

GIRARD AV
RO
SABELL
ST

WASHINGTON BL
17 VELVET LN

STEVENS
CR

AUGUSTI N LN
ST. JAMES DR

WINDSOR WY

COR PO RATE POINTE

LEEVIEWCT

JACKSO N AV

WASHINGTON BL

WASHINGTON PL

WASHINGTON BL

BRADDOCK DR
GRAND
VIEW
BL
BOISE
AV

WASATCH AVCOLO NIAL AV

MIDWAY AV
STAR
CR

HUNTLEYAV

BERRYMAN AV

COOLIDGE AV

MCLAUGHLIN AV

TULLER AV

HURO N AV
CU
LVER B
L

ASTAIRE AVSKELTON CR

COOGAN CR

MARIETTA AV

WASHINGTON BL

ARIZONA
AV

COMMONWEALTH AV

FARRAGUT DR

MILTO N AV
TILDEN
AV
GAR
LAND
DR
P
A
LM
CO
U
RT WY
M
C
CO
NNELL
BL
M
ILDRED
AV

MOORE ST

CHASE AV

CAMPBELL DR

KENYON AV

GLOBE AV

GARLAND DR

PURDUE AV

VENICE BL

CULVER BL

MAYTIME

BALDWIN AV
OCEAN

STUDIO DR
JASM
INE
AV

VIRGINIA

PEARSON ST

LEAHY ST

FARRAGUTDR

PARK AV
DR
2 1
13 14

VENICE BL

RAINTREE
CR
13 CORNER RD
13 M
A
YTIME
LN
LN
AV

BRADDOCK DR

GARFIELD
AV

COOMBSAV

MENTONE
AV
LE

BOURGETAV
MOTOR
AV
VINTON
AV

JASMINE
AV

WASHINGTON BL
LOUISE
AV

CULVER BL

KEYSTO NE AV

SUMMERTIME LN

MOTO R AV

VINTO N AV

JACKSO N AV

REVERE PL

LE BO URGET AV

MENTONE AV
6 7
5 8
HOLLOW 1110
3 4

LINCO LN AV

DUQUESNE AV

INDIAN WOOD RD

SUMMERTIME LN

KINSTON AV

FRANKLIN
AV

FARRAGUT
DR

LA SALLE AV

FARRAGUT
DR
EMER
A
LD
W
Y

KEYSTONE
AV
JORDAN
W
Y
15 9
19 18
12 16
17 HARG IS ST

WESLEY ST

BLACKWELDER ST

SMILEY DRHUTCHISON AV FAY AV
M
C
M
ANUS
AV

HIGUERA ST

WARNER ST

STELLER DR

HELMS AV

SCHAEFER ST

HAYDEN AV

ERNEST AV

DAVID AV
FAY AV

EXPOSITION BL

SENTNEY AV

LA CIENEGABL

JACOB ST

CATTARAUGUS AV

SHERBOURNE DR

CARO LINE AV

HELMS AV

LANDMARK ST

NATIONAL BL

DAUPHIN
AV

PERRY DR

HINES AVADAMS BL

EASTHAM DR

RODEO RD

LA CIENEGA AV

REID AV

ROBERTS AV

MC M ANUS AV
P
E
R
H
A
M
DR

CAROLCTW

RIGHT TR
LENAW
EE
AV

VICSTONE CT

WRIGHTCREST DR
HOKE
AV

HOLLYVIEWTRHOWARDVIEWCTW

RIGHTCRE
S
T DR

CANFIELD AV

INCE BL

KRUEGER
ST
HUBBAR
D
ST
CARSON
ST
W
ILLAT
AV

SEPULVEDA BL

JEFFERSON BL
LA
C
IEN
EG
A
BL
VAN
BUREN
PL

WESLEY ST

LINDBLADE ST

POINSETTIA
CT

LUCERNE AV

FARRAGUT DR

LUCERNE
AV

HAYDEN PL

STONEVIEW DR
IVY WY

CRESTVIEW RD

VERHALEN
CT

BLAIRSTONE DR

CLARINGTON
AV
HUGHES
AV

SEPULVEDA BL

DELMAS TER

CARDIFF AV

MAIN ST

IRVING PL

LAFAYETTE PL

HIGUERA ST

MADISON AV

ROBERTSON BL

WATSEKA AV

JEFFERSON BL
JEANPL

JASMINE
AV

SHEDD TR

SHERBOURNE DR

CATTARAUGUS AV

HELMS AV

WASHINGTON BL
W
ESTW
OOD
BL
KAREN
CR
WY

OVERLAND AV

RHODA WY

KINSTON AV

NORTHGATE ST
S T
DRAKEW
O
O
D

WHITBURN
GALVIN

FLAXTO N ST
ST

STEVER ST

KELMORE ST
W Y

LUGO W Y

TELLEFSO
N
RD
M
O
LO
NY
RD
M
ALATAV
STEVEN
S
AV
HANNU
M
HAYTER
AV

RYANDALE DR

PATOM DRORVILLE
S
T

SEGRELL
W
Y

SEGRELL WY
R
UDM
AN
D
R
G

RAYRIDG
E
DR
PLAYA
CT

SELMARAINE DR

EMPO RIA AV

EMPORIA AV

PURDUE AV
CULVER
PARK
DR

SAWTELLE BL
W
OOLFO
R
D
ST

BANKFIELD AV

SELMARAINE DR

FOX HILLS DR

PATOM D
R

PLAYA ST

CAMBRIDGE WY

SUMNER WY
M
C
DONALD
S
T

BLANCO WY

JANISANN AV

BERRYMAN
AV

DAWES AV

COOLIDGE
AV

BERRYMAN AV

DOVERWOOD DR

BUCKINGHAM PK

COTA ST

DOBSON WY

SLAUSON AV

KINSTON
AV

EL RINCON
WY

STEVER CT
BERNA
RDO
RD
EVEW
ARD
RD
LIN DA

HILL RD

STEPHON
TR

STUBBS LN

DESHIRE
PL

CLARMON PL

CULVIEW ST

BUSH WY

KALEIN DR

HANNU M AV

KENSINGTO N
WY
BUCKIN
G
HA
M
PK

FOX HILLS MALL
DILLER
AV
PORT
RD

CULVER PARK DR
WY
HANNUM
AV

HAMMACK ST

BRISTOL PKWY

CANTERBURY DR
GREEN

VALLEY CR

SOUTH D R
NORTH

UPLA NDER WY
UPLAN
DER
W
Y

BRISTOL PKWY
C
O
R
R
YNE
PL

EMPO RIA
PL

ESTERINAWY
YO
UNG
W
O
RTH RD
PO
RTRD

FAIRBANKS
W
Y

FOX HILLS MALL

BALLONA LN

LANTANA LN

MICHAEL AV
MOORE
ST

REDWO OD AVTIVOLI AV

ALLA RD

LYCEUM AV

MEIER ST

WALG ROVE AV

MITCHELL AV

FRANKLIN
AV

MESM ER AV

OVERLAND AV

MATTESON AV

SEPULVEDA BL

PIGOTT DR

BLEDSO E AV

COOMBSAV
R
D
STO
NYCREE
K

MELVIL ST

ETHELDO AV
AV
PICKFO
RD

MACHADO RD
DR

RANCH RD
CRANKS
RD

TO MP KINS WY
COMEY
AV
ZANJA
ST

WALNUT AV

BEETHOVEN ST

GLENCOE AV
1 SALEM VILLAGE DR
3 SALEM VILLAGE CT

CENTINELA AV
M
AR
CASEL
AV
ELENDA

STTULLER
AV

ARVEE ST

GLOBE AV

TULLER AV

GLOBE AV

HEPBURN CR

SHORT AV

MAXELLA AV

LOUISE AV

ATLANTIC
AV

HURO N AV
7 COPPERFIELD LN
4 TIMBER LAKE LN
9 SHOWBOAT LN
2 SALEM VILLAGE PL
5 WILDERNESS LN
10 RAINBOW'S END
12 CIMMARON LN
6 HUCK FINN LN
8 GASLIGHT LN
18 CASCADE CT
14 ST. LOUIS CT
15 BUTTERFIELD CT
11 SHOWBOAT PL
16 BOUNTY LN
19 TARA TR
13 RAINTREE CR

KENSINGTON
RD

COOLIDGE AV

BERRYMAN AV

MINERVA AV

BLEDSO E AV

ALBRIGHT AV

BENTLEY AV
TILDEN
AV
HARTER
AV

CHARLES AV

WADE ST

NEOSHO AV
MC
DONALD
ST

GARFIELD AV

HUNTLEY PL

HERBERTWY
GRAND
VIEW
BL

COMMONWEALTH
CR

GARFIELD AV

HERBERT ST

WASHINGTON PL

FAIRFAX AV

HERITAGE PL

JEFFERSON BL

SEPULVEDA BL

SLAUSON AV

CENTINELA AV

FRANKLIN
AV

COMMO NWEALTH AV

CENTER ST

HARTER AV

MIDWAY AV

CULVER CENTER DR

WESTWOOD BL
SPAD
PL

PROSPECTAV

MATTESON AV
SAW

TELLEBL

ALBRIGHT AV
LAMARR
AV

CORINTH
AV

SAWTELLE BL

MC LAUGHLIN AV

INGLEWOOD BL

LINDBLADE
DR
Ballona Creek

LOTZ LN

SAN DIEGO FREEWAY

MARINA FREEWAY

SANTA MONICA FREEWAY
U
S
U
U
S
S
G
G
G
H
G
U
U
G
S
G
U
G
G
S
S
G
U
H
G
G
S
U
S
U
S
G
Low Density Single Family
Low Density Two Family
Low Density Three Family
Low Density Multiple Family
Medium Density Multiple Family
Planned Residential Development
Residential
G
S
U
H
Government
School
Utility
Health Center
Commercial
Neighborhood Serving Corridor
General Corridor
Downtown
Community Serving Center
Regional Center
Light Industrial
Industrial Park
Industrial
Industrial
School
Other
Studio
Cemetery
Open Space
Institutional
City Boundary
Freeway
Ballona Creek
Focused Special Studies Area
Hayden Industrial Tract
Blair Hills / Baldwin Hills
Culver City General Plan 2045
Figure 2-4
Existing General Plan Land Use Map
SOURCE: City of Culver City, 2007D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 0 0.25 0.5 1
Miles
0 0.5 1
Miles
©
SCALE 1:8,500
The City of Culver City makes no representation or warranties of any kind with respect to the accuracy of the information of claims furnished herein, as the data is a compilation of records and information obtained from various sources. The data displayed on this map is for representational purposes only. It is neither a legally recorded map nor a survey and is not intended to be used as such. No part of this map may be reproduced or transmitted in any f orm or by any means, electronic or mechanical, including photocopying and re
cording systems except as expressly permitted in writing by the City of Culver City, Information T echnology Department, Geographic Information Systems. © City of Culver City. All Rights Reserved.

INFORMATION TECHNOLOGY DEPARTMENT

GEOGRAPHIC INFORMATION SYSTEMS
9770 CULVER BLVD
CULVER CITY, CA 90232
TEL: 310-253-5950
August 28, 2007

GENERAL PLAN

LAND USE

ELEMENT MAP
City of
*This version of the Land Use Element Map has been updated as of City Council Resolution No. 99-R105, adopted 13 December 1999, regarding General Plan Land Use Element Map Amendment, GPMA P-1999016 / 12101 Washington Boulevard.
§¨¦405
!(90
§¨¦10

COLLEGE
AV

OREG ON AV

WAGNER ST

LINDBLADE ST
BARMAN
AV

BRADDOCK
DR

WAGNER ST

LINDBLADE ST

ETHELDO AV

BARM AN AV

COOMBSAV

HERBERT ST

EAST BL
HURON
AV

ALETTA AV

GIRARD AV
RO
SABELL
ST

WASHINGTON BL
17 VELVET LN

STEVENS
CR

AUGUSTI N LN
ST. JAMES DR

WINDSOR WY

COR PO RATE POINTE

LEEVIEWCT

JACKSO N AV

WASHINGTON BL

WASHINGTON PL

WASHINGTON BL

BRADDOCK DR
GRAND
VIEW
BL
BOISE
AV

WASATCH AVCOLO NIAL AV

MIDWAY AV
STAR
CR

HUNTLEYAV

BERRYMAN AV

COOLIDGE AV

MCLAUGHLIN AV

TULLER AV

HURO N AV
CU
LVER B
L

ASTAIRE AVSKELTON CR

COOGAN CR

MARIETTA AV

WASHINGTON BL

ARIZONA
AV

COMMONWEALTH AV

FARRAGUT DR

MILTO N AV
TILDEN
AV
GAR
LAND
DR
P
A
LM
CO
U
RT WY
M
C
CO
NNELL
BL
M
ILDRED
AV

MOORE ST

CHASE AV

CAMPBELL DR

KENYON AV

GLOBE AV

GARLAND DR

PURDUE AV

VENICE BL

CULVER BL

MAYTIME

BALDWIN AV
OCEAN

STUDIO DR
JASM
INE
AV

VIRGINIA

PEARSON ST

LEAHY ST

FARRAGUTDR

PARK AV
DR
2 1
13 14

VENICE BL

RAINTREE
CR
13 CORNER RD
13 M
A
YTIME
LN
LN
AV

BRADDOCK DR

GARFIELD
AV

COOMBSAV

MENTONE
AV
LE

BOURGETAV
MOTOR
AV
VINTON
AV

JASMINE
AV

WASHINGTON BL
LOUISE
AV

CULVER BL

KEYSTO NE AV

SUMMERTIME LN

MOTO R AV

VINTO N AV

JACKSO N AV

REVERE PL

LE BO URGET AV

MENTONE AV
6 7
5 8
HOLLOW 1110
3 4

LINCO LN AV

DUQUESNE AV

INDIAN WOOD RD

SUMMERTIME LN

KINSTON AV

FRANKLIN
AV

FARRAGUT
DR

LA SALLE AV

FARRAGUT
DR
EMER
A
LD
W
Y

KEYSTONE
AV
JORDAN
W
Y
15 9
19 18
12 16
17 HARG IS ST

WESLEY ST

BLACKWELDER ST

SMILEY DRHUTCHISON AV FAY AV
M
C
M
ANUS
AV

HIGUERA ST

WARNER ST

STELLER DR

HELMS AV

SCHAEFER ST

HAYDEN AV

ERNEST AV

DAVID AV
FAY AV

EXPOSITION BL

SENTNEY AV

LA CIENEGABL

JACOB ST

CATTARAUGUS AV

SHERBOURNE DR

CARO LINE AV

HELMS AV

LANDMARK ST

NATIONAL BL

DAUPHIN
AV

PERRY DR

HINES AVADAMS BL

EASTHAM DR

RODEO RD

LA CIENEGA AV

REID AV

ROBERTS AV

MC M ANUS AV
P
E
R
H
A
M
DR

CAROLCTW

RIGHT TR
LENAW
EE
AV

VICSTONE CT

WRIGHTCREST DR
HOKE
AV

HOLLYVIEWTRHOWARDVIEWCTW

RIGHTCRE
S
T DR

CANFIELD AV

INCE BL

KRUEGER
ST
HUBBAR
D
ST
CARSON
ST
W
ILLAT
AV

SEPULVEDA BL

JEFFERSON BL
LA
C
IEN
EG
A
BL
VAN
BUREN
PL

WESLEY ST

LINDBLADE ST

POINSETTIA
CT

LUCERNE AV

FARRAGUT DR

LUCERNE
AV

HAYDEN PL

STONEVIEW DR
IVY WY

CRESTVIEW RD

VERHALEN
CT

BLAIRSTONE DR

CLARINGTON
AV
HUGHES
AV

SEPULVEDA BL

DELMAS TER

CARDIFF AV

MAIN ST

IRVING PL

LAFAYETTE PL

HIGUERA ST

MADISON AV

ROBERTSON BL

WATSEKA AV

JEFFERSON BL
JEANPL

JASMINE
AV

SHEDD TR

SHERBOURNE DR

CATTARAUGUS AV

HELMS AV

WASHINGTON BL
W
ESTW
OOD
BL
KAREN
CR
WY

OVERLAND AV

RHODA WY

KINSTON AV

NORTHGATE ST
S T
DRAKEW
O
O
D

WHITBURN
GALVIN

FLAXTO N ST
ST

STEVER ST

KELMORE ST
W Y

LUGO W Y

TELLEFSO
N
RD
M
O
LO
NY
RD
M
ALATAV
STEVEN
S
AV
HANNU
M
HAYTER
AV

RYANDALE DR

PATOM DRORVILLE
S
T

SEGRELL
W
Y

SEGRELL WY
R
UDM
AN
D
R
G

RAYRIDG
E
DR
PLAYA
CT

SELMARAINE DR

EMPO RIA AV

EMPORIA AV

PURDUE AV
CULVER
PARK
DR

SAWTELLE BL
W
OOLFO
R
D
ST

BANKFIELD AV

SELMARAINE DR

FOX HILLS DR

PATOM D
R

PLAYA ST

CAMBRIDGE WY

SUMNER WY
M
C
DONALD
S
T

BLANCO WY

JANISANN AV

BERRYMAN
AV

DAWES AV

COOLIDGE
AV

BERRYMAN AV

DOVERWOOD DR

BUCKINGHAM PK

COTA ST

DOBSON WY

SLAUSON AV

KINSTON
AV

EL RINCON
WY

STEVER CT
BERNA
RDO
RD
EVEW
ARD
RD
LIN DA

HILL RD

STEPHON
TR

STUBBS LN

DESHIRE
PL

CLARMON PL

CULVIEW ST

BUSH WY

KALEIN DR

HANNU M AV

KENSINGTO N
WY
BUCKIN
G
HA
M
PK

FOX HILLS MALL
DILLER
AV
PORT
RD

CULVER PARK DR
WY
HANNUM
AV

HAMMACK ST

BRISTOL PKWY

CANTERBURY DR
GREEN

VALLEY CR

SOUTH D R
NORTH

UPLA NDER WY
UPLAN
DER
W
Y

BRISTOL PKWY
C
O
R
R
YNE
PL

EMPO RIA
PL

ESTERINAWY
YO
UNG
W
O
RTH RD
PO
RTRD

FAIRBANKS
W
Y

FOX HILLS MALL

BALLONA LN

LANTANA LN

MICHAEL AV
MOORE
ST

REDWO OD AVTIVOLI AV

ALLA RD

LYCEUM AV

MEIER ST

WALG ROVE AV

MITCHELL AV

FRANKLIN
AV

MESM ER AV

OVERLAND AV

MATTESON AV

SEPULVEDA BL

PIGOTT DR

BLEDSO E AV

COOMBSAV
R
D
STO
NYCREE
K

MELVIL ST

ETHELDO AV
AV
PICKFO
RD

MACHADO RD
DR

RANCH RD
CRANKS
RD

TO MP KINS WY
COMEY
AV
ZANJA
ST

WALNUT AV

BEETHOVEN ST

GLENCOE AV
1 SALEM VILLAGE DR
3 SALEM VILLAGE CT

CENTINELA AV
M
AR
CASEL
AV
ELENDA

STTULLER
AV

ARVEE ST

GLOBE AV

TULLER AV

GLOBE AV

HEPBURN CR

SHORT AV

MAXELLA AV

LOUISE AV

ATLANTIC
AV

HURO N AV
7 COPPERFIELD LN
4 TIMBER LAKE LN
9 SHOWBOAT LN
2 SALEM VILLAGE PL
5 WILDERNESS LN
10 RAINBOW'S END
12 CIMMARON LN
6 HUCK FINN LN
8 GASLIGHT LN
18 CASCADE CT
14 ST. LOUIS CT
15 BUTTERFIELD CT
11 SHOWBOAT PL
16 BOUNTY LN
19 TARA TR
13 RAINTREE CR

KENSINGTON
RD

COOLIDGE AV

BERRYMAN AV

MINERVA AV

BLEDSO E AV

ALBRIGHT AV

BENTLEY AV
TILDEN
AV
HARTER
AV

CHARLES AV

WADE ST

NEOSHO AV
MC
DONALD
ST

GARFIELD AV

HUNTLEY PL

HERBERTWY
GRAND
VIEW
BL

COMMONWEALTH
CR

GARFIELD AV

HERBERT ST

WASHINGTON PL

FAIRFAX AV

HERITAGE PL

JEFFERSON BL

SEPULVEDA BL

SLAUSON AV

CENTINELA AV

FRANKLIN
AV

COMMO NWEALTH AV

CENTER ST

HARTER AV

MIDWAY AV

CULVER CENTER DR

WESTWOOD BL
SPAD
PL

PROSPECTAV

MATTESON AV
SAW

TELLEBL

ALBRIGHT AV
LAMARR
AV

CORINTH
AV

SAWTELLE BL

MC LAUGHLIN AV

INGLEWOOD BL

LINDBLADE
DR
Ballona Creek

LOTZ LN

SAN DIEGO FREEWAY

MARINA FREEWAY

SANTA MONICA FREEWAY
U
S
U
U
S
S
G
G
G
H
G
U
U
G
S
G
U
G
G
S
S
G
U
H
G
G
S
U
S
U
S
G
Low Density Single Family
Low Density Two Family
Low Density Three Family
Low Density Multiple Family
Medium Density Multiple Family
Planned Residential Development
Residential
G
S
U
H
Government
School
Utility
Health Center
Commercial
Neighborhood Serving Corridor
General Corridor
Downtown
Community Serving Center
Regional Center
Light Industrial
Industrial Park
Industrial
Industrial
School
Other
Studio
Cemetery
Open Space
Institutional
City Boundary
Freeway
Ballona Creek
Focused Special Studies Area
Hayden Industrial Tract
Blair Hills / Baldwin Hills
0 0.5 1
Miles
©
SCALE 1:8,500
The City of Culver City makes no representation or warranties of any kind with respect to the accuracy of the information of claims furnished herein, as the data is a compilation of records and information obtained from various sources. The data displayed on this map is for representational purposes only. It is neither a legally recorded map nor a survey and is not intended to be used as such. No part of this map may be reproduced or transmitted in any f orm or by any means, electronic or mechanical, including photocopying and re
cording systems except as expressly permitted in writing by the City of Culver City, Information T echnology Department, Geographic Information Systems. © City of Culver City. All Rights Reserved.

INFORMATION TECHNOLOGY DEPARTMENT

GEOGRAPHIC INFORMATION SYSTEMS
9770 CULVER BLVD
CULVER CITY, CA 90232
TEL: 310-253-5950
August 28, 2007

GENERAL PLAN

LAND USE

ELEMENT MAP
City of
*This version of the Land Use Element Map has been updated as of City Council Resolution No. 99-R105, adopted 13 December 1999, regarding General Plan Land Use Element Map Amendment, GPMA P-1999016 / 12101 Washington Boulevard.
§¨¦405
!(90
§¨¦10

COLLEGE
AV

OREG ON AV

WAGNER ST

LINDBLADE ST
BARMAN
AV

BRADDOCK
DR

WAGNER ST

LINDBLADE ST

ETHELDO AV

BARM AN AV

COOMBSAV

HERBERT ST

EAST BL
HURON
AV

ALETTA AV

GIRARD AV
RO
SABELL
ST

WASHINGTON BL
17 VELVET LN

STEVENS
CR

AUGUSTI N LN
ST. JAMES DR

WINDSOR WY

COR PO RATE POINTE

LEEVIEWCT

JACKSO N AV

WASHINGTON BL

WASHINGTON PL

WASHINGTON BL

BRADDOCK DR
GRAND
VIEW
BL
BOISE
AV

WASATCH AVCOLO NIAL AV

MIDWAY AV
STAR
CR

HUNTLEYAV

BERRYMAN AV

COOLIDGE AV

MCLAUGHLIN AV

TULLER AV

HURO N AV
CU
LVER B
L

ASTAIRE AVSKELTON CR

COOGAN CR

MARIETTA AV

WASHINGTON BL

ARIZONA
AV

COMMONWEALTH AV

FARRAGUT DR

MILTO N AV
TILDEN
AV
GAR
LAND
DR
P
A
LM
CO
U
RT WY
M
C
CO
NNELL
BL
M
ILDRED
AV

MOORE ST

CHASE AV

CAMPBELL DR

KENYON AV

GLOBE AV

GARLAND DR

PURDUE AV

VENICE BL

CULVER BL

MAYTIME

BALDWIN AV
OCEAN

STUDIO DR
JASM
INE
AV

VIRGINIA

PEARSON ST

LEAHY ST

FARRAGUTDR

PARK AV
DR
2 1
13 14

VENICE BL

RAINTREE
CR
13 CORNER RD
13 M
A
YTIME
LN
LN
AV

BRADDOCK DR

GARFIELD
AV

COOMBSAV

MENTONE
AV
LE

BOURGETAV
MOTOR
AV
VINTON
AV

JASMINE
AV

WASHINGTON BL
LOUISE
AV

CULVER BL

KEYSTO NE AV

SUMMERTIME LN

MOTO R AV

VINTO N AV

JACKSO N AV

REVERE PL

LE BO URGET AV

MENTONE AV
6 7
5 8
HOLLOW 1110
3 4

LINCO LN AV

DUQUESNE AV

INDIAN WOOD RD

SUMMERTIME LN

KINSTON AV

FRANKLIN
AV

FARRAGUT
DR

LA SALLE AV

FARRAGUT
DR
EMER
A
LD
W
Y

KEYSTONE
AV
JORDAN
W
Y
15 9
19 18
12 16
17 HARG IS ST

WESLEY ST

BLACKWELDER ST

SMILEY DRHUTCHISON AV FAY AV
M
C
M
ANUS
AV

HIGUERA ST

WARNER ST

STELLER DR

HELMS AV

SCHAEFER ST

HAYDEN AV

ERNEST AV

DAVID AV
FAY AV

EXPOSITION BL

SENTNEY AV

LA CIENEGABL

JACOB ST

CATTARAUGUS AV

SHERBOURNE DR

CARO LINE AV

HELMS AV

LANDMARK ST

NATIONAL BL

DAUPHIN
AV

PERRY DR

HINES AVADAMS BL

EASTHAM DR

RODEO RD

LA CIENEGA AV

REID AV

ROBERTS AV

MC M ANUS AV
P
E
R
H
A
M
DR

CAROLCTW

RIGHT TR
LENAW
EE
AV

VICSTONE CT

WRIGHTCREST DR
HOKE
AV

HOLLYVIEWTRHOWARDVIEWCTW

RIGHTCRE
S
T DR

CANFIELD AV

INCE BL

KRUEGER
ST
HUBBAR
D
ST
CARSON
ST
W
ILLAT
AV

SEPULVEDA BL

JEFFERSON BL
LA
C
IEN
EG
A
BL
VAN
BUREN
PL

WESLEY ST

LINDBLADE ST

POINSETTIA
CT

LUCERNE AV

FARRAGUT DR

LUCERNE
AV

HAYDEN PL

STONEVIEW DR
IVY WY

CRESTVIEW RD

VERHALEN
CT

BLAIRSTONE DR

CLARINGTON
AV
HUGHES
AV

SEPULVEDA BL

DELMAS TER

CARDIFF AV

MAIN ST

IRVING PL

LAFAYETTE PL

HIGUERA ST

MADISON AV

ROBERTSON BL

WATSEKA AV

JEFFERSON BL
JEANPL

JASMINE
AV

SHEDD TR

SHERBOURNE DR

CATTARAUGUS AV

HELMS AV

WASHINGTON BL
W
ESTW
OOD
BL
KAREN
CR
WY

OVERLAND AV

RHODA WY

KINSTON AV

NORTHGATE ST
S T
DRAKEW
O
O
D

WHITBURN
GALVIN

FLAXTO N ST
ST

STEVER ST

KELMORE ST
W Y

LUGO W Y

TELLEFSO
N
RD
M
O
LO
NY
RD
M
ALATAV
STEVEN
S
AV
HANNU
M
HAYTER
AV

RYANDALE DR

PATOM DRORVILLE
S
T

SEGRELL
W
Y

SEGRELL WY
R
UDM
AN
D
R
G

RAYRIDG
E
DR
PLAYA
CT

SELMARAINE DR

EMPO RIA AV

EMPORIA AV

PURDUE AV
CULVER
PARK
DR

SAWTELLE BL
W
OOLFO
R
D
ST

BANKFIELD AV

SELMARAINE DR

FOX HILLS DR

PATOM D
R

PLAYA ST

CAMBRIDGE WY

SUMNER WY
M
C
DONALD
S
T

BLANCO WY

JANISANN AV

BERRYMAN
AV

DAWES AV

COOLIDGE
AV

BERRYMAN AV

DOVERWOOD DR

BUCKINGHAM PK

COTA ST

DOBSON WY

SLAUSON AV

KINSTON
AV

EL RINCON
WY

STEVER CT
BERNA
RDO
RD
EVEW
ARD
RD
LIN DA

HILL RD

STEPHON
TR

STUBBS LN

DESHIRE
PL

CLARMON PL

CULVIEW ST

BUSH WY

KALEIN DR

HANNU M AV

KENSINGTO N
WY
BUCKIN
G
HA
M
PK

FOX HILLS MALL
DILLER
AV
PORT
RD

CULVER PARK DR
WY
HANNUM
AV

HAMMACK ST

BRISTOL PKWY

CANTERBURY DR
GREEN

VALLEY CR

SOUTH D R
NORTH

UPLA NDER WY
UPLAN
DER
W
Y

BRISTOL PKWY
C
O
R
R
YNE
PL

EMPO RIA
PL

ESTERINAWY
YO
UNG
W
O
RTH RD
PO
RTRD

FAIRBANKS
W
Y

FOX HILLS MALL

BALLONA LN

LANTANA LN

MICHAEL AV
MOORE
ST

REDWO OD AVTIVOLI AV

ALLA RD

LYCEUM AV

MEIER ST

WALG ROVE AV

MITCHELL AV

FRANKLIN
AV

MESM ER AV

OVERLAND AV

MATTESON AV

SEPULVEDA BL

PIGOTT DR

BLEDSO E AV

COOMBSAV
R
D
STO
NYCREE
K

MELVIL ST

ETHELDO AV
AV
PICKFO
RD

MACHADO RD
DR

RANCH RD
CRANKS
RD

TO MP KINS WY
COMEY
AV
ZANJA
ST

WALNUT AV

BEETHOVEN ST

GLENCOE AV
1 SALEM VILLAGE DR
3 SALEM VILLAGE CT

CENTINELA AV
M
AR
CASEL
AV
ELENDA

STTULLER
AV

ARVEE ST

GLOBE AV

TULLER AV

GLOBE AV

HEPBURN CR

SHORT AV

MAXELLA AV

LOUISE AV

ATLANTIC
AV

HURO N AV
7 COPPERFIELD LN
4 TIMBER LAKE LN
9 SHOWBOAT LN
2 SALEM VILLAGE PL
5 WILDERNESS LN
10 RAINBOW'S END
12 CIMMARON LN
6 HUCK FINN LN
8 GASLIGHT LN
18 CASCADE CT
14 ST. LOUIS CT
15 BUTTERFIELD CT
11 SHOWBOAT PL
16 BOUNTY LN
19 TARA TR
13 RAINTREE CR

KENSINGTON
RD

COOLIDGE AV

BERRYMAN AV

MINERVA AV

BLEDSO E AV

ALBRIGHT AV

BENTLEY AV
TILDEN
AV
HARTER
AV

CHARLES AV

WADE ST

NEOSHO AV
MC
DONALD
ST

GARFIELD AV

HUNTLEY PL

HERBERTWY
GRAND
VIEW
BL

COMMONWEALTH
CR

GARFIELD AV

HERBERT ST

WASHINGTON PL

FAIRFAX AV

HERITAGE PL

JEFFERSON BL

SEPULVEDA BL

SLAUSON AV

CENTINELA AV

FRANKLIN
AV

COMMO NWEALTH AV

CENTER ST

HARTER AV

MIDWAY AV

CULVER CENTER DR

WESTWOOD BL
SPAD
PL

PROSPECTAV

MATTESON AV
SAW

TELLEBL

ALBRIGHT AV
LAMARR
AV

CORINTH
AV

SAWTELLE BL

MC LAUGHLIN AV

INGLEWOOD BL

LINDBLADE
DR
Ballona Creek

LOTZ LN

SAN DIEGO FREEWAY

MARINA FREEWAY

SANTA MONICA FREEWAY
U
S
U
U
S
S
G
G
G
H
G
U
U
G
S
G
U
G
G
S
S
G
U
H
G
G
S
U
S
U
S
G
Low Density Single Family
Low Density Two Family
Low Density Three Family
Low Density Multiple Family
Medium Density Multiple Family
Planned Residential Development
Residential
G
S
U
H
Government
School
Utility
Health Center
Commercial
Neighborhood Serving Corridor
General Corridor
Downtown
Community Serving Center
Regional Center
Light Industrial
Industrial Park
Industrial
Industrial
School
Other
Studio
Cemetery
Open Space
Institutional
City Boundary
Freeway
Ballona Creek
Focused Special Studies Area
Hayden Industrial Tract
Blair Hills / Baldwin Hills
0 0.5 1
Miles
©
SCALE 1:8,500
The City of Culver City makes no representation or warranties of any kind with respect to the accuracy of the information of claims furnished herein, as the data is a compilation of records and information obtained from various sources. The data displayed on this map is for representational purposes only. It is neither a legally recorded map nor a survey and is not intended to be used as such. No part of this map may be reproduced or transmitted in any f orm or by any means, electronic or mechanical, including photocopying and re
cording systems except as expressly permitted in writing by the City of Culver City, Information T echnology Department, Geographic Information Systems. © City of Culver City. All Rights Reserved.

INFORMATION TECHNOLOGY DEPARTMENT

GEOGRAPHIC INFORMATION SYSTEMS
9770 CULVER BLVD
CULVER CITY, CA 90232
TEL: 310-253-5950
August 28, 2007

GENERAL PLAN

LAND USE

ELEMENT MAP
City of
*This version of the Land Use Element Map has been updated as of City Council Resolution No. 99-R105, adopted 13 December 1999, regarding General Plan Land Use Element Map Amendment, GPMA P-1999016 / 12101 Washington Boulevard.
§¨¦405
!(90
§¨¦10

COLLEGE
AV

OREG ON AV

WAGNER ST

LINDBLADE ST
BARMAN
AV

BRADDOCK
DR

WAGNER ST

LINDBLADE ST

ETHELDO AV

BARM AN AV

COOMBSAV

HERBERT ST

EAST BL
HURON
AV

ALETTA AV

GIRARD AV
RO
SABELL
ST

WASHINGTON BL
17 VELVET LN

STEVENS
CR

AUGUSTI N LN
ST. JAMES DR

WINDSOR WY

COR PO RATE POINTE

LEEVIEWCT

JACKSO N AV

WASHINGTON BL

WASHINGTON PL

WASHINGTON BL

BRADDOCK DR
GRAND
VIEW
BL
BOISE
AV

WASATCH AVCOLO NIAL AV

MIDWAY AV
STAR
CR

HUNTLEYAV

BERRYMAN AV

COOLIDGE AV

MCLAUGHLIN AV

TULLER AV

HURO N AV
CU
LVER B
L

ASTAIRE AVSKELTON CR

COOGAN CR

MARIETTA AV

WASHINGTON BL

ARIZONA
AV

COMMONWEALTH AV

FARRAGUT DR

MILTO N AV
TILDEN
AV
GAR
LAND
DR
P
A
LM
CO
U
RT WY
M
C
CO
NNELL
BL
M
ILDRED
AV

MOORE ST

CHASE AV

CAMPBELL DR

KENYON AV

GLOBE AV

GARLAND DR

PURDUE AV

VENICE BL

CULVER BL

MAYTIME

BALDWIN AV
OCEAN

STUDIO DR
JASM
INE
AV

VIRGINIA

PEARSON ST

LEAHY ST

FARRAGUTDR

PARK AV
DR
2 1
13 14

VENICE BL

RAINTREE
CR
13 CORNER RD
13 M
A
YTIME
LN
LN
AV

BRADDOCK DR

GARFIELD
AV

COOMBSAV

MENTONE
AV
LE

BOURGETAV
MOTOR
AV
VINTON
AV

JASMINE
AV

WASHINGTON BL
LOUISE
AV

CULVER BL

KEYSTO NE AV

SUMMERTIME LN

MOTO R AV

VINTO N AV

JACKSO N AV

REVERE PL

LE BO URGET AV

MENTONE AV
6 7
5 8
HOLLOW 1110
3 4

LINCO LN AV

DUQUESNE AV

INDIAN WOOD RD

SUMMERTIME LN

KINSTON AV

FRANKLIN
AV

FARRAGUT
DR

LA SALLE AV

FARRAGUT
DR
EMER
A
LD
W
Y

KEYSTONE
AV
JORDAN
W
Y
15 9
19 18
12 16
17 HARG IS ST

WESLEY ST

BLACKWELDER ST

SMILEY DRHUTCHISON AV FAY AV
M
C
M
ANUS
AV

HIGUERA ST

WARNER ST

STELLER DR

HELMS AV

SCHAEFER ST

HAYDEN AV

ERNEST AV

DAVID AV
FAY AV

EXPOSITION BL

SENTNEY AV

LA CIENEGABL

JACOB ST

CATTARAUGUS AV

SHERBOURNE DR

CARO LINE AV

HELMS AV

LANDMARK ST

NATIONAL BL

DAUPHIN
AV

PERRY DR

HINES AVADAMS BL

EASTHAM DR

RODEO RD

LA CIENEGA AV

REID AV

ROBERTS AV

MC M ANUS AV
P
E
R
H
A
M
DR

CAROLCTW

RIGHT TR
LENAW
EE
AV

VICSTONE CT

WRIGHTCREST DR
HOKE
AV

HOLLYVIEWTRHOWARDVIEWCTW

RIGHTCRE
S
T DR

CANFIELD AV

INCE BL

KRUEGER
ST
HUBBAR
D
ST
CARSON
ST
W
ILLAT
AV

SEPULVEDA BL

JEFFERSON BL
LA
C
IEN
EG
A
BL
VAN
BUREN
PL

WESLEY ST

LINDBLADE ST

POINSETTIA
CT

LUCERNE AV

FARRAGUT DR

LUCERNE
AV

HAYDEN PL

STONEVIEW DR
IVY WY

CRESTVIEW RD

VERHALEN
CT

BLAIRSTONE DR

CLARINGTON
AV
HUGHES
AV

SEPULVEDA BL

DELMAS TER

CARDIFF AV

MAIN ST

IRVING PL

LAFAYETTE PL

HIGUERA ST

MADISON AV

ROBERTSON BL

WATSEKA AV

JEFFERSON BL
JEANPL

JASMINE
AV

SHEDD TR

SHERBOURNE DR

CATTARAUGUS AV

HELMS AV

WASHINGTON BL
W
ESTW
OOD
BL
KAREN
CR
WY

OVERLAND AV

RHODA WY

KINSTON AV

NORTHGATE ST
S T
DRAKEW
O
O
D

WHITBURN
GALVIN

FLAXTO N ST
ST

STEVER ST

KELMORE ST
W Y

LUGO W Y

TELLEFSO
N
RD
M
O
LO
NY
RD
M
ALATAV
STEVEN
S
AV
HANNU
M
HAYTER
AV

RYANDALE DR

PATOM DRORVILLE
S
T

SEGRELL
W
Y

SEGRELL WY
R
UDM
AN
D
R
G

RAYRIDG
E
DR
PLAYA
CT

SELMARAINE DR

EMPO RIA AV

EMPORIA AV

PURDUE AV
CULVER
PARK
DR

SAWTELLE BL
W
OOLFO
R
D
ST

BANKFIELD AV

SELMARAINE DR

FOX HILLS DR

PATOM D
R

PLAYA ST

CAMBRIDGE WY

SUMNER WY
M
C
DONALD
S
T

BLANCO WY

JANISANN AV

BERRYMAN
AV

DAWES AV

COOLIDGE
AV

BERRYMAN AV

DOVERWOOD DR

BUCKINGHAM PK

COTA ST

DOBSON WY

SLAUSON AV

KINSTON
AV

EL RINCON
WY

STEVER CT
BERNA
RDO
RD
EVEW
ARD
RD
LIN DA

HILL RD

STEPHON
TR

STUBBS LN

DESHIRE
PL

CLARMON PL

CULVIEW ST

BUSH WY

KALEIN DR

HANNU M AV

KENSINGTO N
WY
BUCKIN
G
HA
M
PK

FOX HILLS MALL
DILLER
AV
PORT
RD

CULVER PARK DR
WY
HANNUM
AV

HAMMACK ST

BRISTOL PKWY

CANTERBURY DR
GREEN

VALLEY CR

SOUTH D R
NORTH

UPLA NDER WY
UPLAN
DER
W
Y

BRISTOL PKWY
C
O
R
R
YNE
PL

EMPO RIA
PL

ESTERINAWY
YO
UNG
W
O
RTH RD
PO
RTRD

FAIRBANKS
W
Y

FOX HILLS MALL

BALLONA LN

LANTANA LN

MICHAEL AV
MOORE
ST

REDWO OD AVTIVOLI AV

ALLA RD

LYCEUM AV

MEIER ST

WALG ROVE AV

MITCHELL AV

FRANKLIN
AV

MESM ER AV

OVERLAND AV

MATTESON AV

SEPULVEDA BL

PIGOTT DR

BLEDSO E AV

COOMBSAV
R
D
STO
NYCREE
K

MELVIL ST

ETHELDO AV
AV
PICKFO
RD

MACHADO RD
DR

RANCH RD
CRANKS
RD

TO MP KINS WY
COMEY
AV
ZANJA
ST

WALNUT AV

BEETHOVEN ST

GLENCOE AV
1 SALEM VILLAGE DR
3 SALEM VILLAGE CT

CENTINELA AV
M
AR
CASEL
AV
ELENDA

STTULLER
AV

ARVEE ST

GLOBE AV

TULLER AV

GLOBE AV

HEPBURN CR

SHORT AV

MAXELLA AV

LOUISE AV

ATLANTIC
AV

HURO N AV
7 COPPERFIELD LN
4 TIMBER LAKE LN
9 SHOWBOAT LN
2 SALEM VILLAGE PL
5 WILDERNESS LN
10 RAINBOW'S END
12 CIMMARON LN
6 HUCK FINN LN
8 GASLIGHT LN
18 CASCADE CT
14 ST. LOUIS CT
15 BUTTERFIELD CT
11 SHOWBOAT PL
16 BOUNTY LN
19 TARA TR
13 RAINTREE CR

KENSINGTON
RD

COOLIDGE AV

BERRYMAN AV

MINERVA AV

BLEDSO E AV

ALBRIGHT AV

BENTLEY AV
TILDEN
AV
HARTER
AV

CHARLES AV

WADE ST

NEOSHO AV
MC
DONALD
ST

GARFIELD AV

HUNTLEY PL

HERBERTWY
GRAND
VIEW
BL

COMMONWEALTH
CR

GARFIELD AV

HERBERT ST

WASHINGTON PL

FAIRFAX AV

HERITAGE PL

JEFFERSON BL

SEPULVEDA BL

SLAUSON AV

CENTINELA AV

FRANKLIN
AV

COMMO NWEALTH AV

CENTER ST

HARTER AV

MIDWAY AV

CULVER CENTER DR

WESTWOOD BL
SPAD
PL

PROSPECTAV

MATTESON AV
SAW

TELLEBL

ALBRIGHT AV
LAMARR
AV

CORINTH
AV

SAWTELLE BL

MC LAUGHLIN AV

INGLEWOOD BL

LINDBLADE
DR
Ballona Creek

LOTZ LN

SAN DIEGO FREEWAY

MARINA FREEWAY

SANTA MONICA FREEWAY
U
S
U
U
S
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G
G
G
H
G
U
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G
S
G
U
G
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H
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Low Density Single Family
Low Density Two Family
Low Density Three Family
Low Density Multiple Family
Medium Density Multiple Family
Planned Residential Development
Residential
G
S
U
H
Government
School
Utility
Health Center
Commercial
Neighborhood Serving Corridor
General Corridor
Downtown
Community Serving Center
Regional Center
Light Industrial
Industrial Park
Industrial
Industrial
School
Other
Studio
Cemetery
Open Space
Institutional
City Boundary
Freeway
Ballona Creek
Focused Special Studies Area
Hayden Industrial Tract
Blair Hills / Baldwin Hills
0 0.5 1
Miles
©
SCALE 1:8,500
The City of Culver City makes no representation or warranties of any kind with respect to the accuracy of the information of claims furnished herein, as the data is a compilation of records and information obtained from various sources. The data displayed on this map is for representational purposes only. It is neither a legally recorded map nor a survey and is not intended to be used as such. No part of this map may be reproduced or transmitted in any f orm or by any means, electronic or mechanical, including photocopying and re
cording systems except as expressly permitted in writing by the City of Culver City, Information T echnology Department, Geographic Information Systems. © City of Culver City. All Rights Reserved.

INFORMATION TECHNOLOGY DEPARTMENT

GEOGRAPHIC INFORMATION SYSTEMS
9770 CULVER BLVD
CULVER CITY, CA 90232
TEL: 310-253-5950
August 28, 2007

GENERAL PLAN

LAND USE

ELEMENT MAP
City of
*This version of the Land Use Element Map has been updated as of City Council Resolution No. 99-R105, adopted 13 December 1999, regarding General Plan Land Use Element Map Amendment, GPMA P-1999016 / 12101 Washington Boulevard.
§¨¦405
!(90
§¨¦10

COLLEGE
AV

OREG ON AV

WAGNER ST

LINDBLADE ST
BARMAN
AV

BRADDOCK
DR

WAGNER ST

LINDBLADE ST

ETHELDO AV

BARM AN AV

COOMBSAV

HERBERT ST

EAST BL
HURON
AV

ALETTA AV

GIRARD AV
RO
SABELL
ST

WASHINGTON BL
17 VELVET LN

STEVENS
CR

AUGUSTI N LN
ST. JAMES DR

WINDSOR WY

COR PO RATE POINTE

LEEVIEWCT

JACKSO N AV

WASHINGTON BL

WASHINGTON PL

WASHINGTON BL

BRADDOCK DR
GRAND
VIEW
BL
BOISE
AV

WASATCH AVCOLO NIAL AV

MIDWAY AV
STAR
CR

HUNTLEYAV

BERRYMAN AV

COOLIDGE AV

MCLAUGHLIN AV

TULLER AV

HURO N AV
CU
LVER B
L

ASTAIRE AVSKELTON CR

COOGAN CR

MARIETTA AV

WASHINGTON BL

ARIZONA
AV

COMMONWEALTH AV

FARRAGUT DR

MILTO N AV
TILDEN
AV
GAR
LAND
DR
P
A
LM
CO
U
RT WY
M
C
CO
NNELL
BL
M
ILDRED
AV

MOORE ST

CHASE AV

CAMPBELL DR

KENYON AV

GLOBE AV

GARLAND DR

PURDUE AV

VENICE BL

CULVER BL

MAYTIME

BALDWIN AV
OCEAN

STUDIO DR
JASM
INE
AV

VIRGINIA

PEARSON ST

LEAHY ST

FARRAGUTDR

PARK AV
DR
2 1
13 14

VENICE BL

RAINTREE
CR
13 CORNER RD
13 M
A
YTIME
LN
LN
AV

BRADDOCK DR

GARFIELD
AV

COOMBSAV

MENTONE
AV
LE

BOURGETAV
MOTOR
AV
VINTON
AV

JASMINE
AV

WASHINGTON BL
LOUISE
AV

CULVER BL

KEYSTO NE AV

SUMMERTIME LN

MOTO R AV

VINTO N AV

JACKSO N AV

REVERE PL

LE BO URGET AV

MENTONE AV
6 7
5 8
HOLLOW 1110
3 4

LINCO LN AV

DUQUESNE AV

INDIAN WOOD RD

SUMMERTIME LN

KINSTON AV

FRANKLIN
AV

FARRAGUT
DR

LA SALLE AV

FARRAGUT
DR
EMER
A
LD
W
Y

KEYSTONE
AV
JORDAN
W
Y
15 9
19 18
12 16
17 HARG IS ST

WESLEY ST

BLACKWELDER ST

SMILEY DRHUTCHISON AV FAY AV
M
C
M
ANUS
AV

HIGUERA ST

WARNER ST

STELLER DR

HELMS AV

SCHAEFER ST

HAYDEN AV

ERNEST AV

DAVID AV
FAY AV

EXPOSITION BL

SENTNEY AV

LA CIENEGABL

JACOB ST

CATTARAUGUS AV

SHERBOURNE DR

CARO LINE AV

HELMS AV

LANDMARK ST

NATIONAL BL

DAUPHIN
AV

PERRY DR

HINES AVADAMS BL

EASTHAM DR

RODEO RD

LA CIENEGA AV

REID AV

ROBERTS AV

MC M ANUS AV
P
E
R
H
A
M
DR

CAROLCTW

RIGHT TR
LENAW
EE
AV

VICSTONE CT

WRIGHTCREST DR
HOKE
AV

HOLLYVIEWTRHOWARDVIEWCTW

RIGHTCRE
S
T DR

CANFIELD AV

INCE BL

KRUEGER
ST
HUBBAR
D
ST
CARSON
ST
W
ILLAT
AV

SEPULVEDA BL

JEFFERSON BL
LA
C
IEN
EG
A
BL
VAN
BUREN
PL

WESLEY ST

LINDBLADE ST

POINSETTIA
CT

LUCERNE AV

FARRAGUT DR

LUCERNE
AV

HAYDEN PL

STONEVIEW DR
IVY WY

CRESTVIEW RD

VERHALEN
CT

BLAIRSTONE DR

CLARINGTON
AV
HUGHES
AV

SEPULVEDA BL

DELMAS TER

CARDIFF AV

MAIN ST

IRVING PL

LAFAYETTE PL

HIGUERA ST

MADISON AV

ROBERTSON BL

WATSEKA AV

JEFFERSON BL
JEANPL

JASMINE
AV

SHEDD TR

SHERBOURNE DR

CATTARAUGUS AV

HELMS AV

WASHINGTON BL
W
ESTW
OOD
BL
KAREN
CR
WY

OVERLAND AV

RHODA WY

KINSTON AV

NORTHGATE ST
S T
DRAKEW
O
O
D

WHITBURN
GALVIN

FLAXTO N ST
ST

STEVER ST

KELMORE ST
W Y

LUGO W Y

TELLEFSO
N
RD
M
O
LO
NY
RD
M
ALATAV
STEVEN
S
AV
HANNU
M
HAYTER
AV

RYANDALE DR

PATOM DRORVILLE
S
T

SEGRELL
W
Y

SEGRELL WY
R
UDM
AN
D
R
G

RAYRIDG
E
DR
PLAYA
CT

SELMARAINE DR

EMPO RIA AV

EMPORIA AV

PURDUE AV
CULVER
PARK
DR

SAWTELLE BL
W
OOLFO
R
D
ST

BANKFIELD AV

SELMARAINE DR

FOX HILLS DR

PATOM D
R

PLAYA ST

CAMBRIDGE WY

SUMNER WY
M
C
DONALD
S
T

BLANCO WY

JANISANN AV

BERRYMAN
AV

DAWES AV

COOLIDGE
AV

BERRYMAN AV

DOVERWOOD DR

BUCKINGHAM PK

COTA ST

DOBSON WY

SLAUSON AV

KINSTON
AV

EL RINCON
WY

STEVER CT
BERNA
RDO
RD
EVEW
ARD
RD
LIN DA

HILL RD

STEPHON
TR

STUBBS LN

DESHIRE
PL

CLARMON PL

CULVIEW ST

BUSH WY

KALEIN DR

HANNU M AV

KENSINGTO N
WY
BUCKIN
G
HA
M
PK

FOX HILLS MALL
DILLER
AV
PORT
RD

CULVER PARK DR
WY
HANNUM
AV

HAMMACK ST

BRISTOL PKWY

CANTERBURY DR
GREEN

VALLEY CR

SOUTH D R
NORTH

UPLA NDER WY
UPLAN
DER
W
Y

BRISTOL PKWY
C
O
R
R
YNE
PL

EMPO RIA
PL

ESTERINAWY
YO
UNG
W
O
RTH RD
PO
RTRD

FAIRBANKS
W
Y

FOX HILLS MALL

BALLONA LN

LANTANA LN

MICHAEL AV
MOORE
ST

REDWO OD AVTIVOLI AV

ALLA RD

LYCEUM AV

MEIER ST

WALG ROVE AV

MITCHELL AV

FRANKLIN
AV

MESM ER AV

OVERLAND AV

MATTESON AV

SEPULVEDA BL

PIGOTT DR

BLEDSO E AV

COOMBSAV
R
D
STO
NYCREE
K

MELVIL ST

ETHELDO AV
AV
PICKFO
RD

MACHADO RD
DR

RANCH RD
CRANKS
RD

TO MP KINS WY
COMEY
AV
ZANJA
ST

WALNUT AV

BEETHOVEN ST

GLENCOE AV
1 SALEM VILLAGE DR
3 SALEM VILLAGE CT

CENTINELA AV
M
AR
CASEL
AV
ELENDA

STTULLER
AV

ARVEE ST

GLOBE AV

TULLER AV

GLOBE AV

HEPBURN CR

SHORT AV

MAXELLA AV

LOUISE AV

ATLANTIC
AV

HURO N AV
7 COPPERFIELD LN
4 TIMBER LAKE LN
9 SHOWBOAT LN
2 SALEM VILLAGE PL
5 WILDERNESS LN
10 RAINBOW'S END
12 CIMMARON LN
6 HUCK FINN LN
8 GASLIGHT LN
18 CASCADE CT
14 ST. LOUIS CT
15 BUTTERFIELD CT
11 SHOWBOAT PL
16 BOUNTY LN
19 TARA TR
13 RAINTREE CR

KENSINGTON
RD

COOLIDGE AV

BERRYMAN AV

MINERVA AV

BLEDSO E AV

ALBRIGHT AV

BENTLEY AV
TILDEN
AV
HARTER
AV

CHARLES AV

WADE ST

NEOSHO AV
MC
DONALD
ST

GARFIELD AV

HUNTLEY PL

HERBERTWY
GRAND
VIEW
BL

COMMONWEALTH
CR

GARFIELD AV

HERBERT ST

WASHINGTON PL

FAIRFAX AV

HERITAGE PL

JEFFERSON BL

SEPULVEDA BL

SLAUSON AV

CENTINELA AV

FRANKLIN
AV

COMMO NWEALTH AV

CENTER ST

HARTER AV

MIDWAY AV

CULVER CENTER DR

WESTWOOD BL
SPAD
PL

PROSPECTAV

MATTESON AV
SAW

TELLEBL

ALBRIGHT AV
LAMARR
AV

CORINTH
AV

SAWTELLE BL

MC LAUGHLIN AV

INGLEWOOD BL

LINDBLADE
DR
Ballona Creek

LOTZ LN

SAN DIEGO FREEWAY

MARINA FREEWAY

SANTA MONICA FREEWAY
U
S
U
U
S
S
G
G
G
H
G
U
U
G
S
G
U
G
G
S
S
G
U
H
G
G
S
U
S
U
S
G
Low Density Single Family
Low Density Two Family
Low Density Three Family
Low Density Multiple Family
Medium Density Multiple Family
Planned Residential Development
Residential
G
S
U
H
Government
School
Utility
Health Center
Commercial
Neighborhood Serving Corridor
General Corridor
Downtown
Community Serving Center
Regional Center
Light Industrial
Industrial Park
Industrial
Industrial
School
Other
Studio
Cemetery
Open Space
Institutional
City Boundary
Freeway
Ballona Creek
Focused Special Studies Area
Hayden Industrial Tract
Blair Hills / Baldwin Hills

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
As shown in Table 2-1, approximately 1,408 acres or 44 percent of the land in the Planning Area is designated for residential use. The majority of the residential land is designated for single family residences, with 733.6 acres or 22 percent designated Low Density Single Family within the Planning Area. Open space accounts for the second highest amount of land, with 633 acres or 19.8 percent of the land designated Open Space, although most of this acreage is within the SOI. Commercial land use designations comprise 501.1 acres (15.7 percent) of the Planning Area with Regional Center as the predominant designation covering 222.5 acres (7.0 percent). Finally, the industrial land use category comprises 226.6 acres (7.1 percent) of the Planning Area, with the Industrial designation comprising the majority of the industrial land uses and covering 135.6 acres (4.2 percent) of the Planning Area.

2.3 P urpose and Objectives of the Project
This section provides a description of the Project’s purpose and objectives as required under CEQA Guidelines Section 15124(b). The General Plan 2045 would replace the existing General Plan in its entirety.

California Government Code Section 65300 requires each city and county in California to adopt a general plan “for the physical development of the county or city, and any land outside its boundaries which…bears relation to its planning.” The underlying purpose of the Project is to comprehensively update the General Plan to establish a long-range vision that reflects the unique needs of the City and provides clear direction to improve the quality of life for residents, businesses, and visitors. In addition, the purpose of the Project, which includes updates to portions of the City’s Municipal Code, is also to provide the amendments necessary to the Zoning Code to implement the General Plan Update. The General Plan can be considered the City’s development constitution, containing both a statement of the community’s vision of its long-term development as well as the policies to support that vision by guiding the physical growth of the city. The General Plan 2045 contains policies to guide decision-making related to land use and community character; equity, community health and environment; public safety; housing; mobility; parks and recreation; infrastructure; greenhouse gas reduction; conservation; safety; and noise.

The General Plan Update is a document that would be adopted by the City Council to serve several purposes:
• Establish a long-range vision that reflects the aspirations of the community and outlines steps to achieve this vision;
• Establish long-range development policies that will guide City departments, as well as Planning Commission and City Council decision-making;
• Provide a basis for judging whether specific development proposals and public projects are in harmony with plan policies;
• Designate land uses in a way that meets future land needs based on the projected population and job growth;

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
• Allow City departments, other public agencies, and private developers to design projects that will minimize hazards; and
• Provide the basis for establishing and setting priorities for detailed plans and implementing programs, such as the zoning ordinance, subdivision regulations, comprehensive plans, and the Capital Improvement Program.

The General Plan 2045 will establish the course for the next two decades for the city to foster a vibrant, unique, and diverse community with a strong social and economic fabric stitched together by its arts and cultural assets, creative enterprises, high-quality services, and inclusiveness. Core values include equity and inclusion; sustainability; innovation and creativity; and compassion and community. At the outset of the General Plan Update process, the following Guiding Principles were developed, which are specific and objective benchmarks that guided the development of the General Plan Update:
• Provide high-quality public services through an equitable, adaptive, transparent, accessible, and fiscally sustainable governing structure with intentional investments and regulatory measures;
• Advance racial, demographic, and socioeconomic diversity by supporting a range of housing types for different income levels, household compositions, stages of life, and disadvantaged populations, including persons experiencing homelessness, the elderly, and persons with disabilities;
• Create more opportunities to broaden and deepen civic engagement that bring more of Culver City’s diverse voices to the decision-making table; • Adopt innovative and equitable policies to eliminate greenhouse gas emissions (decarbonize buildings and industry), reduce energy and water use, encourage the purchase of 100 percent renewable, carbon-free electricity, foster the transition to zero-emission vehicles, and adapt to climate disruption, ensuring all residents, are resilient to climate hazards;
• Foster harmony between people and the environment through continued sustainability efforts, urban ecology, and stewardship of natural resources, like the Ballona Creek and Baldwin Hills, for the benefit of future generations;
• Cultivate social connections between residents, workers, businesses, and visitors through urban design that sustains and revitalizes the public realm, creates great places to gather, adapts to a changing climate, and promotes public safety; • Be a creative and proactive leader in solving regional, state, and national challenges around issues like housing, mobility, public safety, equity, climate change, and environmental pollution and disruption;
• Elevate community health and health equity through new, improved, and well-maintained public amenities that are accessible to all— like parks, sport courts and fields, gathering places, healthy and affordable food, natural resources, and community services— that allow people of all ages and abilities to thrive physically, socially, and mentally; • Sustain arts and culture in Culver City, including visual, performing, literary, and culinary arts. Support the continued preservation of historic and cultural resources in Culver City;

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
• Support the continued growth of creative industries as the cornerstone of the renowned arts and cultural identity and unique regional economic role of Culver City, including digital media, architecture and interior design, and visual and performing arts; • Practice resilient and sustainable solutions to maintain and improve infrastructure, including water, road infrastructure, and broadband. Ensure these solutions are implemented equitably throughout the city. Embrace innovative and responsible use of technology to improve City operations, enhance public participation, and build smart, secure, and adaptable infrastructure systems;
• Build more active and shared modes of getting to, from, and through Culver City by providing more reliable, safe, affordable, clean, and connected carbon-free transportation and mobility options for people of all ages and abilities; • Support a diversified, adaptable, and sustainable economy with a balance of small and large businesses across a range of industries that provide employment, commercial, and experiential opportunities. Ensure the economy is resilient to shocks and stresses, like pandemics, seismic events, flooding, wildfires and other natural and human made disasters.

2.4 Project Characteristics
The Project, as defined by the CEQA Guidelines, is the adoption and implementation of a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Code to implement the General Plan Update.

2.4.1 General Plan 2045
The General Plan 2045 would align the Culver City General Plan with current and future community conditions and needs, through the Plan’s 2045 planning horizon. The General Plan Update process was initiated in 2019 and a detailed history of process is provided in Chapter 1, Introduction.

The Land Use and Community Design Element includes updated Land Use Designations and an updated General Plan Land Use Map, and the Mobility Element includes an updated Planned Circulation Map. The General Plan Update also includes the Community Health and Environmental Justice Element in compliance with SB 1000 to address environmental justice and priority neighborhoods and updates to the Safety Element to address emergency evacuation planning in compliance with SB 99.

The analysis provided in this PEIR is based on the potential environmental impacts that may occur as a result of implementation of the General Plan Update. The following elements include goals, objectives, and policies that are intended to guide growth and development within the City that may result in impacts to the environment: Land Use and Community Design; Community Health and Environmental Justice; Housing; Mobility; Parks and Recreation; Infrastructure; Greenhouse Gas Reduction; Conservation; Safety; and Noise. The goals, objectives, and policies of the General Plan Update are considered part of the Project and are included in the environmental analysis where they have a mitigating effect. A detailed description of each of these elements and the features analyzed throughout this PEIR are provided below.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Land Use and Community Design
Land Use Approach
The Land Use and Community Design Element guides the evolution of urban form and land use patterns in Culver City through the 2045 General Plan horizon year. As described above, the City is largely urbanized and has a limited amount of vacant land. The most prevalent existing land uses are single-family residential (29 percent), oil field (14 percent), retail and services (11 percent), and civic and institutional (11 percent). Land uses proposed within the Planning Area can be broken down into four main categories of development: activity centers, commercial corridors, residential neighborhoods, and parks/open space. The layout of these categories within the Planning Area are shown in Figure 2-5, City Structure and Neighborhood Diagram, and are defined as follows:
• Activity Centers: Places where people and activities are clustered, such as a corner on main street or central shopping area that brings residents together constitutes a center of local activity. Pedestrian-oriented areas with creative businesses, offices, retail, housing development and gathering spaces with easy access to active transportation, such as Downtown, a center for gathering, tourism, and commercial activity, including a mix of retailers, restaurants, offices, and civic uses.
• Commercial Corridors: Major boulevards and arterial streets that run through Culver City and create a pattern of residential, non-residential, and mixed-use districts. The parcels that line the corridors of Slauson Avenue, Washington Boulevard, Sepulveda Boulevard, Jefferson Boulevard, National Boulevard, and Culver Boulevard vary in size and use and are almost all commercial buildings.
• Residential Neighborhoods: Residential areas that vary in building size and housing type but are largely characterized by small parcels that front smaller neighborhood streets. With few exceptions, the neighborhood scale is smaller than the scale of development found on the corridors.
• Parks and Open Space: Parks, recreational facilities, cemeteries, and open spaces occupy about 10 percent of the City, with the majority of parks located in residential neighborhoods. Ballona Creek, a flood control channel also mitigates flooding, restores native ecologies, and provides a multi-purpose open space and recreational corridor.

New development would primarily occur on parcels that already contain some existing homes or businesses. The City’s primary approach to accommodating growth is to provide strategies for thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The Project seeks to intensify and mix land uses on key segments of the commercial corridors, and to improve pedestrian experiences along the City’s commercial corridors through parking management strategies, active street frontage guidelines, and public realm improvements. To support the community’s housing vision, the land use vision allows for new residential and mixed-use development within the City’s industrial areas. With this approach to accommodating growth, it is anticipated that construction for infill and redevelopment of existing land uses would occur across many areas of the City, including those areas that would maintain land use designations similar to existing conditions.

Culver City General Plan 2045
Figure 2-5
City Structure and Neighborhood Diagram
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator Metro E Line
Metro E Line
Metro E Line
UniUn nconcorporp ratteded
CouCounty
Interstate 405
Activity
Centers Activity
Center
Activity Center
Activity Center
Activity Center
Activity Center
0 0.25 0.5 1
Miles
Activity Centers
Mixed Use Neighborhoods
Mixed Use Corridors
Districts
Residential Neighborhoods
Open Spaces
Interstate 10
Interstate 10
Interstate 10
Interstate 405
Interstate 405
Bal
lona
Creek
BallonaC
reek
BallonaCreek
Ballona Creek
BallonaC r
eek
N

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
By distributing growth along corridors, including in areas well served by transit, housing will be incrementally added in existing residential areas, providing access to opportunities, such as jobs, neighborhood amenities, and health care facilities. In addition to infill and transit-oriented communities (TOC), the land use plan for the City promotes the retention and expansion of creative economy businesses and other emerging technologies in these industrial mixed-use areas and mixed-use corridors; supports the needs of neighborhood-serving retail by encouraging commercial and experiential opportunities, particularly in the Downtown area; and advances strategies that ensure a safe and effective phase out of the Inglewood Oil Field (IOF).1 The General Plan Update would maintain existing parks and open space resources while continuing to expand these resources in an equitable manner.

The Land Use and Community Design Element includes a land use map which graphically represents the land use vision for the Planning Area, which upon implementation, would achieve the City’s goals land use approach and vision. See Figure 2-6, Draft General Plan Land Use Map, for the projected distribution of land uses throughout the Planning Area.

The analysis provided in this PEIR considers the anticipated environmental effects associated with development and operation of the distribution of the various land use designation throughout the Planning Area.

Land Use Designations
The General Plan land use designations identify allowed uses and development intensity for each parcel of land. The designations focus broadly on future growth and physical development as opposed to what is on the ground today. Overall, there are three broad categories of land use designations: residential, mixed use, and special purpose. Residential designations define the predominantly residential areas of the city and range from single family homes to multi-family housing, while mixed use designations provide areas for a range of residential and commercial uses in vertical or horizontal patterns. The special purpose designations identify a range of institutional uses and public facilities, such as schools, parks, and government facilities.

State law requires that the categories used on the General Plan Land Use Map be accompanied by definitions. These definitions establish the general intended uses and development intensities.

Table 2-2, Proposed General Plan Land Use Designations, provides the proposed land use designations and general development parameters that are contained in the General Plan Update compared to the existing General Plan land use designations. Other uses that are allowed through zoning may be deemed compatible with the general intended uses. More specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and tailored building heights are contained in the Zoning Code Update, described below.

1 The IOF encompasses approximately 1,000 acres based on surface field boundaries, with roughly 80 acres within the limits of Culver City and the remaining 920 acres within unincorporated County of Los Angeles (County), of which approximately 400 acres are located within the City’s SOI.

GreenValleyCir
General Plan
Land Use
°0 0.5 10.25
Miles
Sources:

City of Culver City (2024);
County of Los Angeles (202 1);
ESRI (202 1).

Metro Station
City Limits
Sphere of Influence
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Residential Uses
Single Family
Two Family
Low Density Multifamily
Medium Density Multifamily
High Density Multifamily
Mixed Uses
Mixed Use Corridor 1
Mixed Use Corridor 2
Mixed Use Medium
Mixed Use High
Mixed Use Industrial
Special Uses
Institutional
Studio
Open Space
Cemetery
Transportation
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

DuquesneAve.

National Blvd.

BristolPark way
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
VeniceBlvd.

La Cienega Blvd.

VeniceBlvd.

VeniceBlvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

GreenValleyCir
General Plan
Land Use
°0 0.5 10.25
Miles
Sources:

City of Culver City (2024);
County of Los Angeles (202 1);
ESRI (202 1).

Metro Station
City Limits
Sphere of Influence
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Residential Uses
Single Family
Two Family
Low Density Multifamily
Medium Density Multifamily
High Density Multifamily
Mixed Uses
Mixed Use Corridor 1
Mixed Use Corridor 2
Mixed Use Medium
Mixed Use High
Mixed Use Industrial
Special Uses
Institutional
Studio
Open Space
Cemetery
Transportation
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

DuquesneAve.

National Blvd.

BristolPark way
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
VeniceBlvd.

La Cienega Blvd.

VeniceBlvd.

VeniceBlvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Culver City General Plan 2045
Figure 2-6
Draft General Plan Land Use Map
SOURCE: City of Culver City, 2024; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 2-2

PROPOSED GENERAL PLAN LAND USE DESIGNATIONS
Proposed Land Use
Designations
Maximum
Residential
Density
Maximum Non-
Residential FAR Description Existing GP Designations
Residential Uses
Single Family 8.7 du/ac N/A Single family Low Density Single Family (8.7 du/ac) Two Family 17.4 du/ac N/A Single family and duplexes Low Density Two Family (17.4) Medium Density
Multifamily
50 du/ac N/A multifamily residential Low Density Three Family (29 du/ac), Low Density Multifamily (15 du/ac), Medium Density Multifamily (29
du/ac)
High Density
Multifamily
70 du/ac N/A Multifamily residential Medium Density Multifamily, Planned Residential Development, Low Density Multifamily, Low Density
Two Family
Mixed Uses
Mixed Use Corridor 1 35 du/ac 2.0 Lower-scale mixed use, residential, and neighborhood serving commercial
General Corridor, Neighborhood Serving Corridor,
Medium Density Multifamily
Mixed Use Corridor 2 50 du/ac 3.0 Moderate-scale mixed use, residential, and neighborhood serving commercial
General Corridor, Industrial Park, Industrial, Light
Industrial, Medium Density Multifamily
Mixed Use Industrial 65 du/ac 2.0 A broad range of mixed use, residential, and industrial
Industrial, Light Industrial
Mixed Use Medium 65 du/ac 3.0 A broad range of mixed use, residential, and commercial
Regional Center, General Corridor, Community
Serving Center, Downtown, Industrial
Mixed Use High 100 du/ac 4.0 Large-scale mixed use, residential, and commercial
Regional Center, Community Serving Center, General
Corridor
Special Uses
Studio N/A Varies, maximum
established by project
Private studio campus with corporate
headquarters, offices, facilities, and sets
Studio
Institutional N/A 4.0 Public facilities, including but not limited to government offices, community facilities, and
hospital uses
Institutional, Downtown (City Hall, Fire Station),
Medium Density Multifamily (City Hall, Police
Department, etc.)
Open Space N/A 0.5 Parks and recreation complexes Open Space, Ballona Creek Cemetery N/A 0.5 Cemeteries Cemetery
Transportation N/A 0.5 Transportation, transition, and buffer uses Transportation SOURCE: Raimi + Associates, 2023

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Residential
The General Plan Update establishes the dwelling units per acre (du/ac) to calculate the maximum number of primary dwelling units for residential density. Accessory dwelling units (ADUs) are not counted toward calculating density. The residential unit density is calculated based on net area of the parcel, which excludes dedicated streets and private easements. Under limited circumstances, an increase in density above the maximum allowable density can occur, such as density bonuses for affordable housing, as well as other incentive-based local ordinances that implement the goals of the General Plan.

The General Plan Update includes five residential land use designations in order to provide for development of a range of housing types.

Single-Family Residential
Single Family Residential designation allows detached single-family dwellings with a maximum density of 8.7 du/ac. Additional units are permitted through the City’s ADU Ordinance, SB 9 implementation, and Infill.

Two Family Residential
Two Family Residential designation allows single-family dwellings and duplexes with a maximum density of 17.4 du/ac. The Two Family Residential designation is intended to maintain the character of existing neighborhoods, while allowing the opportunity for two-family residential development.

Low Density Multifamily
The Low Multi-Family designation applies to existing mixed-density neighborhoods and allows a maximum density of 35 du/ac. These units can be configured into a variety of housing types, including low- and medium-density multifamily housing.

Medium Density Multifamily
The Medium Multi-Family designation applies to existing mixed-density neighborhoods and allows a maximum density of 50 du/ac. These units can be configured into a variety of housing types, including low- and medium-density multifamily housing.

High Density Multifamily
High Density Multifamily designation allows a maximum density of 100 du/ac. These dwelling units can be configured into a variety of multifamily housing types.

Mixed Use
Five mixed-use designations are established to encourage a mixture of land uses, including residential, commercial, retail, industrial, and public spaces serving both residents and visitors.

Mixed Use Corridor 1
Neighborhood/Corridor Mixed Use (MU) 1 is located primarily along existing commercial corridors with smaller lot sizes. This designation allows for lower-scale, mixed use, as well as stand-alone residential and commercial developments serving surrounding neighborhoods and

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
visitors from nearby areas. The maximum density is 35 du/ac for residential components and the maximum non-residential intensity is 2.0 FAR.

Mixed Use Corridor 2
Neighborhood/Corridor MU 2 is located primarily in the Arts District industrial area, and existing commercial/industrial corridors with larger lot sizes, such as Jefferson Boulevard and Sepulveda Boulevard. This designation allows lower-scale mixed use, as well as stand-alone residential and commercial developments serving surrounding neighborhoods and nearby areas. The maximum density is 50 du/ac for residential uses and the maximum non-residential intensity is 3.0 FAR.

Mixed Use Industrial
Mixed Use Industrial is located in the Hayden Tract Industrial Area and portions near TOD and along Jefferson Boulevard. This designation allows for residential, mixed use, and light industrial uses that are compatible with residential, such as creative office, research and development.

Industrial mixed-use districts will continue to serve as a creative anchor in the City, providing opportunities for legacy and new creative businesses, fostering architectural and arts innovation, and accommodating new residential uses. The maximum density is 65 du/ac for residential uses and the maximum non-residential intensity is 2.0 FAR.

Mixed Use Medium
Mixed Use Medium is located primarily in Downtown and existing larger commercial and office centers. This designation allows medium scale mixed use, as well as stand-alone residential and commercial developments serving surrounding neighborhoods and nearby areas. The maximum density is 65 du/ac for residential uses and the maximum non-residential intensity is 3.0 FAR.

Mixed Use High
Mixed Use High is located primarily in the Culver City Metro E Line station area and existing larger commercial and office centers. This designation allows large scale mixed use, as well as stand-alone residential and commercial developments. The maximum density is 100 du/ac for residential uses and the maximum non-residential intensity is 4.0 FAR.

Special Purpose
There are five special purpose land use designations to identify public spaces and resources unique to the City.

Studio
The Studio designation recognizes the long-standing existence of studio uses within Culver City.

It is designed and intended to encourage and support studio and media businesses, while ensuring their future expansion will minimize potential impacts on adjacent residential land uses. The Studio designation recognizes the unique densities, uses and relationships of activities on a studio lot, which are addressed specifically through a comprehensive plan.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Institutional
The Institutional designation allows for existing operations and future expansion of institutional uses including hospitals, schools, and government facilities. Densities and uses will vary depending on the type of development. The maximum non-residential intensity is 4.0 FAR.

Open Space
The Open Space designation is established to protect Culver City's open space resources that include public or private land. It is designed and intended to preserve existing and encourage future parks, open space and recreation opportunities. Associated structures should not exceed a maximum non-residential intensity of 0.5 FAR.

Cemetery
The Cemetery designation recognizes the long-standing existence and the future continuance of the Hillside Memorial and Holy Cross Cemeteries in the Fox Hills and Southern- Central Sub-Areas.

It is intended to protect their future existence and to allow anticipated and well-planned expansion.

Associated structures should not exceed a maximum non-residential intensity of 0.5 FAR.

Transportation
The Transportation designation is established for properties that are either located in or adjacent to a right of way or roadway. This designation is intended to allow appropriate transportation, transitional, and buffer uses. Associated structures should not exceed a maximum non-residential intensity of 0.5 FAR.

Growth Projections
The General Plan Update and analysis contained within this PEIR are based on certain assumptions pertaining to future growth through the horizon year 2045. This PEIR analyzes the 2045 growth projections based on an understanding of historic, current, and projected demographic and economic conditions in the Planning Area through 2045, rather than full buildout. The full buildout scenario would assume that every parcel would be developed with the maximum amount allowed under the General Plan Update. Actual development that may occur by the horizon year is typically less than the theoretical maximum of development.

Table 2-3, General Plan 2045 Population, Household, and Job Growth Projections, provides the growth projections for population, housing, and jobs under the General Plan Update. Table 2-3 also shows the net change compared to the existing population, households, and jobs in the City and a comparison of the General Plan Update to the Culver City 1996 General Plan growth projections. As shown therein, the General Plan Update projects a population of 62,400 persons in 2045, which would be an increase of 21,760 persons, compared to the existing (2021) population.2 The General Plan Update also projects 28,310 households in 2045, for an increase of 11,310 households compared to the existing (2019) household count. In addition, the General

2 The existing conditions background reports completed in 2019 established the baseline used in this PEIR and provides a conservative analysis by assuming additional growth compared to an updated baseline year. However, when developing the Growth Projections, an updated baseline (2021) is utilized for residential housing.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Plan Update projects 84,300 jobs in 2045, which would be an increase of 16,260 jobs compared to the existing (2019) job count.

TABLE 2-3
GENERAL PLAN 2045 POPULATION, HOUSEHOLD, AND JOB GROWTH PROJECTIONS Existing
1996 General Plan
Projections (2010)
General Plan 2045
Projections
Net Change (General
Plan 2045 – Existing)
Population 40,800 (2020) 41,330 62,400 21,600
Households 17,000 (2019) N/A 28,310 11,310
Jobs 68,040 (2019) 56,743 84,300 16,260
NOTE: The 1996 General Plan does not project households.

SOURCES: Raimi + Associates, Preferred Plan Growth Projections, May 2023; U.S. Census Bureau, American Community Survey 5- Year Estimates, 2017–2021; City of Culver City, existing land use data, 2019.

Table 2-4, General Plan 2045 Projections by Land Use, identifies anticipated residential land use changes and corresponding changes for nonresidential uses that would occur between 2019 and 2045 with implementation of the General Plan Update. As shown therein, implementation of the Project is anticipated to result in a net increase of 12,706 residential units, 2,682,400 square feet of commercial uses, and 625,700 square feet of industrial uses. No change is projected for institutional square footage. As described in the Land Use Approach above, intensification of land uses is expected within the Planning Area resulting from infill development and redevelopment, thereby resulting in more overall construction. A discussion of each of these land uses is provided below.

TABLE 2-4
GENERAL PLAN 2045 PROJECTIONS BY LAND USE
Land Use Existing (2019) New
General Plan 2045
Projections
Net Change (General
Plan 2045 – Existing)
Residential 17,010 units 12,700 units 29,710 units 12,700 units Commerciala 28,624,900 sf 5,968,000sf 31,956,900 sf 3,332,000 sf Industrial 1,881,100 sf 679,700 sf 2,245,900 sf 364,800 sf Institutional 3,076,600 sf 0 sf 3,076,600 sf 0 sf
NOTES: sf = square feet
a Studio uses, which are a defined General Plan land use designation, are included in the commercial square footage.

SOURCES: Raimi + Associates, Preferred Plan Growth Projections, November 2022; City of Culver City, existing land use data, 2019.

Residential Development
As shown in Table 2-4, the General Plan Update would result in an estimated 12,700 new housing units in the Planning Area by 2045, bringing the total number of housing units to approximately 29,710. The total housing unit number was calculated by considering existing housing units as of 2019, the City’s ADU permitting history, the Housing Element’s projection of SB 9 unit construction, pipeline projects (projects that are under construction, have been entitled, or are in the planning stage), and projected new housing units. The number of new

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
housing units was derived by analyzing a realistic number of potential units that can be built given the development standards for each land use designation compared to historical density growth patterns. Therefore, the total projected housing units includes new infill, accessory dwelling units (ADUs), housing on opportunity sites, pipeline projects, and existing residential units to remain.3 This new development is projected to accommodate an increase in population of 21,600 people, for a total projected population of 62,400 by 2045.4 Non-Residential Development
As shown in Table 2-4, the General Plan Update would result in a net increase of 3.7 million square feet of non-residential development in the Planning Area by 2045. Of this approximately

3.3 million square feet of space would be added in the form of commercial corridor development. In addition, approximately 364,800 square feet of industrial uses are anticipated to be added, and no increase in institutional use is anticipated. This increase in commercial and industrial development was calculated by using the square footage of non-residential square footage that could be built on vacant or underutilized land and would serve the anticipated increases in housing and jobs.

In the Planning Area as a whole, about 16,260 new jobs are projected by the year 2045, raising the total number of jobs from 68,040 in 2019 to approximately 84,300 in 2045. The net change in jobs in Table 2-3 was calculated by applying an assumed job density factor (total employees per acre) for each non-residential land use. Non-residential building area, job sector projections by 2045 for Culver City, and input from the City were utilized in developing the job density factor.

While additional construction may occur within existing non-residential areas in the form of infill and redevelopment, the analysis in this PEIR is based on the net change of land uses within the Planning Area and operations of those land uses through the year 2045.

Community Health and Environmental Justice
Community Health, and Environmental Justice Element provides goals and policies related to the equitable distribution of resources and provision of health within the Planning Area. This element also addresses the requirements of SB 1000, which requires local jurisdictions to address environmental justice, and to identify “SB 1000 Priority Neighborhoods”, which are defined as those communities that are disproportionately burdened by multiple sources of pollution and that face disproportionate impacts of climate change. Clarkdale and Culver/West are identified as “SB 1000 Priority Neighborhoods” because they are low-income areas facing housing pressures, including a high risk of displacement and potentially disproportionate affects from environmental pollution and other hazards.

Housing
The Housing Element of the City's General Plan is the primary planning guide to meet the housing needs of everyone in Culver City. It outlines goals, policies, and programs to meet these

3 The number of residential units anticipated for each of these categories is identified in the Housing Element. 4 Population projections were derived using a household occupancy of 1.8 persons/household for existing residential units to remain and 2.5 persons/household to anticipated new development.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
needs while balancing other community objectives and resources. While the Housing Element was adopted in 2021, the General Plan Update serves as the implementation mechanism for the Housing Element through the amendments to the Land Use Map, shown in Figure 2-5 above, which would support the City’s efforts to meet the State-mandated Regional Housing Needs Allocation (RHNA). The total housing growth need for the City of Culver City during the 2021– 2029 planning period is 3,341 units. As shown in Table 2-4 above, the Project is anticipated to result in 12,700 additional housing units by 2045.

Mobility
The Mobility Element establishes a policy framework and proposed 2045 citywide network for all transportation modes and provides the Mobility Plan, which establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi-modal circulation. The Project has adapted Multimodal Street Classification principles to transition from a highway-centric functional classification system to better integrate land use context and non-motorized transportation components in the transportation network. The Project includes modal priority and special roadway designation typologies that enable the reallocation of public right-of-way to promote and encourage safe use of alternative transportation modes. These Special Classification are shown in Table 2-5, Special Roadway Classifications.

The mobility network presented within the Mobility Element will be referenced and built upon by future and recurring development and capital planning processes. The Mobility Element also designates truck routes in order to facilitate goods movements while minimizing travel through residential streets. The analysis in this PEIR is based on the planned circulation network and truck route network shown in Figure 2-7, Roadway Network & Classification Map, and Figure 2-8, Truck Route Network.

The existing mobility network does not provide an equitable distribution of benefits and costs to all residents. Therefore, the Project helps to operationalize equity indicators within priority implementation and funding decisions to ensure future investments address gaps in underinvested areas and for the most vulnerable travelers. It also highlights targeted investments in SB 1000 Priority Neighborhoods,
5 such as high frequency transit service and
pedestrian safety projects at major intersections, to improve transit efficiency and reliability, create safer pedestrian environments to promote walking, and expand first- and last-mile

mobility options near key commercial areas. The policies and actions in the Mobility Element also prioritize improvements that seek to increase physical activity and improve access to healthcare and social services, schools, employment, and healthy foods. The Project also identifies planned pedestrian, multi-modal, and transit improvements for the city, which are shown on Figure 2-9, Pedestrian Network; Figure 2-10, Bicycle Network; Figure 2-11, Transit Network; and Figure 2-12, Emerging Mobility Network.

5 For more information on SB 1000 neighborhoods, see the Community Health and Environmental Justice Element.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 2-5

SPECIAL ROADWAY CLASSIFICATIONS
Classification Configuration/Guidelines Modal Priority
Truck Route
(Existing)
Threshold based on access / egress routes to ports and State of California Truck Route Network interstates / freeways or local needs for moving commercial goods
n/a
Active Transportation
Corridor (New)
Thresholds to implement active transportation infrastructure and safety treatments consider local factors, such as:
• High pedestrian and/or bicycle volume counts
• High collision and fatality rates
Vehicle: Med
Transit: Med
Bicycle: High
Pedestrian: High
Transit Priority
Corridor (New)
Thresholds to implement transit priority treatments consider local factors, such as:
• High frequency transit service and use
• High transit delay due to congestion
• Future mobility patterns and demands
• Adjacent land uses, including Transit Oriented Community (TOC) objectives
• Regional high-capacity transit investments
• Transit priority corridor or bus rapid transit corridor as identified in regional plans and studies
Vehicle: Med
Transit: High
Bicycle: Med
Pedestrian: High to Med
Car-Free Zones
(Vacated Streets)
(New)
Thresholds for vacating automobiles from roadways (and segments of roadways) consider alternative mobility network connectivity and accessibility, including the proximity of:
• Transit Priority Corridors
• Active transportation Corridors
• TOC and Transit Oriented Development (TOD) improvements Vehicle: n/a
Transit: Med
Bicycle: High
Pedestrian: High
SOURCE: City of Culver City, Draft Mobility Element, Raimi + Associates, 2023. “Other” considerations may include provisions for parking, median, access management issues, etc.

Parks, Recreation, and Public Facilities
The Parks, Recreation, and Public Facilities Element includes goals and policies related to improvements the City can undertake to improve access, amenities, and funding for the park and recreational resources within the Planning Area. The City maintains and operates two community parks, seven neighborhood parks, and five parkettes/mini parks within City limits along with approximately 700 acres of other outdoor recreational spaces within the Planning Area including public plazas, parks and recreation areas owned by other agencies, joint use facilities, and privately owned public open spaces. The City’s park service standard aims to provide 10 acres of park space per 1,000 residents. More specifically, 1 acre per 1,000 residents may be satisfied with joint use agreements with the CCUSD and 6 acres per 1,000 residents may be satisfied by regional parks, leaving at least 3 acres per 1,000 residents to be satisfied by City- owned parks. Based on a projected population of 61,600 in 2045, the City would need an additional 256 park acres to achieve its service standard. 6 6 Parks, Recreation, and Public Facilities Element, p. 138. §¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Roadway Network
Primary Arterial
Secondary Arterial
Major Collector
Minor Collector
Truck Route
Future Roadway Network & Classification
Local Street
FIGURE 26
198 Element 8
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Roadway Network
Primary Arterial
Secondary Arterial
Major Collector
Minor Collector
Truck Route
Future Roadway Network & Classification
Local Street
FIGURE 26
198 Element 8Culver City General Plan 2045
Figure 2-7
Roadway Network & Classi/f_ication Map
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator §¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Truck Network
Truck Route
Corridors Supporting Goods MovementFIGURE 31
210 Element 8
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Truck Network
Truck Route
Corridors Supporting Goods MovementFIGURE 31
210 Element 8Culver City General Plan 2045
Figure 2-8
Truck Route Network
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator !
!
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!
!
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!
!
!
!!
!
!
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!
!
!
!
!!
! !
!
!
!
!
!
!
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Pedestrian
Network
Private School
Ballona Creek Crossing
Active Transportation Corridor
Safe Routes to School (SRTS) Improvement Zone
Future Pedestrian Facilities
!
!
Public School
FIGURE 27
201Mobility
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!!
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!
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!
!!
! !
!
!
!
!
!
!
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Pedestrian
Network
Private School
Ballona Creek Crossing
Active Transportation Corridor
Safe Routes to School (SRTS) Improvement Zone
Future Pedestrian Facilities
!
!
Public School
FIGURE 27
201Mobility Culver City General Plan 2045
Figure 2-9
Pedestrian Network
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator !
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!
!
!
!
!
!
!!
! !
!
!
!
!
!
!
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Bicycle Network
Private School
Existing Regional Bicycle Facility
Ballona Creek
Crossing
Active Transportation Corridor Safe Routes to
School (SRTS)
Improvement Zone
Future Bicycle Network
! Public School
!
*Bicycle network includes other forms of transportation vehicles such as scooters, e-bikes, etc.

Existing Class II: Bicycle Lane
Existing Class III: Bicycle Route
Existing Class I: Bike Path
Proposed Class I: Bike Path
Proposed Class II: Bicycle Lane
Proposed Class III: Bicycle Route
Existing Class IV: Separated Bikeway
Proposed Class IV: Separated Bikeway
FIGURE 28
204 Element 8
!
!
!!!
!
!
!
!
!
!
!!
!
!
!
!
!
!
!
!
!!
! !
!
!
!
!
!
!
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Bicycle Network
Private School
Existing Regional Bicycle Facility
Ballona Creek
Crossing
Active Transportation Corridor Safe Routes to
School (SRTS)
Improvement Zone
Future Bicycle Network
! Public School
!
*Bicycle network includes other forms of transportation vehicles such as scooters, e-bikes, etc.

Existing Class II: Bicycle Lane
Existing Class III: Bicycle Route
Existing Class I: Bike Path
Proposed Class I: Bike Path
Proposed Class II: Bicycle Lane
Proposed Class III: Bicycle Route
Existing Class IV: Separated Bikeway
Proposed Class IV: Separated Bikeway
FIGURE 28
204 Element 8Culver City General Plan 2045
Figure 2-10
Bicycle Network
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator To
Century
City
To
Century
City
To UCLATo UCLA
To AMC Station/
Airport People Mover
To AMC Station/
Airport People Mover
1 3
3 7
5 4
6 3
1 1
5 4
5 7
4 6
7 2
2 2
45 6R
6R
New
New
New
New
New
!
Westfield Culver
City Transit Center
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Transit
Network
Existing (2020) CityBus route to maintain in the future Existing (2020) CityBus route proposed for improved frequency Existing (2020) CityBus route proposed for future realignment New New CityBus route
Transit Priority Corridor
Future Rixed-Route Transit and HCT Improvements
Downtown and Jefferson Circulators
Circulators
Service Areas
Microtransit
FIGURE 29
205Mobility
To
Century
City
To
Century
CityTo UCLATo UCLA
To AMC Station/
Airport People Mover
To AMC Station/
Airport People Mover
1 3
3 7
5 4
6 3
1 1
5 4
5 7
4 6
7 2
2 2
45 6R
6R
New
New
New
New
New
!
Westfield Culver
City Transit Center
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Transit
Network
Existing (2020) CityBus route to maintain in the future Existing (2020) CityBus route proposed for improved frequency Existing (2020) CityBus route proposed for future realignment New New CityBus route
Transit Priority Corridor
Future Rixed-Route Transit and HCT Improvements
Downtown and Jefferson Circulators
Circulators
Service Areas
Microtransit
FIGURE 29
205Mobility Culver City General Plan 2045
Figure 2-11
Transit Network
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator ! !
!!
!
!
!
!
!
!
! !
! !
! ! !
!
!!
!
!
! ! !
!
! !
!
! !
!
!!
!! !
!
! !
!
!
! ! !
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Emerging Mobility
Network
Mobility Hub*
Microtransit Service Area
Downtown and Jefferson Circulators
Active Transportation Corridor
Emerging Mobility Network
Transit Priority Corridor
!
*Mobility Hub typologies (level of capital and service investments) have not been determined yet.

Ballona Creek Crossing
FIGURE 30
207Mobility
! !
!!
!
!
!
!
!
!
! !
! !
! ! !
!
!!
!
!
! ! !
!
! !
!
! !
!
!!
!! !
!
! !
!
!
! ! !
§¨¦
405
!(90
§¨¦
10 GreenValleyCir
0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

Overland Ave.Culver Blvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Parkway
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

Emerging Mobility
Network
Mobility Hub*
Microtransit Service Area
Downtown and Jefferson Circulators
Active Transportation Corridor
Emerging Mobility Network
Transit Priority Corridor
!
*Mobility Hub typologies (level of capital and service investments) have not been determined yet.

Ballona Creek Crossing
FIGURE 30
207Mobility Culver City General Plan 2045
Figure 2-12
Emerging Mobility Network
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-29 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The Parks and Recreation Element establishes policies to reduce inequities for residences within one half mile walking distance of a park or recreational facility, plans for parks and other outdoor recreational spaces in these neighborhoods, and establishes a performance metric to track the percentage of population within walking distance of a park. Implementation of the General Plan Update as well as adoption and continual updates to the City’s Park and Recreation Master Plan (PRMP) would provide direction and resources to make improvements to park and recreational resource quantity, quality, and access. The City has identified locations for planned or proposed trails and recreational facilities throughout the Planning Area, as shown in Figure 2-13, Planned and Proposed Park and Recreational Facilities.

The Parks and Recreation Element also includes goals and policies related to the provision of public facility, library, and school services when taking into account the anticipated population growth through 2045.

Infrastructure
The Infrastructure Element includes goals and policies that seek to ensure adequate infrastructure is provided, maintained, and expanded, to accommodate the growth projected for the Planning Area by 2045. This element addresses potable water, wastewater, stormwater drainage, and electricity and natural gas. Increased potable water demands to service the projected population growth translates to increased wastewater treatment flows. Therefore, the Infrastructure Element includes policies to reduce potable water use through conservation efforts and implementing greywater or blackwater treatment and reuse as there is currently no recycled water network in the city. Other policies in the Infrastructure Element include best practices for both small parcel and larger district scale stormwater management and groundwater recharge for stormwater infrastructure and the City’s transition to all-electric systems and provision of building scale solar for energy infrastructure.

Greenhouse Gas Reduction
The Greenhouse Gas Reduction Element includes goals and policies that address sustainability including greenhouse gas emissions, landfill disposal, water efficiency, and transportation. This element also includes goals and policies related to adaption and resiliency planning. As part of this element, a GHG emissions inventory was prepared in 2019 in order to track the city’s GHG emissions, set a baseline, and identify reductions needed to align with statewide targets.

Conservation
The Conservation Element provides goals and policies for the protection and preservation of cultural resources, including archaeological, and historic resources, paleontological resources, as well as biological resources, water resources, air quality, and mineral resources. The goals and policies of the Conservation Element also direct the city’s activities related to restoration of the IOF and revitalization of Ballona Creek as a recreational corridor. These policies will serve to protect and conserve environmental features within the City during implementation of Project.

GreenValleyCir

CULVER CITY

HIGH SCHOOL

FARRAGUT

ELEMENTARY
SCHOOL

VETERANS

MEMORIAL

COMPLEX

LA BALLONA

ELEMENTARY

CULVER CITY
MIDDLE
SCHOOL

EL RINCON

ELEMENTARY

EL MARINO

LANGUAGE SCHOOL

NEW POOL AT

THE MUNICIPAL
PLUNGE

LINWOOD
HOWE

ELEMENTARY
Stoneview
Nature CenterVeterans
Memorial ParkTellefson
Park
Culver West
Alexander Park
Culver
City Park
Blair Hills
Park
Carlson Park
El Marino
Park
Blanco
Park
Syd
Kronenthal
Park
Fox Hills
Park
Lindberg Park
Fox Hills
Parkette
Coombs
Parkette
Planned and
Proposed Park
and Recreational
Facilities
°0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Trails
Ballona Creek Trail Extension
Joint Use Facilities
CCUSD Facilities
West Los Angeles College
The Municipal Plunge
New lesson pool and upgrade
Veterans Memorial Complex
Bridging the aquatics center to the Teen Center

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 20
143Parks, Recreation, and Public Facilities
GreenValleyCir

CULVER CITY

HIGH SCHOOL

FARRAGUT

ELEMENTARY
SCHOOL

VETERANS

MEMORIAL

COMPLEX

LA BALLONA

ELEMENTARY

CULVER CITY
MIDDLE
SCHOOL

EL RINCON

ELEMENTARY

EL MARINO

LANGUAGE SCHOOL

NEW POOL AT

THE MUNICIPAL
PLUNGE

LINWOOD
HOWE
ELEMENTARY Stoneview
Nature CenterVeterans
Memorial ParkTellefson
Park
Culver West
Alexander Park
Culver
City Park
Blair Hills
Park
Carlson Park
El Marino
Park
Blanco
Park
Syd
Kronenthal
Park
Fox Hills
Park
Lindberg Park
Fox
Hills
Parkette
Coombs
Parkette
Planned and
Proposed Park
and Recreational
Facilities
°0 0.5 10.25
Miles
Sources: City of Culver City (2021);
County of Los Angeles (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Trails
Ballona Creek Trail Extension
Joint Use Facilities
CCUSD Facilities
West Los Angeles College
The Municipal Plunge
New lesson pool and upgrade
Veterans Memorial Complex
Bridging the aquatics center to the Teen Center

FIGURE XX
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 20
143Parks, Recreation, and Public Facilities Culver City General Plan 2045 Figure 2-13
Planned and Proposed Park and
Recreational Facilities
SOURCE: Draft Parks, Recreation, and Public Facilities Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Safety
The Safety Element addresses natural and human-made hazards by providing goals and policies that proactively advance community resilience. The Safety Element identifies actions that promote safety and reduce risks from natural and human-made hazards and climate change, while also ensuring an effective response and recovery from adverse events. The Safety Element also incorporates by reference the City’s Multi-Jurisdictional Hazard Mitigation Plan, which addresses evacuation planning in accordance with Assembly Bill (AB) 747. The Safety Element identifies potential environmental hazards that may be exacerbated by implementation of the Project and provides goals and policies to address those hazards such as seismic hazards, geologic hazards, flooding, wildfire, climate change, hazardous materials, aging buildings, and critical facilities.

Noise
The Noise Element sets goals and policies that ensure that noise and vibration from various sources, including construction, traffic, and stationary equipment, do not create an unacceptable noise and vibration environment. As the Land Use and Community Design Element lays out the plan for development and redevelopment within the city, these patterns contribute to construction noise and stationary noise sources from operation of certain land uses. In conjunction with the Mobility Element, the circulation pattern for the Planning Area also contributes to noise from mobile sources. The Noise Element includes goals and policies to ensure noise and vibration from both mobile and stationary sources preserve a peaceful noise environment within neighborhoods and have minimal impacts to structures, people, and equipment.

2.4.2 Zoning Code Update
The Zoning Code provides the mechanism to ensure that the goals and policies in the City’s General Plan are implemented through the development that occurs throughout the City over time. California Government Code Section 65860(a) requires that a jurisdiction’s zoning ordinance be consistent with its General Plan or any updates to its General Plan. Figure 2-14, Existing Zoning Map, shows the distribution of the existing zoning districts. These districts are associated with the adopted General Plan land use designations.

In light of the proposed changes in the General Plan Update, updates to the Zoning Code are necessary for consistency with the land use designations in the General Plan Update. The proposed Zoning Code Update would implement the new vision in the General Plan Update, changing from single-use commercial and industrial districts to mixed-use zones. Thus, the Zoning Code Update would implement the new land use designations that are in the General Plan Update. Table 2-6, Zoning Code Framework – Uses and Development Standards, shows the associated General Plan 2045 land use designations, the proposed zoning districts, and the existing zoning district. Figure 2-15, Proposed Zoning Map, shows the distribution of the proposed zoning districts.

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Culver City General Plan 2045
Figure 2-14
Existing Zoning Map
SOURCE: City of Culver City, July 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 2-6
ZONING CODE – USES AND DEVELOPMENT STANDARDS
General Plan
Designation
Implementing
Zone Max Density/FAR
Max
Height* Existing Zone (changes)
Residential
Single Family Single Family (R1) 8.7 du/acre

0.45 FAR
Flat roofs:
27 ft
Sloped
roofs: 30 ft
R1 (reduced residential FAR)
Two Family Two Family (R2) 17.4 du/acre 30 ft R2 (no expected change) Low Density
Multifamily
Low Density
Multifamily (RLD)
35 du/acre 32 ft R3, RLD, RMD (increased max density
from 26–29 du/acre to 35 du/acre,
height from 30 to 32 ft)
Medium Density
Multifamily
Medium-Density
Multifamily (RMD)
50 du/acre 48 ft RHD (increased max density from
29 du/acre to 50 du/acre, height from
40 to 48 ft)
High Density
Multifamily
High Density
Multifamily (RHD)
70 du/acre 56 ft New zone
Mixed Use
Mixed Use
Corridor 1
Mixed Use
Neighborhood
(MU-N)
35 du/acre

2.0 FAR
56 ft CN (height increased from 43 to 56 ft)
Mixed Use
Corridor 1
Mixed Use Corridor
1 (MU-1)
35 du/acre

2.0 FAR
56 ft CN, CG (height increased from 43–
56 ft to 56 ft)
Mixed Use
Corridor 2
Mixed Use Corridor
2 (MU-2)
50 du/acre

3.0 FAR
56 ft CN, CG, IL (height increased from 43–
56 ft to 56 ft)
Mixed Use
Mixed Use
Medium
Mixed Use
Downtown (MU-DT)
65 du/acre

3.0 FAR
56 ft CD (height increased from 30-56 ft to
56 ft)
Mixed Use
Medium
Mixed Use Medium
(MU-MD)
65 du/acre

3.0 FAR
56 ft CN, CG, CD, CC, CRB (height
increased from 30–56 ft to 56 ft)
Mixed Use High Mixed Use High
(MU-HD)
100 du/acre

4.0 FAR
56 ft CRB, CRR (height increased from 30–
56 ft to 56 ft)
Mixed Use
Industrial
Mixed Use Industrial
(MU-I)
65 du/acre

3.0 FAR
56 ft IG (height increased from 43 to 56 ft)
Special Purpose
Studio Studio (S) Varies, maximum
established by
project
56 ft Studio (No change)
Institutional Institutional (I) 4.0 56 ft Not in existing code Open Space Open Space (OS) 0.5 56 ft Open Space (No change) Cemetery Cemetery (E) 0.5 N/A Cemetery (No change)
Transportation Transportation (T) 0.5 N/A Transportation (No change) Various Planned
Development (PD)
N/A N/A PD (No change)
* Heights not to exceed 56 feet.

Culver City General Plan 2045
Figure 2-15
Proposed Zoning Map
SOURCE: City of Culver City, 2024; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 8 BUFSCPEZ
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2. Project Description
General Plan 2045 and Zoning Code Update Project 2-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The four existing overlays, Residential Zero Setback Overlay (-Rz), Redevelopment Project Area Overlay (-Rp), Civic Center Overlay (-Cv), and Residential Hillsides Overlay (-Rh) would not change. The Commercial Zero Setback overlay (-Cz) and East Washington Boulevard Overlay (-Ew) would be removed.

While the General Plan Update provides general characteristics and parameters of each land use designation, the Zoning Code Update would provide more specificity to guide the future development and provide clear parameters for applicants. Specifically, the Zoning Code Update, which would establish the zoning districts associated with each of the land use designations in the General Plan Update, would provide the specific development standards, including permitted and conditional uses, densities (units per acre), intensities (floor area ratio or FAR), setbacks, lot coverage, and building heights. The last column in Table 2-6 provides key development parameters in the Zoning Code Update compared with the existing development standards.

The Zoning Code Update would result in five residential zones with varying densities. The Single Family (R1) and Two Family (R2) zones would remain generally the same as in the existing code.

The multifamily residential zones would allow more density and increased building heights. The increase in density is necessary in order to implement the Housing Element and achieve the housing development to meet the 6th cycle RHNA allocation as well as future allocations.

The commercial and industrial areas would change from buildings with commercial or industrial uses to mixed-use developments. There would be a total of seven mixed use zones, which would allow residential uses at varying levels of density. The Zoning Code Update would introduce floor area ratio to regulate the intensity of nonresidential development. The Zoning Code Update would retain five existing special purpose zones and would add an Institutional zone.

As can be seen in Table 2-6, while the allowable building height would be increased in some zoning districts, the maximum height in the City would be 56 feet. Some areas that would have an increase in allowable building height include Mixed Use Industrial designated properties in the Hayden Tract, some properties along Jefferson Boulevard that are designated Mixed Use Industrial and Mixed Use Corridor 2. In addition, some parcels in the Fox Hills neighborhood that would be designated High Density Multifamily would have allowable height limits of up to 56 feet, which is greater than current allowable heights. Also, some properties designated Medium Density Multifamily in the Washington Culver neighborhood would have 48-foot height limits, which is greater than the current height limit in the area. However, as is currently the case, the maximum height in the Zoning Code Update would be limited to 56 feet. Exemptions to the 56- foot maximum height would still be allowed for future development that complies with the state’s density bonus law as determined during the project review process or with the height exception process described in the Zoning Code.

In addition, the Zoning Code Update would implement recent state laws related to various housing requirements. Finally, the Zoning Code Update would address streamline review processes for future development applications.

2. Project Description
General Plan 2045 and Zoning Code Update Project 2-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

2.5 Project Implementation

2.5.1 Required Permits and Approvals
The Project will require a recommendation from the Planning Commission to the City Council regarding certification of this PEIR and adoption of the General Plan Update and Zoning Code Update. The City Council will take the final actions on the Project. Future, subsequent development under the Project may require approval of federal, state, and responsible or trustee agencies that may rely on this PEIR for decisions in their areas of expertise.

2.5.2 Decision-Making Agencies
The Project sets high-level goals and policies to be used during the decision-making process when determining City priorities and during review of individual development proposals. The Zoning Code Update, in compliance with California Government Code Section 65860(a), would be consistent with the General Plan Update. Implementing the Project is the responsibility of the City Council, the Planning Commission, other City boards, committees and commissions, and City departments, as follows:
• City Council
• Planning Commission
• Planning and Development Department
• Public Works Department
• Transportation Department
• Additional City advisory committees, boards, and commissions Details on their powers and duties are in the City’s Municipal Code. The City will also need to consult with the County of Los Angeles and other public agencies about implementation proposals that affect their respective areas of jurisdiction.

2.5.3 Implementation Tools
The Project will be implemented through a variety of methods, including government programs initiated by the City, review of independent development proposals, and decisions made by the various City commissions, departments, and the City Council. Additional project specific environmental documents may be needed to evaluate site-specific environmental impacts in coordination with state and CEQA law.

General Plan 2045 and Zoning Code Update Project 3-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CHAPTER 3
Environmental Setting

3.1 Overview of the Environmental Setting
CEQA Guidelines Section 15125 requires that an EIR include a description of the physical environmental conditions in the vicinity of the Project, as they exist at the time the NOP is published, or if no NOP is published, at the time environmental analysis is commenced, from both a local and regional perspective. This environmental setting will normally constitute the baseline physical conditions by which a lead agency determines whether an impact is significant.

This chapter provides a general overview of the environmental setting for the Project. However, detailed information on existing conditions is provided for each environmental topic evaluated in Chapter 4, Environmental Impact Analysis. This chapter also provides a discussion regarding cumulative impacts analysis that is required in CEQA Guidelines Section 15130(a).

As described in Chapter 1, Introduction, the NOP for the Project was published on March 1, 2022, and a Recirculated NOP was published on February 15, 2024, in order to include the proposed Zoning Code Update to maintain compliance with the recently adopted housing element and comply with state law. Due to the long-term planning nature of a comprehensive General Plan Update, the environmental analysis commenced in 2019 and the information presented in the NOP and supporting Initial Study was based on existing conditions reports prepared in 2019.
1 Therefore, for analytic purposes in this Draft PEIR, the baseline year established for existing conditions is 2019 unless otherwise noted and the horizon year representing future conditions is 2045. In cases where current data is not available, the most recent known data is used to depict baseline conditions.

3.1.1 Existing Conditions
The approximately 3,910-acre Planning Area is comprised of two areas: the incorporated City of Culver City (3,280 acres) and the City’s Sphere of Influence (SOI) within unincorporated Los Angeles County (630 acres). Primary regional access is provided by three freeways; the San Diego Freeway (I-405), which runs north–south in the western part of the city, the Santa Monica

1 Existing conditions reports were developed to provide a baseline understanding of the existing conditions in Culver City as of the year 2019. These reports were published in Summer and Fall of 2020 and cover topics including:

Mobility and Transportation; Socioeconomic Profile and Market Analysis; Land Use and Community Design; Environmental Background; Housing; Arts and Culture; Parks, Public Facilities, and Public Services; Infrastructure; Smart Cities; Climate Hazards; Community Health and Environmental Justice; and Greenhouse Gas Inventories.

The existing conditions reports are available on the City’s website: https://www.pictureculvercity.com/resources.

3. Environmental Setting
General Plan 2045 and Zoning Code Update Project 3-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Freeway (I-10) which runs east–west, north of the city boundary and, the Marina Freeway (SR-90) which runs east–west in the western part of the city.

The Planning Area is currently largely developed with mostly residential uses, followed by commercial development, with other industrial and institutional uses as well. A large portion of the open space within the Planning Area is currently occupied by the Inglewood Oil Field (IOF).

The Planning Area is located approximately 1.5 miles from the Pacific Ocean and is relatively flat with areas of rolling hills that vary in elevation from 40 feet above mean sea level (amsl) in the western portion of the Planning Area to approximately 100 feet amsl in the central portion of the Planning Area. Baldwin Hills, located in the northeastern portion of the Planning Area, is the highest area within the Planning Area rising to above 400 feet amsl.

3.1.2 Surrounding Uses
The Planning Area is located within the western area of Los Angeles County, bounded by the City of Los Angeles to the north, west, and south, and unincorporated Los Angeles County to the east. Areas within the City of Los Angeles surrounding the Planning Area are largely developed with residential and commercial land uses. Areas within unincorporated Los Angeles County to the southeast of the Planning Area are developed largely with residential uses. Areas east of the SOI within unincorporated county include West Los Angeles College, undeveloped and open space lands east of La Cienega Boulevard including the Kenneth Hahn State Recreation Area, and other oil and gas plant areas located within Baldwin Hills.

3.2 Adopted General Plan and Zoning

3.2.1 Adopted General Plan Land Use Designations
The adopted General Plan consists of nine elements and their respective objectives, goals, policies, and implementation measures, which have been individually updated over the years since it was first adopted. Each of the nine elements include: Land Use (amended through 2000); Circulation (amended through 2004); Housing (adopted 2021); Open Space (adopted 1996); Noise (adopted 1996); Conservation (adopted 1973); Seismic (adopted 1974); Public Safety Element (adopted 1975); and Recreation (adopted 1968).

The adopted General Plan Land Use Element and accompanying Land Use Map provide the basis for the current land use designations and distribution in the City, which are shown in Figure 2-4, Existing General Plan Land Use Map. As shown in Figure 2-4, the City consists of 18 land use designations: Low Density Single Family, Low Density Two Family, Low Density Three Family, Low Density Multiple Family, Medium Density Multiple Family, Planned Residential Development, Neighborhood Serving Corridor, General Corridor, Downtown, Community Serving Center, Regional Center, Industrial, Industrial Park, Light Industrial, Open Space, Cemetery, Studio, and Institutional. Three focuses special study areas are also included for Blair Hills/Baldwin Hills Area, Hayden Industrial Tract, and Ballona Creek. The largest land use designation in terms of land area is Low Density Single Family, with Open Space occupying the second largest. Table LU-1 of the adopted Land Use Element shows a development potential of

3. Environmental Setting
General Plan 2045 and Zoning Code Update Project 3-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
571 additional housing units, for a total of 18,466 housing units. Table LU-3 of the adopted Land Use Element shows a development potential of 2,508,200 square feet of non-residential area for a total of 22,823,489 square feet of non-residential area.

Land use changes and consistency with local, regional, and state policies and plans are discussed in Section 4.10, Land Use and Planning.

3.2.2 Current Zoning
The Culver City Zoning Code (Title 17 of the Culver City Municipal Code) provides the basis for current zoning in the City. The City’s Zoning Map has 5 base zoning districts: residential, commercial, industrial, planned development, and special purpose; and 6 overlay zoning districts for residential and commercial setbacks, redevelopment areas, civic center, East Washington, and residential hillsides.

Reflecting the adopted general plan designations, the zoning designations that occupy the majority of the City include Single-Family Residential (R1) and Open Space (OS).

3.3 Cumulative Projects
CEQA Guidelines Section 15130(a) states that an EIR shall “discuss the cumulative impacts of a project when the project’s incremental effect is cumulatively considerable.” The CEQA Guidelines define cumulative impacts as “two or more individual effects that, when considered together, are considerable or which compound or increase other environmental impacts.” CEQA Guidelines Section 15355 further states that the individual effects can be various changes related to a single project or the change involved in a number of other closely related past, present, and reasonably foreseeable future projects.

CEQA Guidelines Section 15130 allows for the use of two different methods to determine the scope of projects for the cumulative impact analysis:
• List Method – A list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency. • Projections Method – A summary of projections contained local, regional or statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect.

The cumulative analysis provided in this Draft PEIR is based on the Projections Method. The Project consists of the General Plan Update and Zoning Code Update. Consistent with CEQA Guidelines Section 15130(b)(1)(B), this Draft PEIR analyzes the environmental impacts of development in accordance with the proposed Draft Land Use Plan (see Figure 2-6, Draft General Plan Land Use Map). As a result, this Draft PEIR addresses the cumulative impacts taking into account growth from the General Plan Update in the Planning Area, in combination with impacts from projected growth throughout the whole of Los Angeles County and the surrounding region, as forecasted in the adopted SCAG regional projections.

3. Environmental Setting
General Plan 2045 and Zoning Code Update Project 3-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The cumulative analyses for each environmental issue are provided in their applicable sections in Chapter 4, Environmental Impact Analysis, of this Draft PEIR.

General Plan 2045 and Zoning Code Update Project 4-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CHAPTER 4
Environmental Impact Analysis

4.0 Introduction to the Analysis

4.0.1 Introduction
The focus of this chapter is on the potential impacts that could occur as a result of the Project.

The sections included are those that have the potential to result in significant adverse impacts to the physical environment. The following sections are included in this chapter:
• Aesthetics (Section 4.1)
• Air Quality (Section 4.2)
• Biological Resources (Section 4.3)
• Cultural Resources (Sections 4.4)
• Energy (Section 4.5)
• Geology and Soils (Section 4.6)
• Greenhouse Gas Emissions (Section 4.7)
• Hazards and Hazardous Materials (Section 4.8)
• Hydrology and Water Quality (Section 4.9)
• Land Use and Planning (Section 4.10)
• Mineral Resources (Section 4.11)
• Noise (Section 4.12)
• Population and Housing (Section 4.13)
• Public Services (Section 4.14)
• Recreation (Section 4.15)
• Transportation (Section 4.16)
• Tribal Cultural Resources (Section 4.17)
• Utilities and Service Systems (Section 4.18)
• Wildfire (Section 4.19)
Based on the Initial Study, which is contained in Appendix A of this Draft PEIR, public comments received during the NOP circulation period, the Recirculated NOP period, and input received

4. Environmental Impact Analysis

General Plan 2045 and Zoning Code Update Project 4-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
during the Draft PEIR Scoping Meetings, it was determined that one issue area, Agriculture and Forestry Resources, would not be subject to potentially significant impacts due to implementation of the Project. There are a few questions within issue areas, such as air quality, biological resources, and noise, in which a particular question was evaluated in the Initial Study and it was determined that no further analysis was necessary. Please see Chapter 6, Other CEQA Considerations, of this Draft PEIR for a discussion of the issue areas for which a detailed analysis is not included and the basis for that determination.

4.0.2 Format of the Environmental Impact Analysis
Each section in this chapter addresses a specific environmental issue area as listed above and includes the following components:
• Environmental Setting: This subsection describes the physical characteristics and existing environmental conditions within and in the vicinity of the Planning Area. • Regulatory Framework: This subsection presents information on the laws, regulations, plans, and policies that relate to the issue area being discussed. Regulations originating from federal, State, regional, and local levels are discussed as appropriate. • Thresholds of Significance: This subsection presents the criteria established by the Lead Agency to identify at what level an impact would be considered significant thereby requiring implementation of mitigation measures.
• Methodology: This subsection provides a description of the methodology used for the analysis of the environmental issue addressed in the section. • Project Impact Analysis: This subsection provides an analysis of the nature and extent of potential Project impacts. These analyses address direct (or primary) effects of the Project as well as the indirect (or secondary) impacts, as necessary. This subsection also provides applicable proposed General Plan Goals and Policies that may reduce or eliminate Project impacts.
• Mitigation Measures: This subsection provides mitigation measures, if necessary, to reduce or eliminate significant impacts identified in the analysis of Project impacts. • Level of Significance after Mitigation: A discussion of the significance of each impact after mitigation is provided.
• Cumulative Impacts: A discussion of the effects of the Project when combined with the effects of cumulative projects, which include the cumulative projections for the region. The approach to addressing cumulative impacts, using the projection approach, is described in Chapter 3, Environmental Setting, of this Draft PEIR.

4.0.3 Terminology Used in this PEIR
In evaluating the impacts of the Project, the impact is determined by applying the evaluation criteria, or threshold of significance, presented for each resource area. The following terms are used to describe the effect:
• Threshold of Significance: A threshold of significance is a criterion applied by the Lead Agency to identify significant adverse environmental impacts. A threshold is defined by a

4. Environmental Impact Analysis

General Plan 2045 and Zoning Code Update Project 4-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Lead Agency based on guidance found in CEQA or the CEQA Guidelines, scientific and factual data relative to the Lead Agency jurisdiction, views of the public in affected areas, the policy/regulatory environment of affected jurisdictions, and other factors. • Less than Significant Impact: A less than significant impact does not result in a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (see CEQA Guidelines Section 15382). Impacts determined to be less than significant do not require mitigation measures. • Significant Impact: Public Resources Code (PRC) Section 21068 defines a significant impact as “a substantial, or potentially substantial, adverse change in the environment.” The environmental checklist included as Appendix G of the CEQA Guidelines provides additional guidance for determining which impacts would be regarded as significant. This EIR applies the thresholds contained within Appendix G and identified in each section’s “Thresholds of Significance,” and uses the CEQA definition of “significant impact.” Feasible mitigation measures or alternatives to the Project must be identified and adopted if they would avoid or substantially reduce the significant impact.
• Significant and Unavoidable Impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the decision-making agency would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the decision-making agency considered in approving the project notwithstanding the potential for significant environmental impacts.

Mitigation measures are measures identified to avoid or reduce a significant impact that has been identified through environmental analysis. Mitigation measures generally include the following provisions:
• Avoiding the impact by not taking a certain action or parts of an action; • Minimizing the impact by limiting the degree or magnitude of the action and its implementation;
• Rectifying the impact by repairing, rehabilitating or restoring the affected environment; • Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and,
• Compensating for the effect by replacing or providing substitute resources or environments.

If mitigation measures are necessary, the mitigation measures will be included in a Mitigation Monitoring and Reporting Program (MMRP). The MMRP will be adopted by the City to ensure that the implementation of the mitigation measures can be tracked by the City to ensure compliance.

4. Environmental Impact Analysis

General Plan 2045 and Zoning Code Update Project 4-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.1-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.1 Aesthetics

4.1.1 Introduction
This section provides an analysis of the potential environmental impacts on aesthetics from implementation of the Project, including potential impacts related to scenic vistas, conflicts with applicable zoning and other regulations governing scenic quality, and light and glare. The section provides context regarding the Planning Area’s existing visual character and scenic resources, as well as relevant federal, regional, state, and local regulations and programs.

4.1.2 Environmental Setting
The Planning Area is located in the western area of Los Angeles County and is located approximately 5 miles east of the Pacific Ocean, 5 miles north of Los Angeles International Airport (LAX), and 8 miles west of downtown Los Angeles. The 315-acre Kenneth Hahn State Recreation Area borders the Planning Area’s eastern boundary and Ballona Creek runs through Culver City in a south-westerly direction from its origin near Cochrane Avenue and Venice Boulevard in the City of Los Angeles ending at the Pacific Ocean. The Planning Area is a highly developed urban environment, which constitutes the majority of the Planning Area’s visual character, as discussed in greater detail below.

Scenic Vistas and Viewsheds
The term “scenic vista” generally refers to visual access to, or the visibility of, a particular sight from a given vantage point or corridor. The City recognizes the value of preserving sightlines (view access) to designated scenic resources or subjects of visual interest from public vantage points. The subjects of valued or recognized views may be focal (meaning of specific individual resources), or panoramic (meaning broad geographic area). The nature of a view may be unique, such as a view from an elevated vantage point or particular angle. Existing views may be focused on a single feature, such as a building or garden, or panoramic encompassing a broad field of view, such as ocean/coastal views, distant mountain range, or hilltop ridgelines.

The topography within the majority of the Planning Area is generally flat with more elevated areas of the Planning Area located in the eastern portions of the Planning Area, including Blair Hills/Baldwin Hills, the Culver Crest and Fox Hills neighborhoods, and within the Sphere of Influence (SOI). While the Planning Area does not have any designated scenic vistas, the Blair Hills/Baldwin Hills offer expansive, long-range views as well as view corridors from Playa Street traveling northeast towards Overland Avenue, Elenda Street traveling northwest towards Culver Boulevard, and Jefferson Boulevard traveling south along Ballona Creek. In addition, the State of California’s Baldwin Hills Conservancy owns and operates the Baldwin Hills Scenic Overlook, which is within City limits.

Scenic Resources
Scenic resources typically involve prominent, unique, and identifiable natural features in the environment (e.g., trees, rock outcroppings, islands, ridgelines, channels of water, and aesthetically appealing open space) and cultural features or resources (e.g., regional or

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architecturally distinctive buildings, or structures that serve as a focal point of interest).

Pursuant to CEQA Guidelines Appendix G, this area of consideration includes specific mention of such natural or manmade features when they are located within the viewshed of a state scenic highway.

According to the California State Scenic Highway System Map, there are no designated or eligible state scenic highways in the Planning Area There are no adopted or eligible state scenic highways nor any designated historic parkways within the Planning Area. 1 However, the stretch
of State Route 1 (SR-1) that extends approximately from Venice Boulevard to Ozone Avenue is eligible for designation, which is located approximately 0.75 miles north from the western portion of Culver City.

Visual Character
Visual character is an impartial description of the defining physical features, landscape patterns, and distinctive physical qualities within a landscape. Visual character is informed by the composition of land, vegetation, water, and structure and their relationship (or dominance) to one another, and by prominent elements of form, line, color, and texture that combine to define the composition of views. Visual character-defining resources and features within a landscape may derive from notable landforms, vegetation, land uses, building design and façade treatments, transportation facilities, overhead utility structures and lighting, historic structures or districts, or panoramic open space.

The Planning Area consists of Culver City and its SOI, which is an unincorporated area of Los Angeles County located to the east of the City boundary in the Baldwin Hills area. The Planning Area is an urban, developed environment with open space and natural resources with the eastern portion of the Planning Area. Interstate 405 (I-405) runs in a north-south direction in the western part of the Planning Area and I-10 runs in an east-west direction just outside of the Planning Area to the north. State Route (SR) 90 intersects the Planning Area from the west and ends at Slauson Avenue in the Fox Hills neighborhood.

The Planning Area is a mix of residential, commercial, industrial, civic, institutional, park and open space, with associated transportation, and flood control and utility infrastructure. Open space accounts for the second highest amount of land in the Planning Area, with 633 acres or 19.8 percent of the land designated Open Space, although most of this acreage is within the SOI. Natural resources within the Planning Area include over 100 undeveloped acres of Blair Hills that are privately owned. Portions of Culver City Park, which abuts these undeveloped hillsides, also offer some habitat value. Of the Planning Area’s privately owned land, the 88 acres of cemetery property and land within and adjoining the public rights-of-way are considered to contribute to the urban design character of the city and are important visual open space resources. 2 1 California Department of Transportation (Caltrans). 2023. California State Scenic Highway System Map. https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa.

Accessed July 2023.
2 Culver City, 2004. Culver City General Plan Open Space Element, pg. OS-2. https://www.culvercity.org/Services/Building-Development/General-Plan. Accessed June 2023.

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The major boulevards and arterial streets that run through Culver City create a pattern of residential, non-residential, and mixed-use districts and include Slauson Avenue, Washington Boulevard, Sepulveda Boulevard, Jefferson Boulevard, National Boulevard, and Culver Boulevard. The parcels that line these corridors vary in size and use and almost all commercial buildings front one of these six corridors. The City’s main commercial corridor is Culver Boulevard in Downtown.

Within this framework of corridors and freeways, Culver City has a mix of mostly residential and commercial uses along with industrial and studio uses sprinkled throughout the central and eastern portions of the city. The western portion of the City is comprised of commercial, including regional commercial, and residential uses. The central portion of the City includes industrial and studio uses in addition to commercial and residential uses. Specifically, industrial uses are located along Jefferson Boulevard, adjacent to Ballona Creek, with pockets of industrial uses in the northeastern and central portions of the city and studio uses are located along the northern boundary of the city. Most of the eastern portion of the city includes the Inglewood Oil Field (IOF), which straddles both the city and the SOI, and cemetery use, though there are pockets of residential, office, and industrial uses in this area. Approximately 68 acres of the IOF, or 2 percent of the City’s total acreage, is located within the City’s boundaries. The other approximately 932 acres of the IOF are located within the SOI, along with designated open space.

Parks, recreational facilities, and open spaces are distributed throughout the city. The largest park facility is Baldwin Hills, which is owned and managed by the State of California through the Baldwin Hills Conservancy. Ballona Creek, a flood control channel, is approximately 9 miles long and runs from Los Angeles through the central portion of Culver City and out to the Pacific Ocean. Ballona Creek provides a unique opportunity to mitigate flooding, restore native ecologies, and serve as a scenic multi-purpose open space and recreational corridor.

Urban form, including street patterns, lot size, lot shape, and building footprints, in the Planning Area vary from neighborhood to neighborhood. This variation in urban form is due in part to the economic eras in which neighborhoods were built. Corridors, activity centers, and neighborhoods shape the city’s urban form. Collectively, these components of the built environment reflect the city’s history and evolving priorities, needs, and development models.

The city’s neighborhoods vary in size, layout, typology, and natural environment. Residential neighborhoods vary in building size and housing type but are largely characterized by small parcels that front two-lane neighborhood streets. With few exceptions, the neighborhood scale is smaller than the scale of development found on the corridors. In addition to the development scale, the design of building street fronts has changed over time. Homes in older neighborhoods typically have large street-facing windows, porches, or stoops, and prominent front doors. In the newer neighborhoods, wide driveways and street-facing garage doors contrast with older homes, where garages were typically set back from, or behind, the house with much narrower driveway aprons. These differences result in varied community character in different neighborhoods.

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Light and Glare
Sources of artificial lights that operate during evening and nighttime hours may include streetlights, illuminated signage, vehicle headlights, security lighting, outdoor lighting on residential and commercial buildings, and other point sources. Uses, such as residences and hotels, are considered light-sensitive because they are typically occupied by persons who have an expectation of darkness and privacy during nighttime hours and who can be disturbed by bright light sources.

Glare is primarily a daytime occurrence caused by the reflection of sunlight or artificial light from highly polished surfaces, such as window glass or reflective materials, and, to a lesser degree, from broad expanses of light-colored surfaces. Glare can also be produced during evening and nighttime hours by artificial light directed toward a light-sensitive land use. Activities, such as driving, and land uses, such as parks and residences, are considered glare sensitive as the presence of glare could interfere with vision and/or result in an irritant to these activities/uses.

Light and glare sources within the Planning Area are primarily associated with residential, commercial, and industrial land uses. In commercial and industrial areas, security lighting, streetlights, illuminated security and/or wayfinding signage, signs, and parking lots may produce light and highly reflective materials, such as shiny metals or glass, may cause glare at certain times of the day depending on the direction of the sun. In residential areas, streetlights, outdoor and security lighting would be typical light sources and glass might be a source of glare.

However, these sources of light and glare are typical for an urban setting and are not considered unique to the Planning Area.

4.1.3 Regulatory Framework
This section provides the relevant state, regional, and local regulations applicable to the Project.

There are no federal regulations which apply to the Project.

State
Senate Bill No. 743
Senate Bill (SB) 743, codified within Public Resources Code (PRC) Section 21099 et. seq., states that “Aesthetic (…) impacts of a residential, mixed-use residential, or employment center project on an infill site within a transit priority area shall not be considered significant impacts on the environment.” (PRC Section 21099(d)(1)). Pursuant to PRC Section 21099, aesthetic impacts do not include impacts to historic or cultural resources. Pertinent definitions applicable to PRC Section 21099(a) include:
• “Infill site” means a lot located within an urban area that has been previously developed, or on a vacant site where at least 75 percent of the perimeter of the site adjoins or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses.
• “Transit priority area” means an area within 0.5 miles of a major transit stop that is existing or planned, if the planned stop is scheduled to be completed within the planning horizon

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included in a Transportation Improvement Program adopted pursuant to Section 450.216 or 450.322 of Title 23 of the Code of Federal Regulations. • “Employment center project” means a project located on property zoned for commercial uses with a floor area ratio of no less than 0.75, located within a transit priority area. • “Major transit stop” is defined by PRC Section 21064.3 to mean a site containing an existing rail transit station, a ferry terminal served by either a bus or rail transit service, or the intersection of two or more major bus routes with a frequency of service interval of 15 minutes or less during the morning and afternoon peak commute periods.

Projects that meet the criteria set forth in PRC Section 21099(d), are exempt from findings of significance related to aesthetic impacts, including view, visual quality, and light and glare impacts as described in the CEQA Guidelines Appendix G questions used by the City as thresholds of significance related to aesthetics. While the Project does not meet these criteria, future development projects facilitated by the Project could be found exempt from aesthetic findings of significance related to aesthetic impacts if the future project meets the criteria established in PRC Section 21099.

California Scenic Highways
Appendix G of the CEQA Statute & Guidelines identifies substantial damage to a scenic resource within a California Scenic Highway as a potentially significant impact on the environment. As such the regulations for the establishment and maintenance of State Scenic Highways are set forth in Streets & Highways Code, section 260 et seq. The intent of the system is to establish the state’s responsibility for the protection and enhancement of California’s natural scenic beauty by identifying those portions of the state highway system, which, together with the adjacent scenic corridors, require special scenic conservation treatment. By designating scenic highways, the California Legislature assigns responsibility for the development of such scenic highways and for the establishment and application of specific planning and design standards and procedures appropriate to the location and extent of routes and areas requiring continuing and careful coordination of planning, design, construction, and regulation of land use and development, by state and local agencies, in order to protect the social and economic values provided by the state’s scenic resources. Streets & Highways Code, Section 263 establishes the system of State Scenic Highways and composes a list of the highways specified under the system. As indicated previously, there are no State Scenic Highways within the City of Culver City. 3 California Historic Parkways
Streets & Highways Code Section 280 regulates the designation and maintenance of the system of California Historic Parkways. To be designated as a Historic Parkway, a freeway must have (1) original construction completed prior to 1945; (2) features of historical significance as recognized by the State Office of Historic Preservation, including notable landmarks, historical sites, or natural or human achievements that exist or have occurred during the original

3 California Department of Transportation (Caltrans). 2023. California State Scenic Highway System Map. https://caltrans.maps.arcgis.com/apps/webappviewer/index.html?id=465dfd3d807c46cc8e8057116f1aacaa.

Accessed July 2023.

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construction of the parkway or in the immediately adjacent land area through which the parkway currently passes; (3) any portion of the highway or corridor bound on one or both sides by federal, state, or local parkland, Native American lands or monuments, or other open space, greenbelt areas, natural habitat, or wildlife preserves, or similar acreage used for or dedicated to historical or recreational uses; and (4) any portion of the highway traversed, at the time of designation and by Caltrans’s best count or estimate using existing information, by not less than 40,000 vehicles per day on an annual daily average basis. No designated Historic Parkways are located in the City of Culver City.

Regional
Los Angeles General Plan
The Los Angeles County General Plan applies to the SOI within the Planning Area, including the majority of the IOF. The Los Angeles County General Plan Land Use Element outlines the County’s Special Management Areas, which are areas requiring additional development regulations to prevent the loss of life and property and protect the natural environment and important resources. Scenic Resources in the unincorporated areas of the County are regulated by Hillside Management Area (HMA) policies as well as the corresponding HMA Ordinance. The County’s General Plan also protects ridgelines, scenic viewsheds, and areas along scenic highways. Scenic resources are addressed in greater detail in the Conservation and Natural Resources Element, which seeks to guide the long-term conservation of natural resources and preservation of available open space areas. Specific Scenic Resources policies include protecting ridgelines from incompatible development, encouraging development with a visual relationship to surrounding terrain and vegetation, and prohibiting outdoor advertising and billboards along scenic routes, corridors, and other scenic areas. For impacts related to the IOF, refer to Section 4.11, Mineral Resources, of this Draft PEIR.

Local
Culver City Urban Forest Master Plan
The Culver City Urban Forest Master Plan (UFMP) was adopted in 2015 to foster a robust and resilient urban forest. The UFMP articulates a clear vision for the future of Culver City’s urban forest based on analysis of the City’s historical and existing urban forest, as well as on synthesis of current research, best management practices and community input. The Plan provides guiding principles for both long-term and day-to-day management, comprehensive tree designations, technical standards, and resources for City and community members today and for the future. The UFMP provides recommendations for the City’s urban forest as well as a structured framework of five Action Areas and related Strategies to support achievement of this vision. The recommendations also address important functions of the urban forest including wayfinding and placemaking. It also identifies a “Tree Palette” of recommended tree species for Culver City, as a process for selecting certain species for each location in the City. Areas of greatest need are described as “Places of Priority.” Along with the other recommendations related to habitat and existing conditions, the UFMP’s Tree Palette and Designations provide a plan for creating a more resilient urban forest in Culver City. As a master list of all the species

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that are recommended for Culver City’s urban forest, the Tree Palette includes Ulmus parvifolia, or Chine Elm, and other researched tree species.

Culver City Municipal Code
Culver City Municipal Code (CCMC) Titles 15 and 17 include regulations related to aesthetics and visual character including art in public places, building heights, lighting, signage, and landscaping, as described below. Title 9 (General Regulations) of the CCMC includes regulations to ensure quality development throughout the city.

Art in Public Places
CCMC Section 15.06.100 et seq. establishes an Art in Public Places Program (APPP) to fund and develop cultural and artistic outlets to improve the environment, image, and character of the community. All new residential development of five or more units, and all commercial, industrial, and public building development projects, with a building valuation of $500,000 or more are subject to this requirement. The APPP allocation can be placed into a Cultural Trust Fund; used to commission original, site-specific artwork; used to donate artwork to the City; used to incorporate a Cultural Facility; or used to designate a building or portion thereof as “Architecture as Art.”
Building Height
CMC Section 17.300.025 provides the maximum building heights by zoning designation. In 1990, the City Council approved an initiative that limits building heights in commercial and planned development zones throughout the city to 56 feet. An exemption to the 56-foot maximum building height may be granted only by complying with the state’s density bonus law as determined during the project review process or with the height exception process described in the Zoning Code. For residential uses, the maximum building is limited to 3 stories and 40 feet or less; for commercial uses, the maximum building height is limited to 56 feet or less; for industrial uses, the maximum building heights is limited to 43 feet or less; and for Planned Development Zones, maximum building heights is limited to 56 feet or less. CCMC Section 17.300.025.C, Exceptions to Height Limits, allows non-habitable design elements, such as spires, turrets, towers, and similar architectural features to extend up to 13 feet, 6 inches above the height of the building.

CCMC Section 17.300.035.C.1, Screening of Utilities, requires mechanical equipment (e.g., air conditioning, heating, exhaust, and ventilation ducts), loading docks, refuse and recyclable materials storage areas, and utility services to be screened from public view from adjoining public streets and rights-of-way. The method of screening is required to be architecturally compatible with other on-site development in terms of colors, materials, and architectural style as determined by the Director.

Lighting
CCMC Section 17.300.040, Outdoor Lighting, requires that exterior lighting comply with the following conditions:

1. All lighting fixtures shall be architecturally integrated with the character of the structure.

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2. All lighting shall be energy-efficient and shielded or recessed so that direct glare and reflections are confined to the maximum extent feasible within the boundaries of the site and shall be directed downward and away from adjoining properties and public rights-of- way.

3. Permanently installed lighting shall not blink, flash, or be of unusually high intensity or brightness.

4. Timers, where acceptable, shall be used to turn off lights during hours when they are not needed.

5. Uniformity or, where appropriate, compatibility of lighting type (i.e., height, wattage, energy efficiency, base support, finish material, texture, color and style of poles and luminaires) shall be provided.

6. Landscaping and pedestrian walkway lights shall be low profile.

7. Freestanding light poles and luminaires shall not exceed a maximum height of 18 feet, or a lesser height determined by the Director, to mitigate any impacts to adjoining properties.

8. Security lighting shall be provided at all entrances/exits, except in a residential zone.

Signage
CCMC Section 17.330, Signs, provides a comprehensive system for the regulation of signs in the City in order to address community aesthetics, vehicular and pedestrian safety, property values, and the visual environment. Section 17.330.020.B, Table 3.5, and Section 17.330.025 identify the types of signs allowed in non-residential zoning districts and the corresponding maximum sign area, maximum sign height, maximum number of signs, location, and additional requirements. Section 17.330.030, General Requirements for All Signs, includes requirements for sign measurement (area and height), sign location, aesthetic design standards, sign illumination, installation, and maintenance standards. CCMC Section 17.330.050, Review Process and Appeals, identifies permit requirements, sign-related decisions and appeals, and other requirements for Comprehensive Sign Programs.

Landscaping
CCMC Section 17.310 provides landscaping regulations and standards to enhance landscaping, conserve water, provide landscape area requirements and general landscaping and irrigation requirements. CCMC Section 17.310.030 requires the preparation and submittal of a Preliminary Landscape Plan and Final Landscape Plan. The Preliminary Landscape Plan includes such features as proposed and existing buildings and structures; proposed parking areas; proposed landscaped areas; a calculation of total hardscape and planted areas; and preliminary list of plant materials.

The Final Landscape Plan identifies such features as plant materials; hardscaped and landscaped areas; water features and fences; existing and proposed buildings and structures; planting and installation details; irrigation design; and maintenance specifications.

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4.1.4 Project Impact Analysis
Thresholds of Significance and Methodology
Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant impact related to aesthetics if the project would:

Threshold AES-1: Have a substantial adverse effect on a scenic vista; Threshold AES-2: Substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic highway;
Threshold AES-3: In non-urbanized area, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point.) If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality;
Threshold AES-4: Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area.

The Initial Study (Appendix A) found that no potentially significant impacts related to substantially damaging scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a State Scenic highway (Threshold AES-2) would occur with implementation of the Project. Therefore, this issue is not studied further in this PEIR.

Methodology
The evaluation of aesthetics and aesthetic impacts is generally subjective by nature, and therefore the level of the Project’s visual impact is difficult to quantify. As such, this analysis was conducted qualitatively, assessing potential implications of implementation of the proposed General Plan Update on scenic views, existing visual character and scenic quality, and light and glare sources within the Planning Area. In addition, it is difficult to estimate the impact future development would have on scenic resources, since individual development projects are not known at this time and can be designed to be compatible with and/or enhance the aesthetic quality of an area. As such, the following analysis considers the overall changes to the land use pattern and the potential location of future development as well as the overall amount of new development at buildout of the Project.

Scenic Vistas
The analysis of scenic vistas includes a qualitative analysis of whether future development allowed under the Project would block views of valued visual resources and scenic vistas from public vantage points in the Planning area. For purposes of this analysis, when analyzing aesthetic impacts, views generally refer to visual access to, or the visibility of, a particular sight from a given vantage point or corridor. “Panoramic” views are considered vistas and provide visual access to a large geographic area, for which the field of view can be wide and extend into

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the distance. Panoramic vistas are usually associated with vantage points looking out over a section of urban or natural areas that provide a geographic orientation not commonly available.

Examples of panoramic views and vistas might include an urban skyline or mountain range. “Focal views” focus on a particular object, scene, setting, or feature of visual interest. Examples of focal views include public art/signs and notable buildings and structures.

Light and Glare
The analysis of light and glare describes the existing light and glare environments in the Planning Area, identifies the light- and glare-sensitive land uses, describes potential light and glare sources associated with future development under the Project, and qualitatively evaluates whether future development under the Project would result in a substantial increase in nighttime lighting and daytime glare as seen from sensitive uses within the Planning Area.

In addition, although the CEQA Guidelines do not provide a threshold pertinent to shade/shadow, a discussion of the effects of shade and shadow is provided under light and glare. The analysis is qualitative given that there is not a specific development project at this point in time.

Project Impact Analysis
Scenic Vistas
Threshold AES-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would have a substantial adverse effect on a scenic vista.

Impact Statement AES-1: While there are no designated scenic vistas in the Planning Area, there are long-range views and view corridors which could be impacted during construction and operation of future development that would occur under the Project. However, future development would be required to comply with the goals and policies of the General Plan Update that protect scenic vistas as well as with all applicable laws, regulations, and standards related to scenic vistas. Therefore, impacts related to a substantial adverse effect on a scenic vista would be less than significant.

General Plan Update
As discussed in Section 4.1.2, Environmental Setting, while the Planning Area does not have any designated scenic vistas, the Blair Hills/Baldwin Hills area, including the Baldwin Hills Scenic Overlook, offers expansive, long-range views. In addition, there are view corridors from Playa Street traveling northeast towards Overland Avenue; Elenda Street traveling northwest towards Culver Boulevard; and Jefferson Boulevard traveling south along Ballona Creek.

The Planning Area is mainly characterized by urban environments, and as a result, scenic vistas are mostly limited to open space, vacant natural areas, and parks. The General Plan Update introduces land use changes throughout the city, primarily through redevelopment and infill development due to the highly urbanized nature of the Planning Area and the limited amount of vacant land. Land uses proposed within the Planning Area include four main categories of land uses: activity centers, commercial corridors, residential neighborhoods, and parks/open space.

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The General Plan Update would continue to guide development with its goals and policies that ensure that opportunities to enjoy scenic views, parks, natural areas, and open space are either preserved or enhanced.

Due to the highly urbanized nature of the Planning Area, the majority of the future development that would occur under the General Plan Update would primarily occur on parcels that already contain existing development. The City’s primary approach to accommodating growth is to provide strategies for infill development and redevelopment within opportunity sites located in activity centers and along commercial corridors. By focusing development in infill areas, the General Plan Update relieves pressure to develop in open space and natural areas while adhering to the visual character of the existing neighborhoods. This approach allows for the preservation of open space views and the enhancement of urban views.

In addition, the General Plan Update includes several policies pertaining to preserving these resources and their scenic qualities. Policies include context-specific development standards that provide clear guidance for height limitations, bulk and massing controls for future development. For example, large opportunity sites and activity centers are locations where increase in development, including building height, would be appropriate. Policies address the need to study increasing building heights in certain areas of the city, including opportunity sites and in mixed use development areas (Policies LU-4.1 and LU-4.3) as well as near transit stations (Policy LU-1.8) and for small lots (Policy LU-3.3). Policies also address compatibility with surrounding neighborhoods (Policy LU-6.4) and implementation of the City View Preservation Ordinance (Policy LU-12.3). While the General Plan Update does not include maximum building heights it recognizes the relevance of development standards, including building heights, and includes proposed policies to study increasing building heights in certain areas of the city.

Building heights are addressed in the Zoning Code Update, which is discussed below.

In addition, individual development projects would be subject to development and planning review and would be required to comply with applicable regulations regarding aesthetic qualities such as building heights, building setbacks, lighting, landscaping, and signage. Thus, compliance with the applicable regulations would minimize effects to scenic vistas as future development occurs under the General Plan Update. As such, the approach of infill development and redevelopment to increase densities across the Planning Area in combination with implementing the goals and policies of the General Plan Update, impacts to scenic vistas would be less than significant.

Zoning Code Update
The Zoning Code Update would provide requirements for future development consistent with the General Plan goals and policies. The Zoning Code Update would establish the zoning districts associated with each of the land use designations in the General Plan Update and the specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and tailored building heights.

Currently, the maximum building height for commercial and planned development zones throughout the city is 56 feet. This maximum height was established in 1990 through a City

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Council approved initiative. An exemption to the 56-foot maximum building height may be granted only by complying with the state’s density bonus law as determined during the project review process or with the height exception process described in the Zoning Code. The Zoning Code Update would result in some increases in allowable building heights in limited areas throughout the city. Some areas would include some of the Mixed Use Industrial designated properties in the Hayden Tract including some properties along Jefferson Boulevard that are designated Mixed Use Industrial and Mixed Use Corridor 2. In addition, some parcels in the Fox Hills neighborhood that would be designated High Density Multifamily would have allowable height limits of up to 56 feet, which is greater than current allowable heights. Also, some properties designated Medium Density Multifamily in the Washington Culver neighborhood would have 48-foot height limits, which is greater than the current height limit in the area.

However, as is currently the case, the maximum height in the Zoning Code Update would be limited to 56 feet. Exemptions to the 56-foot maximum height would still be allowed for future development that complies with the state’s density bonus law as determined during the project review process or with the height exception process described in the Zoning Code.

As such, the Zoning Code Update would not result in a substantial adverse effect on a scenic vista. Future development would be reviewed by the City for compliance with applicable requirements and the mitigation measures referenced in other sections of this PEIR. Therefore, impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Land Use and Community Design Element
LU-1.8: Development standards near transit stations. Allow relaxed development standards within half a mile of high-quality transit, such as reduced setbacks and greater building height.

LU-3.3: Development standards review program. Evaluate and modify existing development standards that prevent development on small sites, e.g., setbacks and height transitions.

LU-4.1: Height limitations. Study increasing the height limit in certain areas of the city to support housing, affordable housing, and publicly accessible open space provision.

Study the introduction of additional development standards that provide clear guidance of bulk and massing controls. Standards could include floor plate limits, maximum façade lengths, step backs, or similar.

LU-4.3: Mixed use development. On large nonresidential sites, study relaxing of development standards and raising of height limits to allow concentrated, new vertical residential development to maintain existing commercial, industrial, and studio uses, and to create horizontal mixed use development on the site.

LU-6.4: Studio compatibility. Continue to implement design standards for neighborhood compatibility that regulate height, circulation, sound, and lighting.

LU-12.3: Views. Implement the City View Preservation Ordinance.

Mitigation Measures
No mitigation measures are required.

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Level of Significance after Mitigation
Not applicable. The Project would result in less-than-significant impacts related to a substantial adverse effect on a scenic vista.

Conflict with Applicable Regulations Governing Scenic Quality Threshold AES-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would conflict with applicable zoning and other regulations governing scenic quality.

Impact Statement AES-2: The Project would not conflict with applicable zoning and other regulations governing scenic quality and impacts would be less than significant.

General Plan Update
While the General Plan Update would increase densities and intensities of land uses, the majority of the proposed changes would occur within Culver City with limited land use changes occurring within the SOI. Proposed policies in the General Plan Update are intended to complement and improve the existing scenic quality and resources in the City as well as to implement the City’s vision for the future character of the City.

Future development under the Project would be reviewed for compliance with the goals and policies of the General Plan Update related to scenic quality, including scenic views and scenic resources. The General Plan Update includes policies intended to reduce impacts to visual character in and around the Planning Area and promote cohesive and visually appealing development consistent with the character of the city. Proposed policies aim to maintain design standards that provide clear guidance of bulk and massing controls for future development and require compliance with location-specific design guidelines (. In addition, building heights in certain zones are limited to 56 feet citywide as a result of the initiative passed in 1990. The General Plan Update includes proposed policies to study increasing building heights to support an increase in the housing stock, the inclusion of affordable housing and public open space provisions as well as increasing building height limits on large non-residential parcels to allow for new concentrated vertical residential development in certain areas of the city. However, as discussed above, building heights are not addressed in the General Plan Update, but are development standards in the Zoning Code Update. Future development under the Project within the SOI would be required to comply with the Los Angeles County General Plan and Code of Ordinances which contain provisions that would protect scenic resources.

Future development occurring under the proposed General Plan Update would be subject to regulations in the CCMC, which implements the City’s General Plan, and would be reviewed for compliance prior to project approval. The Zoning Code requirements and the Zoning Code Update are discussed below. Compliance with the policies of the General Plan Update and the CCMC would ensure that future development would be consistent with the scenic character and would not detract from the scenic quality of the city. For these reasons, impacts to scenic quality within the city would be less than significant.

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
In regard to the SOI, the designation in the General Plan Update would remain Open Space as the area is currently designated. The Los Angeles County General Plan and Municipal Code contain provisions that would protect scenic resources. With the applicable policies listed under Impact Statement AES-1, the General Plan Update would therefore, not substantially degrade the existing visual character or quality of public views of the SOI and its surroundings, and thus, the impact of the Project on scenic quality within the SOI would be less than significant.

Zoning Code Update
The Zoning Code Update would provide requirements for future development consistent with the General Plan goals and policies. The Zoning Code Update would provide the specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and tailored building heights consistent with the General Plan Update. As such, the Zoning Code Update would not conflict with the General Plan Update and other regulations governing scenic quality and visual character. The form and mass of future buildings would be dictated by the standards, including setbacks, FAR, building height, and lot coverage. While some increase in building height would occur in certain areas of the city, the maximum building heights throughout the city would be 56 feet, consistent with the initiative approved by City Council in 1990. In addition, CCMC Section 17.310 provides landscaping regulations and standards to enhance landscaping; CCMC Section 17.300.035.C.1 (Screening of Utilities), requires mechanical equipment, loading docks, refuse and recyclable materials storage areas, and utility services to be screened from public view; and CCMC Section 17.300.035.C.2 requires the method of screening to be architecturally compatible with other on-site development in terms of colors, materials, and architectural style. Future development would be reviewed by the City for compliance with applicable requirements and the mitigation measures referenced in other sections of this PEIR. Therefore, impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
See policies listed under Impact Statement AES-1.

Mitigation Measures
No mitigation measures are required.

Level of Significance after Mitigation
Not applicable. The Project would result in less-than-significant impacts related to conflicts with applicable zoning and other regulations governing scenic quality.

Light and Glare Impacts
Threshold AES-3: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would create a new source of substantial light or glare that would adversely affect day or nighttime views in the area.

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Statement AES-3: The Project would not create a new source of substantial light or glare that would adversely affect day or nighttime views in the area. Therefore, impacts would be less than significant.

General Plan Update
The General Plan Update includes an updated Land Use Element and Land Use Map, which would result in increased densities and intensities of land uses. New development would primarily occur on parcels that already contain some development. The primary approach to accommodating growth is to provide strategies for infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors.

Since the Planning Area is urban, future development under the Project would primarily occur on parcels that already contain uses that currently generate light and/or glare. However, future development under the General Plan Update would create new sources of light and glare within the Planning Area, which could contribute to increased ambient nighttime lighting conditions.

Specific sources of new lighting would include residential and non-residential interior and exterior lighting, parking lot lighting, and non-residential signage lighting, While future development would include additional lighting and/or materials that could cause glare, the addition of these light and glare sources would be consistent with the existing urban environment and would replace the previous onsite light and glare sources. Therefore, any increase in ambient nighttime light conditions would not be substantial and would not be out of character with the urban environment.

In addition, the General Plan Update includes policies requiring the use of low intensity lighting to reduce the amount of light reaching sensitive habitat, ensure neighborhood compatibility and reduce light and glare impacts in and around the Planning Area. The General Plan Update also includes policies to incorporate shielded or directed low level lights along the Ballona Creek path, parks and other open spaces in the city to promote safety and security while avoiding light spill and glare onto residential properties and habitats adjacent to the creek and ensure neighborhood compatibility (Policies C-6.5, C-6.7, C-2.8, LU-6.4, and PR-6.5). Nighttime lighting in parks would enable greater availability of facilities. Policy PR-2.4 would ensure that impacts from light exposure on nearby residents is avoided. In addition, future development under the Project would be required to comply with applicable regulations related to lighting to minimize the effects of new light sources.

The General Plan Update includes policies related to buffering between development and sensitive habitats, and between future development and existing uses. Adherence to design standards in the CCMC and other regulations would ensure that light and glare from future development and redevelopment projects facilitated under the General Plan Update would be minimized. As such, impacts related to light and glare would be less than significant.

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Zoning Code Update
The Zoning Code Update would establish new zoning districts and associated development standards to correspond with and implement the land use designations in the General Plan Update. Future development under the Zoning Code Update would be required to comply with applicable lighting regulations and standards. Such requirements include directing light to be oriented downward and to avoid any light spillover to adjacent properties; requiring that permanently installed lighting shall not blink, flash, or be of unusually high intensity or brightness; landscaping and pedestrian walkway lights shall be low profile; and that freestanding light poles and luminaires shall not exceed a maximum height of 18 feet, or a lesser height determined by the Director of Planning. Therefore, impacts regarding light and glare that could affect day or nighttime views in the area would be less than significant.

Applicable Proposed General Plan Goals and Policies
Conservation Element
C-2.8: Lighting near open spaces. Require that development near natural open space areas include low-intensity lighting to reduce the amount of light that reaches sensitive habitat.

C-6.5: Lighting along Ballona Creek. Incorporate shielded or directed low level lights along the Ballona Creek path to promote safety and security while avoiding light spill and glare onto residential properties and habitats adjacent to the Creek.

C-6.7: Design innovation along the Ballona Creek corridor. Encourage design innovation in new development along the Ballona Creek corridor while avoiding significant noise and lighting effects on residential uses adjacent to the Creek. For example, orient improvements towards the creek, landscape open space areas, include public art like murals, decks/overlooks, seating, shade, bicycle facilities, and connections to the Ballona Creek path.

Land Use and Community Design Element
LU-6.4: Studio compatibility. Continue to implement design standards for neighborhood compatibility that regulate height, circulation, sound, and lighting.

Parks, Recreation, and Public Facilities Element
PR-6.5: Vegetation management. Manage vegetation at parks and open spaces in Culver City to support biodiversity by reducing pesticide use, reducing light pollution, and planting native and non-native species that provide valuable resources for native wildlife and increase resilience.

Mitigation Measures
No mitigation measures are required.

Level of Significance after Mitigation
Not applicable. The Project would result in less-than-significant impacts related to creating a new source of substantial light or glare that would adversely affect day or nighttime views in the area.

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Supplemental Shading Discussion
Potential shading effects could occur when new structures are located in proximity to shadow- sensitive uses. The potential for shading is highest when a shadow-sensitive use is immediately adjacent to a new structure and decreases the further the sensitive use is located from a Project Site. The consequences of shadows on land uses can be positive, including cooling effects during warm weather or negative, such as loss of warmth during cooler weather and loss of natural light for landscaping and human activity.

Potential shading impacts could result when shadow-sensitive uses are located to the north, northwest, or northeast of new structures. Shading impacts are influenced by the height and bulk of a building or structure, the time of year, the duration of shading during the day, and the proximity of shade-sensitive land uses or receptors. As the sun moves from the east to the west throughout the day, shadow lengths and direction move accordingly. Shadows are longest during the winter, with the maximum length occurring during the Winter Solstice (December 22). During the spring, fall, and summer, shadow lengths are shorter than winter shadows.

Facilities and operations sensitive to the effects of shading include routinely usable outdoor spaces associated with residential, recreational, or institutional uses (e.g., schools, convalescent homes), commercial uses such as pedestrian-oriented outdoor spaces or restaurants with outdoor eating areas, nurseries, and existing solar collectors. These uses are considered sensitive because sunlight is important to function, physical comfort, or commerce.

Appendix G of the CEQA Guidelines does not provide screening questions that address impacts with regard to shading. Currently, the maximum building height allowed in the City is 56 feet, which would not change with the Zoning Code Update. However, under the Zoning Code Update some areas of the City would have an increase in the allowable building height. While some increase in building heights would occur in some of the zoning districts, the maximum building height in the City would be 56 feet. However, the City could require a shade/shadow analysis for a particular project as determined to be necessary. [Note to City: Please confirm and advise if there are any requirements we can cite]
[Note to City: Discussion needed regarding breezes]

4.1.5 Cumulative Impact Analysis
The geographic context for cumulative visual impacts that would occur under the General Plan Update is the Planning Area, including the SOI, and those areas in the immediate vicinity of the Planning Area boundaries which are visible from or have a clear view of the city, including the City of Los Angeles and an unincorporated area of Los Angeles County, known as Ladera Heights to the southeast. However, the primary contributor to potential visual changes in and surrounding the city is future development under the Project.

No state scenic highway is located within the southern region of Los Angeles County, including Culver City, and thus reasonably foreseeable growth within the central southern region of Los Angeles County, including Culver City, would not substantially damage scenic resources within

4. Environmental Impact Analysis

4.1 Aesthetics
General Plan 2045 and Zoning Code Update Project 4.1-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
the corridor of a state scenic highway. The Project would not contribute to a cumulative impact with respect to a state scenic highway would occur.

Future development and growth within this region of Los Angeles County, including the City, could have cumulative effects on the region’s aesthetic character, thus resulting in a significant cumulative impact. The Planning Area is characterized by residential, commercial, industrial and institutional uses, the IOF, public facilities, and parks. Development to accommodate future residents and jobs may impact scenic vistas should it encroach on open hillsides. Various proposed policies including those that address open space preservation and sensitive transitions between new and existing development would ensure that scenic quality is maintained in the City. Additionally, it is unlikely that significant growth would occur in the SOI. With compliance with applicable policies and regulations related to aesthetics, the cumulative impact would be less than significant. Therefore, the Project would not contribute to a cumulative significant impact related to scenic vistas and conflicts with applicable zoning and other regulations governing scenic quality in an urbanized area.

The City is in an urban area with numerous sources of nighttime lighting. The cumulative effect of existing development has resulted in a cumulative loss of available nighttime views (i.e., cityscape or foothills). However, the contribution of the Project to this cumulative impact would not be cumulatively considerable as growth anticipated under the General Plan Update would comply with applicable requirements that regulate the placement of exterior lighting and would comply with General Plan policies regarding buffering between development and sensitive habitats, and between new development and existing uses. Given the applicable goals, policies and regulations pertinent to lighting and illuminated signage, the Project would not contribute to a significant cumulative impact. Therefore, the Project would result in less-than-significant cumulative impacts related to aesthetic impacts.

4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.2-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.2 Air Quality

4.2.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on air quality from implementation of the Project, including potential impacts related to conflict with or obstruction of air quality plans, a cumulatively considerable net increase in criteria pollutants, and exposing sensitive receptors to substantial pollutant concentrations. The section provides context regarding the Planning Area’s existing criteria pollutants and emissions, as well as relevant federal, State, and local regulations and programs.

4.2.2 Environmental Setting
Regional Context
Criteria Pollutants and Effects
Certain air pollutants have been recognized to cause notable health problems and consequential damage to the environment either directly or in reaction with other pollutants, due to their presence in elevated concentrations in the atmosphere. Such pollutants have been identified and regulated as part of the overall endeavor to prevent further deterioration and facilitate improvement in air quality. The National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) have been set at levels considered safe to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly with a margin of safety, and to protect public welfare, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings. 1 As the scientific methods for
the study of air pollution health effects have progressed over the past decades, adverse effects have been shown to occur at lower levels of exposure. For some pollutants, no clear thresholds for effects have been demonstrated. New findings over time have, in turn, led to the revision and lowering of NAAQS which, in the judgment of the U.S. Environmental Protection Agency (USEPA), are necessary to protect public health. Ongoing assessments of the scientific evidence from health studies continue to be an important part of setting and informing revisions to federal and state air quality standards.
2 The six principal pollutants for which national and State criteria and standards have been promulgated, known as “criteria pollutants”, and which are most relevant to current air quality planning and regulation in the Air Basin include O
3, respirable and fine particulate matter (PM10
and PM2.5, respectively), carbon monoxide (CO), nitrogen dioxide (NO2), sulfur dioxide (SO2), and lead (Pb). These pollutants are referred to as “criteria air pollutants” as a result of the specific standards, or criteria, which have been adopted for them, as summarized in Table 4.2-1, Ambient Air Quality Standards.

1 USEPA, 2023. NAAQS Table, last updated on March 15, 2023. https://www.epa.gov/criteria-air-pollutants/naaqs- table. Accessed December 2023.
2 South Coast Air Quality Management District (SCAQMD), 2022. 2022 Air Quality Management Plan, Appendix I-154, Adopted December 2, 2022.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.2-1

AMBIENT AIR QUALITY STANDARDS
Pollutant Average Time
California Standardsa National Standardsb
Concentrationc Methodd Primaryc,e Secondaryc,f Methodg
O3
h 1 Hour 0.09 ppm
(180 µg/m3)
Ultraviolet Photometry — Same as Primary Standard Ultraviolet Photometry 8 Hour 0.070 ppm
(137 µg/m3)

0.070 ppm
(137 µg/m3)
NO2
i 1 Hour 180 ppb
(339 µg/m3)
Gas Phase
Chemiluminescence
100 ppb None Gas Phase
Chemiluminescence
Annual Arithmetic Mean 30 ppb
(57 µg/m3)
53 ppb Same as Primary Standard
CO 1 Hour 20 ppm
(23 mg/m3)
Non-Dispersive Infrared
Photometry (NDIR)
35 ppm
(40 mg/m
3)
None Non-Dispersive Infrared
Photometry (NDIR)
8 Hour 9.0 ppm
(10mg/m3)
9 ppm
(10 mg/m3)
8 Hour (Lake Tahoe) 6 ppm
(7 mg/m3)
— —
SO2
j 1 Hour 0.25 ppm
(655 µg/m3)
Ultraviolet Fluorescence 75 ppb
(196 µg/m3)
— Ultraviolet Fluorescence;
Spectrophotometry
(Pararosaniline Method)
9 3 Hour — — 0.5 ppm
(1300 µg/m3)
24 Hour 0.04 ppm
(105 µg/m3)

0.14 ppm
(for certain areas)j
—
Annual Arithmetic Mean — 0.030 ppm
(for certain areas) j
—
PM10k 24 Hour 50 µg/m3 Gravimetric or Beta
Attenuation
150 µg/m3 Same as Primary Standard Inertial Separation and Gravimetric Analysis Annual Arithmetic Mean 20 µg/m 3 — PM2.5k 24 Hour No Separate State Standard 35 µg/m3 Same as Primary Standard Inertial Separation and Gravimetric Analysis Annual Arithmetic Mean 12 µg/m 3 Gravimetric or Beta Attenuation

12.0 µg/m3k 15 µg/m3
Leadl,m 30 Day Average 1.5 µg/m3 Atomic Absorption — — High Volume Sampler and Atomic Absorption Calendar Quarter — 1.5 µg/m3
(for certain areas) m
Same as Primary Standard
Rolling 3-Month Averagem — 0.15 µg/m3

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Pollutant Average Time
California Standardsa National Standardsb
Concentrationc Methodd Primaryc,e Secondaryc,f Methodg
Visibility
Reducing
Particlesn
8 Hour Extinction coefficient of 0.23 per kilometer—
visibility of 10 miles or more (0.07–30 miles or
more for Lake Tahoe) due to particles when
relative humidity is less than 70 percent. Method:

Beta Attenuation and Transmittance through
Filter Tape.

No
Federal
Standards
Sulfates
(SO4)
24 Hour 25 µg/m3 Ion Chromatography
Hydrogen
Sulfide
1 Hour 0.03 ppm
(42 µg/m
3)
Ultraviolet Fluorescence
Vinyl Chloridel 24 Hour 0.01 ppm
(26 µg/m3)
Gas Chromatography
a California standards for ozone, carbon monoxide (except 8-hour Lake Tahoe), sulfur dioxide (1 and 24 hour), nitrogen dioxide, and particulate matter (PM10, PM2.5, and visibility reducing particles), are values that are not to be exceeded. All others are not to be equaled or exceeded. California ambient air quality standards are listed in the Table of Standards in Section 70200 of Title 17 of the California Code of Regulations.
b National standards (other than ozone, particulate matter, and those based on annual arithmetic mean) are not to be exceeded more than once a year. The ozone standard is attained when the fourth highest 8-hour concentration measured at each site in a year, averaged over three years, is equal to or less than the standard. For PM10, the 24-hour standard is attained when the expected number of days per calendar year with a 24-hour average concentration above 150 micrograms/per cubic meter (μg/m3) is equal to or less than one. For PM2.5, the 24-hour standard is attained when 98 percent of the daily concentrations, averaged over three years, are equal to or less than the standard. c Concentration expressed first in units in which it was promulgated. Equivalent units given in parentheses are based upon a reference temperature of 25°C and a reference pressure of 760 torr. Most measurements of air quality are to be corrected to a reference temperature of 25°C and a reference pressure of 760 torr; ppm in this table refers to ppm by volume, or micromoles of pollutant per mole of gas. d Any equivalent procedure which can be shown to the satisfaction of CARB to give equivalent results at or near the level of the air quality standard may be used. e National Primary Standards: The levels of air quality necessary, with an adequate margin of safety to protect the public health. f National Secondary Standards: The levels of air quality necessary to protect the public welfare from any known or anticipated adverse effects of a pollutant. g Reference method as described by the USEPA. An “equivalent method” of measurement may be used but must have a “consistent relationship to the reference method” and must be approved by the USEPA. h On October 1, 2015, the national 8-hour ozone primary and secondary standards were lowered from 0.075 to 0.070 ppm. i To attain the 1-hour national standard, the 3-year average of the annual 98th percentile of the 1-hour daily maximum concentrations at each site must not exceed 100 ppb. j On June 2, 2010, a new 1-hour SO2 standard was established and the existing 24-hour and annual primary standards were revoked. To attain the 1-hour national standard, the 3-year average of the annual 99th percentile of the 1-hour daily maximum concentrations at each site must not exceed 75 ppb. The 1971 SO2 national standards (24-hour and annual) remain in effect until one year after an area is designated for the 2010 standard, except that in areas designated non-attainment for the 1971 standards, the 1971 standards remain in effect until implementation plans to attain or maintain the 2010 standards are approved.
k On December 14, 2012, the national annual PM2.5 primary standard was lowered from 15 μg/m3 to 12.0 μg/m3. l CARB has identified lead and vinyl chloride as 'toxic air contaminants' with no threshold level of exposure for adverse health effects determined. These actions allow for the implementation of control measures at levels below the ambient concentrations specified for these pollutants. m The national standard for lead was revised on October 15, 2008, to a rolling 3-month average. The 1978 lead standard (1.5 μg/m3 as a quarterly average) remains in effect until one year after an area is designated for the 2008 standard, except that in areas designated non-attainment for the 1978 standard, the 1978 standard remains in effect until implementation plans to attain or maintain the 2008 standard are approved.
n In 1989, CARB converted both the general statewide 10-mile visibility standard and the Lake Tahoe 30-mile visibility standard to instrumental equivalents, which are "extinction of 0.23 per kilometer" and "extinction of 0.07 per kilometer" for the statewide and Lake Tahoe Air Basin standards, respectively.

SOURCE: California Air Resources Board, 2016. Ambient Air Quality Standards (5/4/16), http://www.arb.ca.gov/research/aaqs/aaqs2.pdf. Accessed January 2024.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Ozone (O3). Ozone is a secondary pollutant formed by the chemical reaction of volatile organic compounds (VOCs) and nitrogen oxides (NOX) in the presence of sunlight under favorable meteorological conditions, such as high temperature and stagnation episodes. Ozone concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are favorable. According to the USEPA, ozone can cause the muscles in the airways to constrict potentially leading to wheezing and shortness of breath.
3 Ozone can make it more difficult to breathe deeply and vigorously; cause shortness of breath and pain when taking a deep breath; cause coughing and sore or scratchy throat; inflame and damage the airways; aggravate lung diseases such as asthma, emphysema and chronic bronchitis; increase the frequency of asthma attacks; make the lungs more susceptible to infection; continue to damage the lungs even when the symptoms have disappeared; and cause chronic obstructive pulmonary disease.
4 Long-term exposure to ozone is linked to aggravation
of asthma, and is likely to be one of many causes of asthma development and long-term exposures to higher concentrations of ozone may also be linked to permanent lung damage, such as abnormal lung development in children.
5 According to the California Air Resource Board
(CARB), inhalation of ozone causes inflammation and irritation of the tissues lining human airways, causing and worsening a variety of symptoms and exposure to ozone can reduce the volume of air that the lungs breathe in and cause shortness of breath. 6 The USEPA states that people most at risk from breathing air containing ozone include people with asthma, children, older adults, and people who are active outdoors, especially outdoor workers.
7 Children are at greatest risk from exposure to ozone because their lungs are still developing and they are more likely to be active outdoors when ozone levels are high, which increases their exposure.8 According to CARB, studies show that children are no more or less likely to suffer harmful effects than adults; however, children and teens may be more susceptible to ozone and other pollutants because they spend nearly twice as much time outdoors and engaged in vigorous activities compared to adults. 9 Children breathe more rapidly
than adults and inhale more pollution per pound of their body weight than adults and are less likely than adults to notice their own symptoms and avoid harmful exposures. 10 Further
research may be able to better distinguish between health effects in children and adults. 11 Volatile Organic Compounds (VOCs). VOCs are organic chemical compounds of carbon and are not “criteria” pollutants themselves; however, in combination with NOX they form ozone, and 3 United States Environmental Protection Agency, 2023a. Health Effects of Ozone Pollution, https://www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution. Accessed January 2024. 4 Ibid.
5 Ibid.
6 California Air Resource Board, 2023a. Ozone & Health, Health Effects of Ozone, https://ww2.arb.ca.gov/resources/ozone-and-health. Accessed January 2024. 7 United States Environmental Protection Agency, 2023a. Health Effects of Ozone Pollution, https://www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution. Accessed January 2024. 8 Ibid.
9 California Air Resource Board, 2023a. Ozone & Health, Health Effects of Ozone, https://ww2.arb.ca.gov/resources/ozone-and-health. Accessed January 2024. 10 Ibid.
11 Ibid.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
are regulated to prevent the formation of ozone.12 According to CARB, some VOCs are highly reactive and play a critical role in the formation of ozone, other VOCs have adverse health effects, and in some cases, VOCs can be both highly reactive and have adverse health effects.13 VOCs are typically formed from combustion of fuels and/or released through evaporation of organic liquids, internal combustion associated with motor vehicle usage, and consumer products (e.g., architectural coatings, etc.).
14 Nitrogen Dioxide (NO2) and Nitrogen Oxides (NOX). NOX is a term that refers to a group of compounds containing nitrogen and oxygen. The primary compounds of air quality concern include NO
2 and nitric oxide (NO). Ambient air quality standards have been promulgated for NO2, which is a reddish-brown, reactive gas.15 The principle form of NOX produced by combustion is NO, but NO reacts quickly in the atmosphere to form NO2, creating the mixture of NO and NO2 referred to as NOX.16 Major sources of NOX include emissions from cars, trucks and buses, power plants, and off-road equipment.17 The terms NOX and NO2 are sometimes used interchangeably. However, the term NOX is typically used when discussing emissions, usually from combustion-related activities, and the term NO2 is typically used when discussing ambient air quality standards. Where NOX emissions are discussed in the context of the thresholds of significance or impact analyses, the discussions are based on the conservative assumption that all NO
X emissions would oxidize in the atmosphere to form NO2.

According to the USEPA, short-term exposures to NO2 can potentially aggravate respiratory diseases, particularly asthma, leading to respiratory symptoms (such as coughing, wheezing or difficulty breathing), hospital admissions and visits to emergency rooms while longer exposures to elevated concentrations of NO
2 may contribute to the development of asthma and potentially increase susceptibility to respiratory infections.18 According to CARB, controlled human exposure studies that show that NO2 exposure can intensify responses to allergens in allergic asthmatics.19 In addition, a number of epidemiological studies have demonstrated associations between NO2 exposure and premature death, cardiopulmonary effects, decreased lung function growth in children, respiratory symptoms, emergency room visits for asthma, and intensified allergic responses.
20 Infants and children are particularly at risk from exposure to NO2 because they have disproportionately higher exposure to NO2 than adults due to their greater breathing rate for their body weight and their typically greater outdoor exposure duration while in adults,

12 United States Environmental Protection Agency, 2023b. Technical Overview of Volatile Organic Compounds. https://www.epa.gov/indoor-air-quality-iaq/technical-overview-volatile-organic-compounds. Accessed January 2024.
13 California Air Resources Board, 2023b. CARB Identified Toxic Air Contaminants. https://ww2.arb.ca.gov/resources/documents/carb-identified-toxic-air-contaminants. Accessed January 2024. 14 Ibid.
15 California Air Resources Board, 2023c. Nitrogen Dioxide & Health. https://ww2.arb.ca.gov/resources/nitrogen- dioxide-and-health. Accessed January 2024.
16 Ibid.
17 United States Environmental Protection Agency, 2023c. Nitrogen Dioxide (NO2) Pollution. https://www.epa.gov/no2-pollution/basic-information-about-no2. Accessed January 2024. 18 Ibid.
19 California Air Resources Board, 2023c. Nitrogen Dioxide & Health. https://ww2.arb.ca.gov/resources/nitrogen- dioxide-and-health. Accessed January 2024.
20 Ibid.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
the greatest risk is to people who have chronic respiratory diseases, such as asthma and chronic obstructive pulmonary disease.21 CARB states that much of the information on distribution in air, human exposure and dose, and health effects is specifically for NO2 and there is only limited information for NO and NOX, as well as large uncertainty in relating health effects to NO or NOX exposure.22
Carbon Monoxide (CO): Carbon monoxide (CO) is primarily emitted from combustion processes and motor vehicles due to the incomplete combustion of fuel, such as natural gas, gasoline, or wood, with the majority of outdoor CO emissions from mobile sources. 23 According to the
USEPA, breathing air with a high concentration of CO reduces the amount of oxygen that can be transported in the blood stream to critical organs like the heart and brain and at very high levels, which are possible indoors or in other enclosed environments, CO can cause dizziness, confusion, unconsciousness and death.
24 Very high levels of CO are not likely to occur outdoors; however, when CO levels are elevated outdoors, they can be of particular concern for people with some types of heart disease since these people already have a reduced ability for getting oxygenated blood to their hearts and are especially vulnerable to the effects of CO when exercising or under increased stress.
25 In these situations, short-term exposure to elevated CO may result in reduced oxygen to the heart accompanied by chest pain also known as angina. 26 According to CARB, the most common effects of CO exposure are fatigue, headaches, confusion, and dizziness due to inadequate oxygen delivery to the brain. 27 For people with cardiovascular
disease, short-term CO exposure can further reduce their body’s already compromised ability to respond to the increased oxygen demands of exercise, exertion, or stress; inadequate oxygen delivery to the heart muscle leads to chest pain and decreased exercise tolerance. 28 Unborn
babies, infants, elderly people, and people with anemia or with a history of heart or respiratory disease are most likely to experience health effects with exposure to elevated levels of CO. 29 Sulfur Dioxide (SO2). According to the USEPA, the largest source of sulfur dioxide (SO2) emissions in the atmosphere is the burning of fossil fuels by power plants and other industrial facilities while smaller sources of SO
2 emissions include industrial processes such as extracting metal from ore; natural sources such as volcanoes; and locomotives, ships and other vehicles and heavy equipment that burn fuel with a high sulfur content. 30 In 2006, California phased-in

21 California Air Resources Board, 2023c. Nitrogen Dioxide & Health. https://ww2.arb.ca.gov/resources/nitrogen- dioxide-and-health. Accessed January 2024.
22 Ibid.
23 California Air Resources Board, 2023d. Carbon Monoxide & Health. https://ww2.arb.ca.gov/resources/carbon- monoxide-and-health. Accessed January 2024.
24 United States Environmental Protection Agency, 2023d. Carbon Monoxide (CO) Pollution in Outdoor Air. https://www.epa.gov/co-pollution/basic-information-about-carbon-monoxide-co-outdoor-air-pollution. Accessed January 2024.
25 Ibid.
26 Ibid.
27 California Air Resources Board, 2023d. Carbon Monoxide & Health. https://ww2.arb.ca.gov/resources/carbon- monoxide-and-health. Accessed January 2024.
28 Ibid.
29 Ibid.
30 United States Environmental Protection Agency, 2023e. Sulfur Dioxide (SO2) Pollution. https://www.epa.gov/so2- pollution/sulfur-dioxide-basics#effects. Accessed January 2024.

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the ultra-low-sulfur diesel regulation limiting vehicle diesel fuel to a sulfur content not exceeding 15 parts per million (ppm), down from the previous requirement of 500 ppm, substantially reducing emissions of sulfur from diesel combustion.31 According to the USEPA, short-term exposures to SO2 can harm the human respiratory system and make breathing difficult.32 According to CARB, health effects at levels near the state 1-hour standard are those of asthma exacerbation, including bronchoconstriction accompanied by symptoms of respiratory irritation such as wheezing, shortness of breath and chest tightness, especially during exercise or physical activity and exposure at elevated levels of SO 2 (above 1 ppm) results
in increased incidence of pulmonary symptoms and disease, decreased pulmonary function, and increased risk of mortality.
33 Children, the elderly, and those with asthma, cardiovascular disease, or chronic lung disease (such as bronchitis or emphysema) are most likely to experience the adverse effects of SO

2.34,35
Particulate Matter (PM10 and PM2.5). Particulate matter air pollution is a mixture of solid particles and liquid droplets found in the air.36 Some particles, such as dust, dirt, soot, or smoke, are large or dark enough to be seen with the naked eye while other particles are so small they can only be detected using an electron microscope.
37 Particles are defined by their diameter for
air quality regulatory purposes: inhalable particles with diameters that are generally 10 micrometers and smaller (PM10); and fine inhalable particles with diameters that are generally 2.5 micrometers and smaller (PM2.5).
38 Thus, PM2.5 comprises a portion or a subset
of PM10. Sources of PM10 emissions include dust from construction sites, landfills and agriculture, wildfires and brush/waste burning, industrial sources, and wind-blown dust from open lands.
39 Sources of PM2.5 emissions include combustion of gasoline, oil, diesel fuel, or wood.40 PM10 and PM2.5 may be either directly emitted from sources (primary particles) or formed in the atmosphere through chemical reactions of gases (secondary particles) such as SO
2, NOX, and certain organic compounds.41 According to CARB, both PM10 and PM2.5 can be inhaled, with some depositing throughout the airways; PM10 is more likely to deposit on the surfaces of the larger airways of the upper region of the lung while PM2.5 is more likely to travel into and deposit on the surface of the deeper parts of the lung, which can induce tissue damage,

31 California Air Resources Board, 2004. Final Regulation Order, Amendments to the California Diesel Fuel Regulations, Amend Section 2281, Title 13, California Code of Regulations. https://www.arb.ca.gov/regact/ulsd2003/fro2.pdf. Accessed January 2024. 32 United States Environmental Protection Agency, 2023e. Sulfur Dioxide (SO2) Pollution. https://www.epa.gov/so2- pollution/sulfur-dioxide-basics#effects. Accessed January 2024. 33 California Air Resources Board, 2023e. Sulfur Dioxide & Health. https://ww2.arb.ca.gov/resources/sulfur-dioxide- and-health. Accessed January 2024.
34 Ibid.
35 United States Environmental Protection Agency, 2023e. Sulfur Dioxide (SO2) Pollution. https://www.epa.gov/so2- pollution/sulfur-dioxide-basics#effects. Accessed March 2023. 36 United States Environmental Protection Agency, 2023f. Particulate Matter (PM) Pollution, https://www.epa.gov/pm-pollution/particulate-matter-pm-basics. Accessed January 2024. 37 Ibid.
38 Ibid.
39 California Air Resources Board, 2023f. Inhalable Particulate Matter and Health (PM2.5 and PM10). https://www.arb.ca.gov/research/aaqs/common-pollutants/pm/pm.htm. Accessed January 2024. 40 Ibid.
41 Ibid.

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and lung inflammation.42 Short-term (up to 24 hours duration) exposure to PM10 has been associated primarily with worsening of respiratory diseases, including asthma and chronic obstructive pulmonary disease, leading to hospitalization and emergency department visits. 43 The effects of long-term (months or years) exposure to PM10 are less clear, although studies suggest a link between long-term PM10 exposure and respiratory mortality. The International Agency for Research on Cancer published a review in 2015 that concluded that particulate matter in outdoor air pollution causes lung cancer.
44 Short-term exposure to PM2.5 has been
associated with premature mortality, increased hospital admissions for heart or lung causes, acute and chronic bronchitis, asthma attacks, emergency room visits, respiratory symptoms, and restricted activity days and long-term exposure to PM2.5 has been linked to premature death, particularly in people who have chronic heart or lung diseases, and reduced lung function growth in children.
45 According to CARB, populations most likely to experience adverse health effects with exposure to PM10 and PM2.5 include older adults with chronic heart or lung disease, children, and asthmatics and children and infants are more susceptible to harm from inhaling pollutants such as PM10 and PM2.5 compared to healthy adults because they inhale more air per pound of body weight than do adults, spend more time outdoors, and have developing immune systems.
46 Lead (Pb). Major sources of lead emissions include ore and metals processing, piston-engine aircraft operating on leaded aviation fuel, waste incinerators, utilities, and lead-acid battery manufacturers.47 In the past, leaded gasoline was a major source of lead emissions; however, the removal of lead from gasoline has resulted in a decrease of lead in the air by 98 percent between 1980 and 2014.
48 Lead can adversely affect the nervous system, kidney function, immune system, reproductive and developmental systems and the cardiovascular system, and affects the oxygen carrying capacity of blood.
49 The lead effects most commonly encountered in
current populations are neurological effects in children, such as behavioral problems and reduced intelligence, anemia, and liver or kidney damage. 50 Excessive lead exposure in adults
can cause reproductive problems in men and women, high blood pressure, kidney disease, digestive problems, nerve disorders, memory and concentration problems, and muscle and joint pain.
51 42 California Air Resources Board, 2023f. Inhalable Particulate Matter and Health (PM2.5 and PM10). https://www.arb.ca.gov/research/aaqs/common-pollutants/pm/pm.htm. Accessed January 2024. 43 Ibid.
44 Ibid.
45 Ibid.
46 Ibid.
47 United States Environmental Protection Agency, 2023g. Lead Air Pollution. https://www.epa.gov/lead-air- pollution/basic-information-about-lead-air-pollution. Accessed January 2024. 48 Ibid.
49 Ibid.
50 California Air Resources Board, 2023g. Lead & Health. https://ww2.arb.ca.gov/resources/lead-and-health.

Accessed January 2024.
51 Ibid.

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General Plan 2045 and Zoning Code Update Project 4.2-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Existing Criteria Pollutants Levels at Nearby Monitoring Stations The South Coast Air Quality Management District (SCAQMD) maintains a network of air quality monitoring stations located throughout the South Coast Air Basin (SCAB) to measure ambient pollutant concentrations. Culver City is primarily located in SCAQMD Source Receptor Area (SRA) 2 (Northwest Los Angeles County Coastal) with the southern portion of Culver City located in SCAQMD SRA 3 (Southwest Los Angeles County Coastal). The monitoring stations representative of the ambient air quality conditions in Culver City are the Southwest Los Angeles County Coastal Monitoring Station 091 in SRA 2 and the Northwest Los Angeles County Monitoring Station 820 in SRA 3. Station 091 collects monitored data for CO, ozone, and NO

2. Station 820 collects monitored data for CO, ozone, NO2, SO2, PM10, and lead. The nearest station which collects data on PM2.5 is Station 087 in SRA 1 (Central Los Angeles County).

The most recent data available from SCAQMD for these monitoring stations are from years 2019 to 2022. The pollutant concentration data for these years are summarized in Table 4.2-2, Air Pollutant Standards and Ambient Air Quality Data – SRA 2, Table 4.2-3, Air Pollutant Standards and Ambient Air Quality Data – SRA 3, and Table 4.2-4, Air Pollutant Standards and Ambient Air Quality Data – SRA 1 (for PM2.5). As shown, ambient concentrations have remained relatively consistent between 2019 and 2022, with ozone, NO2, CO, and PM2.5 trending lower in more recent years.

TABLE 4.2-2
AIR POLLUTANT STANDARDS AND AMBIENT AIR QUALITY DATA – SRA 2 Pollutant/Standard 2019 2020 2021 2022
Ozone, O3 (1-hour)
Maximum Concentration (ppm) 0.086 0.134 0.095 0.081
Days > CAAQS (0.09 ppm) 0 6 1 0
Ozone, O3 (8-hour)
Maximum Concentration (ppm) 0.075 0.092 0.082 0.070
4th High 8-hour Concentration (ppm) 0.064 0.078 0.059 0.058 Days > CAAQS (0.070 ppm) 1 8 1 0
Days > NAAQS (0.070 ppm) 1 8 1 0
Nitrogen Dioxide, NO2 (1-hour)
Maximum Concentration (ppm) 0.048 0.076 0.060 0.051
Days > CAAQS (0.18 ppm) 0 0 0 0
98th Percentile Concentration (ppm) 0.043 0.043 0.041 0.044 Days > NAAQS (0.100 ppm) 0 0 0 0
Nitrogen Dioxide, NO2 (Annual)
Annual Arithmetic Mean (0.030 ppm) 0.009 0.010 0.010 0.011 Carbon Monoxide, CO (1-hour)
Maximum Concentration (ppm) 1.9 2.0 1.5 — a
Days > CAAQS (20 ppm) 0 0 0 0
Days > NAAQS (35 ppm) 0 0 0 0

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Pollutant/Standard 2019 2020 2021 2022
Carbon Monoxide, CO (8-hour)
Maximum Concentration (ppm) 1.2 1.2 1.0 — a
Days > CAAQS (9.0 ppm) 0 0 0 0
Days > NAAQS (9 ppm) 0 0 0 0
NOTES: SRA = Source Receptor Area; ppm = parts per million; µg/m3 = micrograms per cubic meter a Criteria pollutants were not measured at the receptor area location during this year.

SOURCE: South Coast Air Quality Management District, 2019, 2020, 2021, 2022. Historical Data by Year, https://www.aqmd.gov/home/air-quality/historical-air-quality-data/historical-data-by-year. Accessed January 2024.

TABLE 4.2-3
POLLUTANT STANDARDS AND AMBIENT AIR QUALITY DATA – SRA 3 Pollutant/Standard 2019 2020 2021 2022
Ozone, O3 (1-hour)
Maximum Concentration (ppm) 0.082 0.117 0.059 — a
Days > CAAQS (0.09 ppm) 0 1 0 0
Ozone, O3 (8-hour)
Maximum Concentration (ppm) 0.067 0.074 0.049 — a
4th High 8-hour Concentration (ppm) 0.060 0.066 0.047 — a Days > CAAQS (0.070 ppm) 0 2 0 0
Days > NAAQS (0.070 ppm) 0 2 0 0
Nitrogen Dioxide, NO2 (1-hour)
Maximum Concentration (ppm) 0.056 0.076 0.062 — a
Days > CAAQS (0.18 ppm) 0 0 0 0
98th Percentile Concentration (ppm) 0.043 0.059 0.047 — a Days > NAAQS (0.100 ppm) 0 0 0 0
Nitrogen Dioxide, NO2 (Annual)
Annual Arithmetic Mean (0.030 ppm) 0.009 0.009 0.007 — a Carbon Monoxide, CO (1-hour)
Maximum Concentration (ppm) 1.8 1.6 1.7 — a
Days > CAAQS (20 ppm) 0 0 0 0
Days > NAAQS (35 ppm) 0 0 0 0
Carbon Monoxide, CO (8-hour)
Maximum Concentration (ppm) 1.3 1.3 1.3 — a
Days > CAAQS (9.0 ppm) 0 0 0 0
Days > NAAQS (9 ppm) 0 0 0 0

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Preliminary − Subject to Revision
Pollutant/Standard 2019 2020 2021 2022
Sulfur Dioxide, SO2 (1-hour)
Maximum Concentration (ppm) 0.008 0.006 — a — a
Days > CAAQS (0.25 ppm) 0 0 0 0
98th Percentile Concentration (ppm) 0.003 0.003 — a — a Days > NAAQS (0.075 ppm) 0 0 0 0
Respirable Particulate Matter, PM10 (24-hour)
Maximum Concentration (µg/m3) 62 43.0 33 — a
Samples > CAAQS (50 µg/m3) 2 0 0 — a
Samples > NAAQS (150 µg/m3) 0 0 0 0
Respirable Particulate Matter, PM10 (Annual)
Annual Arithmetic Mean (20 µg/m3) 19.2 22.5 17.7 — a
Lead
Maximum 30-day average (µg/m3) 0.004 0.008 0.003 — a
Samples > CAAQS (1.5 µg/m3) 0 0 0 0
Maximum 3-month rolling average (µg/m3) 0.004 0.005 0.004 — a Days > NAAQS (0.15 µg/m3) 0 0 0 0
NOTES: SRA = Source Receptor Area; ppm = parts per million; µg/m3 = micrograms per cubic meter SOURCE: South Coast Air Quality Management District, 2019, 2020, 2021, 2022. Historical Data by Year, https://www.aqmd.gov/home/air-quality/historical-air-quality-data/historical-data-by-year. Accessed January 2024.

TABLE 4.2-4
POLLUTANT STANDARDS AND AMBIENT AIR QUALITY DATA – SRA 1 (FOR PM2.5) Pollutant/Standard 2019 2020 2021 2022
Fine Particulate Matter, PM2.5 (24-hour)
Maximum Concentration (µg/m3) 43.5 47.3 61 33.7
98th Percentile Concentration (µg/m3) 28.3 28 44.8 21.9 Samples > NAAQS (35 µg/m3) 1 2 12 0
Fine Particulate Matter, PM2.5 (Annual)
Annual Arithmetic Mean (12 µg/m3) 10.85 12.31 12.77 10.94 NOTES: SRA = Source Receptor Area; ppm = parts per million; µg/m3 = micrograms per cubic meter SOURCE: South Coast Air Quality Management District, 2019, 2020, 2021, 2022. Historical Data by Year, https://www.aqmd.gov/home/air-quality/historical-air-quality-data/historical-data-by-year. Accessed January 2024.

Toxics Air Contaminants
In addition to criteria pollutants, the SCAQMD periodically assesses levels of toxic air contaminants (TACs) in the Air Basin. A TAC is defined by California Health and Safety Code Section 39655 as an air pollutant which may cause or contribute to an increase in mortality or in serious illness, or which may pose a present or potential hazard to human health. A substance that is listed as a hazardous air pollutant pursuant to subsection (b) of Section 112 of the federal

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General Plan 2045 and Zoning Code Update Project 4.2-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
act (42 U.S.C. Sec. 7412(b)) is a toxic air contaminant. CARB has listed approximately 200 toxic substances, including diesel particulate matter, which are identified on the California Air Toxics Program’s TAC List. TACs are not classified as “criteria” air pollutants. The effects of TACs can be diverse and their health impacts tend to be local rather than regional. Consequently, ambient air quality standards for these pollutants have not been established, and analysis of health effects is instead based on cancer risk and non-cancer exposure levels.

The SCAQMD periodically assesses levels of TACs in the Air Basin. In August 2021, the SCAQMD released the Final Multiple Air Toxics Exposure Study V (MATES V). 52 The MATES V study
includes a fixed site monitoring program with 10 stations, an updated emissions inventory of TACs, and a modeling effort to characterize risk across the Air Basin. The purpose of the fixed site monitoring is to characterize long-term regional air toxics levels in residential and commercial areas. In addition to new measurements and updated modeling results, several key updates were implemented in MATES V.

First, MATES V estimates cancer risks by taking into account multiple exposure pathways, which includes inhalation and non-inhalation pathways. This approach is consistent with how cancer risks are estimated in SCAQMD’s programs such as permitting, Air Toxics Hot Spots (Assembly Bill [AB] 2588), and CEQA. Previous MATES studies quantified the cancer risks based on the inhalation pathway only. Second, along with cancer risk estimates, MATES V includes information on the chronic noncancer risks from inhalation and non-inhalation pathways for the first time. Cancer risks and chronic noncancer risks from MATES II through IV measurements have been re-examined using current Office of Environmental Health Hazard Assessment (OEHHA) and the California Environmental Protection Agency (CalEPA) risk assessment methodologies and modern statistical methods to examine the trends over time. This has led to a reduction of the Air Basin average air toxics cancer risk in MATES V of 455 in one million (multiple exposure pathways), compared to MATES IV of 997 in one million. 53 The Air Basin
average air toxics cancer risk in MATES V for the inhalation exposure pathway only is 424 in one million.

The key takeaways from the MATES V study include: air toxics cancer risk has decreased by about 50 percent since MATES IV based on modeling data; MATES V Basin average multi- pathway air toxics cancer risk is 455 in one million, with the highest risk locations being in the Los Angeles International Airport, downtown and the ports areas; diesel particulate matter is the main risk driver for air toxics cancer risk; goods movement and transportation corridors have the highest air toxics cancer risks; and the chronic noncancer risk was estimated for the first time with a chronic hazard index of approximately 5 to 9 across all 10 fixed stations. 54 52 South Coast Air Quality Management District. 2021a. Final Report Multiple Air Toxics Exposure Study in the South Coast Air Basin MATES V.
53 Ibid.
54 South Coast Air Quality Management District. 2021a. Final Report Multiple Air Toxics Exposure Study in the South Coast Air Basin MATES V.

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General Plan 2045 and Zoning Code Update Project 4.2-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Existing Conditions
Existing Emissions
Culver City is a mix of residential, commercial, retail, office, industrial, school, recreational, and open space land uses. Everyday operational activities at these residential and non-residential uses result in the emission of air pollutants associated with vehicle trips, landscaping equipment, on-site combustion of natural gas for heating and cooking, and fugitive emissions of VOCs from the use of aerosol products and coatings and landscaping. However, data with respect to the exact activity level (i.e., utility consumption, trip generation) and building energy standards for each residential or business use is not obtainable. Therefore, emissions estimates for existing uses are based generally on default parameters in the California Emissions Estimator (CalEEMod, version 2022.1) for area and building energy source emissions. The emissions estimates for existing uses also assumes no wood stoves and CalEEMod default usage for fireplaces and assuming a municipal solid waste diversion rate of 50 percent in compliance with Assembly Bill (AB) 939 and Senate Bill (SB) 1016. (See Section 4.18, Utilities and Service Systems, of this PEIR, for additional information regarding AB 939 and SB 1016.) Existing emissions for mobile sources are based on vehicle miles traveled (VMT) 55 and on-road mobile source emission
factors from the CARB on-road vehicle emissions factors (EMFAC2021) model. Table 4.2-5, Estimated Existing Regional Operational Emissions, presents the regional emissions from the existing development in Culver City.

TABLE 4.2-5

ESTIMATED EXISTING REGIONAL OPERATIONAL EMISSIONS (POUNDS PER DAY) Source VOC NO X CO SO2 PM10 PM2.5
Existing Development (2016)
Area (Consumer Products, Fireplaces, Landscaping) 5,454 307 6,754 9 622 622 Energy (Natural Gas) 12 207 156 1 16 16
Mobile (Based on 2019 VMT) 850 2,186 8,617 18 1,353 366 Total Regional Emissionsa 6,316 2,700 15,527 28 1,991 1,004 a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix B of this PEIR.

SOURCE: ESA, 2024; Fehr & Peers, 2024 (VMT data).

Existing Health Risks from Toxics Air Contaminants
As part of the SCAQMD MATES V, the SCAQMD has released a mapping tool that shows regional trends in estimated outdoor cancer risk from TAC emissions, as part of an ongoing effort to provide insight into relative risks. The maps represent the estimated number of potential cancers per million people associated with a lifetime of breathing air toxics (24 hours per day outdoors for 70 years). The background potential cancer risk per million people in Culver City is estimated in the range of 460 in one million in the western end of the City and 468 in the northern end of the City (compared to an overall Air Basin-wide risk of 455 in one million

55 Fehr & Peers, 2024.

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[multiple exposure pathways] for the average of 10 fixed monitoring sites).56 Generally, the risk from air toxics is lower near the coastline and increases inland, with higher risks concentrated near large diesel sources (e.g., freeways, airports, rail yards and ports).

Sensitive Populations and Receptors
Certain population groups, such as children, elderly, and acutely and chronically ill persons (especially those with cardio-respiratory diseases), are considered more sensitive to the potential effects of air pollution than others. SCAQMD defines sensitive receptors as any residence (including private homes, condominiums, apartments, and other living quarters), schools, preschools, daycare centers and health facilities such as hospitals or retirement and nursing homes. It also includes long-term care hospitals, hospices, prisons, and dormitories or similar live-in housing.

Because the Project is a planning document that does not include exact locations, sizes, or land use type for any individual projects that will occur within the city under the General Plan and Zoning Code Updates, there are no specific sensitive locations identified with respect to the Project. As a conservative estimate of impacts, sensitive receptors are anticipated to be located directly adjacent to new development.

4.2.3 Regulatory Framework
This section provides the relevant federal, State, regional, and local regulations applicable to the Project.

Federal
Federal Clean Air Act
The federal Clean Air Act governs air quality in the United States. The USEPA is responsible for implementation and enforcement of the Clean Air Act. The Clean Air Act establishes federal NAAQS and specifies future dates for achieving compliance. It also requires the USEPA to designate areas as attainment, nonattainment, or maintenance. The Clean Air Act also mandates that the state submit and implement a state implementation plan (SIP) for each criteria pollutant if the NAAQS for the pollutant has not been achieved. The SIP includes pollution control measures that demonstrate how the standards will be met. The sections of the Clean Air Act which are most applicable to the Project include Title I (Nonattainment Provisions) and Title II (Mobile Source Provisions).

Title I requirements are implemented for the purpose of attaining NAAQS for the following criteria pollutants: O
3; NO2; CO; SO2; PM10; and Pb. The NAAQS were amended in July 1997 to include an 8-hour standard for O3 and to adopt a NAAQS for PM2.5. The NAAQS were also amended in September 2006 to include an established methodology for calculating PM2.5 as well as revoking the annual PM10 threshold.

56 SCAQMD, n.d., Multiple Air Toxics Exposure Study, MATES V Data Visualization Tool, Cancer Risk. https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/page/Main- Page/?views=Click-tabs-for-other-data%2CCancer-Risk. Accessed December 2023.

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Table 4.2-1 above shows the NAAQS currently in effect for each criteria pollutant. Table 4.2-6, South Coast Air Basin Attainment Status (Los Angeles County), shows the attainment status of the Air Basin for each criteria pollutant. As shown in Table 4.2-6, the Air Basin is currently in nonattainment of NAAQS for O3, PM2.5, and in one area of the Air Basin for Pb that does not include Culver City.

In addition to criteria pollutants, Title I also includes air toxics provisions which require the USEPA to develop and enforce regulations to protect the public from exposure to airborne contaminants that are known to be hazardous to human health. In accordance with Section 112, the USEPA establishes National Emission Standards for Hazardous Air Pollutants (NESHAPs). The list of hazardous air pollutants (HAPs), or air toxics, includes specific compounds that are known or suspected to cause cancer or other serious health effects.

TABLE 4.2-6

SOUTH COAST AIR BASIN ATTAINMENT STATUS (LOS ANGELES COUNTY) Pollutant National Standards California Standards
O3 (1-hour standard) Non-attainment – Extreme Non-attainment O3 (8-hour standard) Non-attainment – Extreme Non-attainment CO Attainment Attainment
NO2 Attainment Attainment
SO2 Attainment Attainment
PM10 Attainment Non-attainment
PM2.5 Non-attainment – Serious Non-attainment
Lead Non-attainment (Partial)a Attainment
Visibility Reducing Particles N/A Unclassified
Sulfates N/A Attainment
Hydrogen Sulfide N/A Unclassified
Vinyl Chloride N/A N/A
NOTE: N/A = not applicable
a Partial Nonattainment designation – Los Angeles County portion of the Air Basin only for near-source monitors.

SOURCE: U.S. Environmental Protection Agency 2023b, The Green Book Nonattainment Areas for Criteria Pollutants, last updated on December 1, 2023. https://www.epa.gov/green-book. Accessed December 2023; California Air Resources Board 2023i, Area Designations Maps/State and National. https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area- designations. Accessed December 2023.

Title II requirements pertain to mobile sources, such as cars, trucks, buses, and planes.

Reformulated gasoline, automobile pollution control devices, and vapor recovery nozzles on gas pumps are a few of the mechanisms the USEPA uses to regulate mobile air emission sources.

The provisions of Title II have resulted in tailpipe emission standards for vehicles which have strengthened in recent years to improve air quality. For example, the standards for NO X
emissions have been lowered substantially, and the specification requirements for cleaner burning gasoline are more stringent.

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State
California Clean Air Act
The California Clean Air Act, signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practical date. The CAAQS apply to the same criteria pollutants as the federal Clean Air Act but also include state-identified criteria pollutants, which include sulfates, visibility-reducing particles, hydrogen sulfide, and vinyl chloride. CARB has primary responsibility for ensuring the implementation of the California Clean Air Act, responding to the federal Clean Air Act planning requirements applicable to the state, and regulating emissions from motor vehicles and consumer products within the state. Table 4.2-1 shows the CAAQS currently in effect for each of the criteria pollutants as well as the other pollutants recognized by the state. As shown in Table 4.2-1, the CAAQS include more stringent standards than the NAAQS for most of the criteria air pollutants.

Health and Safety Code Section 39607(e) requires CARB to establish and periodically review area designation criteria. Table 4.2-6 provides a summary of the attainment status of the Los Angeles County portion of the Air Basin with respect to the State standards. The Air Basin is designated as attainment for the California standards for sulfates and unclassified for hydrogen sulfide and visibility-reducing particles. Because vinyl chloride is a carcinogenic toxic air contaminant, CARB does not classify attainment status for this pollutant.

California Air Resources Board On-Road and Off-Road Vehicle Rules In 2004, CARB adopted an Airborne Toxic Control Measure (ATCM) to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter (DPM) and other TACs (Title 13 California Code of Regulations [CCR], Section 2485). The measure applies to diesel-fueled commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are licensed to operate on highways, regardless of where they are registered. This measure does not allow diesel-fueled commercial vehicles to idle for more than 5 minutes at any given time.

In 2008, CARB also approved the Truck and Bus regulation to reduce PM and NO X emissions
from existing diesel vehicles operating in California (13 CCR, Section 2025). The requirements were amended to apply to nearly all diesel-fueled trucks and buses with a gross vehicle weight rating (GVWR) greater than 14,000 pounds. For the largest trucks and buses in the fleet, those with a GVWR greater than 26,000 pounds, all must be equipped with diesel particulate filters (DPFs) from 2014 and onward, and must have 2010 model year engines by January 1, 2023. For trucks and buses with a GVWR of 14,001 to 26,000 pounds, those with engine model years 14 to 20 years or older must be replaced with 2010 model year engines in accordance with the schedule specified in the regulation.

In addition to limiting exhaust from idling trucks, CARB also promulgated emission standards for off-road diesel construction equipment of greater than 25 horsepower (hp) such as bulldozers, loaders, backhoes and forklifts, as well as many other self-propelled off-road diesel vehicles. The regulation adopted by CARB on July 26, 2007, aims to reduce emissions by installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines

4. Environmental Impact Analysis

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with newer emission-controlled models (13 CCR, Section 2449). Implementation is staggered based on fleet size (which is the total of all off-road horsepower under common ownership or control), with large fleets beginning compliance in 2014, medium fleets in 2017, and small fleets in 2019. Each fleet must demonstrate compliance through one of two methods. The first option is to calculate and maintain fleet average emissions targets, which encourages the retirement or repowering of older equipment and rewards the introduction of newer cleaner units into the flee4.2-17econd second option is to meet the Best Available Control Technology (BACT) requirements by turning over or installing Verified Diesel Emission Control Strategies (VDECS) on a certain percentage of its total fleet horsepower. The compliance schedule requires that BACT turn overs or retrofits (VDECS installation) be fully implemented by 2023 in all equipment for large and medium fleets and by 2028 for small fleets.

California Air Resources Board Air Quality and Land Use Handbook CARB published the Air Quality and Land Use Handbook in 2005 to serve as a general guide for considering impacts to sensitive receptors from facilities that emit TAC emissions. The recommendations provided therein are voluntary and do not constitute a requirement or mandate for either land use agencies or local air districts. The goal of the guidance document is to protect sensitive receptors, such as children, the elderly, acutely ill, and chronically ill persons, from exposure to TAC emissions. Some examples of CARB’s siting recommendations include the following: (1) avoid siting sensitive receptors within 500 feet of a freeway, urban road with 100,000 vehicles per day, or rural roads with 50,000 vehicles per day; (2) avoid siting sensitive receptors within 1,000 feet of a distribution center (that accommodates more than 100 trucks per day, more than 40 trucks with operating transport refrigeration units per day, or where transport refrigeration unit operations exceed 300 hours per week); (3) avoid siting sensitive receptors within 300 feet of any dry cleaning operation using perchloroethylene and within 500 feet of operations with two or more machines, and (4) avoid siting sensitive receptors within 300 feet of a large gasoline dispensing facility (3.6 million gallons per year or more) or 50 feet of a typical gasoline dispensing facility (less than 3.6 million gallons per year). 57 In April 2017, CARB published a Technical Advisory supplement to the Air Quality and Land Use Handbook recognizing that infill developments as promoted by the State can place sensitive individuals in close proximity to high-volume roadways. The Technical Advisory provides planners and other stakeholders involved in land use planning and decision-making with information on scientifically based strategies to reduce exposure to traffic emissions near high- volume roadways. The strategies include those that reduce traffic emissions, such as vehicle speed reduction mechanisms, including roundabouts, traffic signal management, and speed limit reductions on high-speed roadways. Strategies also include those that increase the dispersion of traffic emissions, such as implementing designs that promote air flow and pollutant dispersion along street corridors (e.g., wider sidewalks, bicycle lanes, streets characterized by buildings of varying heights), solid barriers such as sound walls, and vegetation for pollutant dispersion. Other strategies include those that remove pollution from the air such as indoor high efficiency filtration. This Technical Advisory is not intended as guidance for any

57 California Air Resources Board, 2005. Air Quality and Land Use Handbook: A Community Health Perspective.

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specific project, nor does it create any presumption regarding the feasibility of mitigation measures for purposes of compliance with CEQA.58
Airborne Toxics Control Measures
The California Air Toxics Program is an established two-step process of risk identification and risk management to address potential health effects from exposure to toxic substances in the air. In the risk identification step, CARB and the OEHHA determine if a substance should be formally identified, or “listed,” as a TAC in California. In the risk management step, CARB reviews emissions sources of an identified TAC to determine whether regulatory action is needed to reduce risk. Based on the results of that review, CARB has promulgated a number of ATCMs, both for stationary and mobile sources, including On-Road and Off-Road Vehicle Rules. These ATCMs include measures such as limits on heavy-duty diesel motor vehicle idling and emissions standards for off-road diesel construction equipment in order to reduce public exposure to DPM and other TACs. These actions are also supplemented by the AB 2588 Air Toxics “Hot Spots” program and SB 1731, which require facilities to report their air toxics emissions, assess health risks, notify nearby residents and workers of significant risks if present, and reduce their risk through implementation of a risk management plan. SCAQMD has adopted two rules to limit cancer and non-cancer health risks from facilities located within its jurisdiction. Rule 1401 (New Source Review of Toxic Air Contaminants) regulates new or modified facilities, and Rule 1402 (Control of Toxic Air Contaminants from Existing Sources) regulates facilities that are already operating. Rule 1402 incorporates requirements of the AB 2588 program, including implementation of risk reduction plans for significant risk facilities.

Advanced Clean Trucks Regulation
In 2020, CARB approved the Advanced Clean Trucks (ACT) regulation (13 CCR, Sections 1963– 1963.5 and 2012–2012.3) to accelerate a large-scale transition to zero- and near-zero-emissions medium- and heavy-duty vehicles. The regulation requires manufacturers of medium- and heavy-duty vehicles to sell an increasing percentage of zero-emissions models from 2024 to 2035 with up to 55 percent of Classes 2b–3 trucks, 75 percent of Classes 4–8 trucks, and 40 percent of truck tractor sales. The regulation also includes reporting requirements to provide information that would be used to identify future strategies. The ACT is part of the statewide goal to considerably reduce NOx and PM emissions in accordance with the NAAQS, reduce GHG emissions by 40 percent, and reduce petroleum use by 50 percent by 2030. By transitioning to zero-emissions trucks, the state would move away from petroleum dependency and emit less air pollutants from heavy-duty mobile sources.

Heavy-Duty Engine and Vehicle Omnibus Regulation
CARB’s Heavy-Duty Engine and Vehicle Omnibus Regulation (Omnibus Regulation) was adopted on September 9, 2021, and became effective on December 22, 2021, to drastically cut smog- forming NOx from conventional heavy-duty engines. The Omnibus Regulation will significantly increase the stringency of NOx emissions standards and will also lengthen the useful life and emissions warranty of heavy-duty diesel engines for use in vehicles with a GVWR greater than

58 California Air Resources Board, 2005. Air Quality and Land Use Handbook: A Community Health Perspective.

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10,000 pounds. The more stringent NOx emission standards begin with the 2024 model year engines and become more stringent with 2027 and subsequent model year engines.59 Senate Bill 1000
SB 1000 amended California’s Planning and Zoning Law to require local governments to identify disadvantaged communities and incorporate environmental justice into their general plans. The purpose of SB 1000 is to provide transparent public engagement in local government planning and decision making, to reduce pollutants associated with health risk in environmental justice communities, and to promote equitable access to health-inducing benefits such as healthy food options, housing, public facilities, and recreation.

The Community Health and Environmental Justice Element identifies SB 1000 Priority Neighborhoods. Figure 4.2-1, SB 1000 Priority Neighborhoods, shows the areas in the city that are identified as SB 1000 Priority Neighborhoods. As shown on the figure in dark purple, areas within the Clarkdale and Culver/West neighborhoods are identified as SB 1000 Priority Neighborhoods, which means there is a high proportion of low-income households exposed to high pollution burdens compared to the rest of the state. Culver/West is designated as an SB 1000 Priority Neighborhood because its census tract (tract 28.03) falls in the top quartile of CalEnviroScreen 4.0. Additionally, one block group in the Clarkdale neighborhood (tract 28.01) is low-income and has a high potential pollution burden for diesel particulate matter, and traffic- related air pollution. Two additional block groups in Clarkdale and Fox Hills, shown in light purple on the figure, were identified as Threshold SB 1000 Priority Neighborhoods. These areas had a high pollution burden and, although they are not considered low-income based on American Community Survey data, they are within the margin of error to be considered low- income within the State’s established low-income threshold.

Regional
South Coast Air Quality Management District
SCAQMD has jurisdiction over air quality planning for all of Orange County, Los Angeles County except for the Antelope Valley, the non-desert portion of western San Bernardino County, and the western and Coachella Valley portions of Riverside County. The South Coast Air Basin is a subregion within SCAQMD jurisdiction. While air quality in the Air Basin has improved, the Air Basin requires continued diligence to meet the air quality standards.

59 California Air Resources Board, 2023h. Omnibus Regulation. https://ww2.arb.ca.gov/our- work/programs/innovative-clean-transit/omnibus-
regulation#:~:text=The%20Heavy%2DDuty%20Engine%20and,from%20conventional%20heavy%2Dduty%20engin es. Accessed January 2024.

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7026.00
7027.00
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7028.03
7028.01
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Miles
City of Los Angeles
West Los
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College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
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Washington Blvd.

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

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Baldwin Hills
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Jeff
erson Blvd.

Washington Blvd.

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Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

SB 1000 Priority
Neighborhoods
S ources: C ity of Culv er Ci ty (20 21);
County of Los Angeles (2021);
CalEnviroScreen (2021); ESRI (2021).

City Limits
Sphere of Influence
Metro Station
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Major Roads
Local Roads
Parks and Open Space
Waterbody
Census Tract
SB 1000 Priority Neighborhoods
Threshold SB 1000 Priority Neighborhoods
FIGURE XXFIGURE 6
Culver City General Plan 2045
Figure 4-2.1
SB 1000 Priority Neighborhoods
SOURCE: Draft Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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Air Quality Management Plan
To meet the NAAQS and CAAQS, the SCAQMD has adopted a series of Air Quality Management Plans (AQMPs), which serve as a regional blueprint to develop and implement an emission reduction strategy that will bring the Air Basin into attainment with the standards in a timely manner. The most current AQMP is the 2022 Air Quality Management Plan (2022 AQMP) 60,
which was adopted on December 2, 2022. The goal of the 2022 AQMP is to provide a regional roadmap to help the Air Basin achieve the’USEPA's NAAQS 2015 8-hour ozone standard (70 parts per billion).

On January 26, 2023, CARB adopted Resolution 23-4, which directs the CARB Executive Officer to submit the 2022 AQMP to the USEPA for inclusion in the California SIP to be effective, for purposes of federal law, after notice and public hearing as required by Section 110(l) of the Clean Air Act and 40 Code of Federal Regulations Section 51.102 and approval by the USEPA.

USEPA approval has not yet occurred.

The 2022 AQMP builds upon measures already in place from previous AQMPs. It also includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emissions technologies, when cost-effective and feasible, and low NOx technologies in other applications), best management practices, co-benefits from existing programs (e.g., climate and energy efficiency), incentives, and other CAA measures to achieve the 2015 8-hour ozone standard.

The 2022 AQMP incorporates the transportation strategy and transportation control measures from Southern California Association of Governments (SCAG) Connect SoCal 2020 (2020-2045 Regional Transportation Plan/Sustainable Communities Strategy [2020-2045 RTP/SCS]). 61 SCAG
is the regional planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino, and Imperial Counties, and addresses regional issues relating to transportation, the economy, community development and the environment. SCAG coordinates with various air quality and transportation stakeholders in Southern California to ensure compliance with the federal and state air quality requirements. Pursuant to California Health and Safety Code Section 40460, SCAG has the responsibility of preparing and approving the portions of the AQMP relating to the regional demographic projections and integrated regional land use, housing, employment, and transportation programs, measures, and strategies. SCAG is required by law to ensure that transportation activities “conform” to, and are supportive of, the goals of regional and state air quality plans to attain the NAAQS. The RTP/SCS includes transportation programs, measures, and strategies generally designed to reduce vehicle miles traveled (VMT), which are contained in the AQMP.

The 2022 AQMP forecasts future emissions inventories with growth based on SCAG’s 2020-2045 RTP/SCS. According to the 2022 AQMP, the South Coast Air Basin is projected to see a 12 percent growth in population, 17 percent growth in housing units, 11 percent growth in employment, and an 8 percent growth in VMT between 2018 and 2037. Despite regional growth

60 SCAQMD, 2022. 2022 Air Quality Management Plan.
61 SCAG, 2020. Connect SoCal 2020, Demographics and Growth Forecast, September 2020.

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in the past, air quality has improved substantially over the years, primarily due to the effects of air quality control programs at the local, state and federal levels.62 Noteworthy control strategies for mobile sources in the AQMP with potential applicability to reducing short-term emissions from construction activities associated with future development that could occur under the proposed General Plan and Zoning Code Updates include strategies denoted in the 2022 AQMP as MOB-05, MOB-06, and MOB-10, which are intended to reduce emissions from on-road and off-road heavy-duty vehicles and equipment.63 Descriptions of these measures are provided below:

MOB-05 – ACCELERATED RETIREMENT OF OLDER LIGHT-DUTY AND MEDIUM-DUTY VEHICLES:

This measure seeks to achieve emission reductions by accelerating retirement of older gasoline- and diesel-powered vehicles with up to 8,500 lbs. gross vehicle weight rating (GVWR).

MOB-06 – ACCELERATED RETIREMENT OF OLDER ON-ROAD HEAVY-DUTY VEHICLES: This measure seeks additional emission reductions from existing heavy-duty vehicles with GVWR greater than 8,500 lbs through an accelerated vehicle replacement program with zero or low NO
X emission vehicles.

MOB-10 – OFF-ROAD MOBILE SOURCE EMISSION REDUCTION CREDIT GENERATION PROGRAM: This measure seeks to develop mechanisms to incentivize early deployment of Tier 4, low NOx, and zero off-road equipment, where applicable, through the generation of mobile source emission reduction credits.

Rules and Regulations
Several SCAQMD rules adopted to implement portions of the AQMP may apply to future development that could occur under the proposed General Plan and Zoning Code Update. For example, SCAQMD Rule 403 requires implementation of best available fugitive dust control measures during active construction periods capable of generating fugitive dust emissions from on-site earth-moving activities, construction/demolition activities, and construction equipment travel on paved and unpaved roads. Rules and regulations that are most relevant to future development that could occur under the General Plan and Zoning Code Update include the following:

Regulation IV – Prohibitions: This regulation sets forth the restrictions for visible emissions, odor nuisance, fugitive dust, various air emissions, fuel contaminants, start-up/shutdown exemptions and breakdown events. The following is a list of rules that apply to the Project:
• Rule 401 – Visible Emissions: This rule states that a person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is as dark or darker in shade as that designated No. 1 on the Ringelmann Chart or of such opacity as to obscure an ob’erver's view.

62 SCAQMD, 2022. 2022 Air Quality Management Plan, Table 3-3. 63 SCAQMD, 2022. 2022 Air Quality Management Plan, pages 4-21 through 4-30.

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• Rule 402 – Nuisance: This rule states that a person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property.
• Rule 403 – Fugitive Dust: This rule requires projects to prevent, reduce or mitigate fugitive dust emissions from a site. Rule 403 restricts visible fugitive dust to the project property line, restricts the net PM10 emissions to less than 50 micrograms per cubic meter (µg/m3) and restricts the tracking out of bulk materials onto public roads. Additionally, projects must utilize one or more of the best available control measures (identified in the tables within the rule). Mitigation measures may include adding freeboard to haul vehicles, covering loose material on haul vehicles, watering, using chemical stabilizers and/or ceasing all activities.

Finally, a contingency plan may be required if so determined by USEPA. • Rule 445 – Wood Burning Devices: This rule reduces the emission of particulate matter from wood-burning devices and establishes contingency measures for applicable ozone standards for the reduction of volatile organic compounds. The rule generally prohibits the installation of a wood-burning device into any new development, which means residential or commercial, single or multi-building unit, which begins construction on or after March 9, 2009.

Regulation XI – Source Specific Standards: Regulation XI sets emissions standards for specific sources. The following is a list of rules which may apply to the Project as a result of project construction activities (i.e., application of architectural coatings, and potential sediment and dirt being tracked onto roads), proposed restaurant uses on-site, and on-site water heaters for the proposed uses:
• Rule 1113 – Architectural Coatings: This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories.
• Rule 1138 – Control of Emissions from Restaurant Operations: This rule specifies emissions and odor control requirements for commercial cooking operations that use chain-driven charbroilers to cook meat.
• Rule 1146.2 – Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers and Process Heaters: This rule requires manufacturers, distributors, retailers, refurbishers, installers, and operators of new and existing units to reduce NO X emissions from natural
gas-fired water heaters, boilers, and process heaters as defined in this rule. • Rule 1186 – PM10 Emissions from Paved and Unpaved Roads, and Livestock Operations:

This rule applies to owners and operators of paved and unpaved roads and livestock operations. The rule is intended to reduce PM10 emissions by requiring the cleanup of material deposited onto paved roads (including city street), use of certified street sweeping equipment, and treatment of high-use unpaved roads (see also Rule 403).

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4.2. Air Quality
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Regulation XIII – New Source Review (NSR): Regulation XIII sets requirements for preconstruction review required under both federal and State statutes for new and modified sources located in areas that do not meet the Clean Air Act stand“rds ("non-atta”nment" areas).

NSR applies to both individual permits and entire facilities. Any permit that has a net increase in emissions is required to apply BACT measures. Facilities with a net increase in emissions are required to offset the emission increase by use of Emission Reduction Credits (ERCs). The regulation provides for the application, eligibility, registration, use and transfer of ERCs. For low emitting facilities, the SCAQMD maintains an internal bank that can be used to provide the required offsets. In addition, certain facilities are subject to provisions that require public notice and modeling analysis to determine the downwind impact prior to permit issuance.

Regulation XIV – Toxics and Other Noncriteria Pollutants: Regulation XI sets emissions standards for TACs and other noncriteria pollutant emissions. The following is a list of rules which may apply to the Project due to the demolition of existing buildings/structures that could contain asbestos and the operation of diesel-powered generators during operations since diesel particulate matter is a TAC:
• Rule 1403 – Asbestos Emissions from Demolition/Renovation Activities: This rule requires owners and operators of any demolition or renovation activity and the associated disturbance of asbestos-containing materials, any asbestos storage facility, or any active waste disposal site to implement work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos-containing materials.
• Rule 1466 – Control of Particulate Emissions from Soils with Toxic Air Contaminants: This rule sets requirements to minimize the amount of fugitive dust containing toxic air contaminants that is emitted during earth-moving activities, including, excavating, grading, handling, treating, stockpiling, transferring, and removing soil that contains applicable TACs.

Rule 1166 is applicable to the transportation of soils with applicable TACs through the SCAB.

Applicable requirements include covering the truck loads for soil that contains applicable TACs.
• Rule 1470 – Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines: This rule applies to stationary compression ignition engine greater than 50 brake horsepower and sets limits on emissions and operating hours. In general, new stationary emergency standby diesel-fueled engines greater than 50 brake horsepower are not permitted to operate more than 50 hours per year for maintenance and testing.

Regulation XXIII– Facility Based Mobile Source Measures: In order to obtain the 80 ppb and 75 ppb 8-hour ozone standards by the 2023 and 2031 applicable attainment dates, respectively, and in support of the AQMP, the SCAQMD formulated Facility Based Mobile Sources Rules to reduce NOx emissions from indirect sources (e.g., mobile sources generated by, or attracted to

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facilities). The following rule would apply to future warehouse development that could occur under the proposed General Plan and Zoning Code Update:
• Rule 2305 – Warehouse Indirect Sources Rule. Rule 2305 was formally adopted on May 7, 2021.64 This rule would reduce local and regional emissions of NOx and PM, and facilitate local and regional emission reductions associated with warehouses and mobile sources attracted to warehouses in order to assist in meeting the state and federal AAQS for ozone and PM. The Warehouse Actions and Investments to Reduce Emissions (WAIRE) Program is a menu-based points system that will require warehouse operators to annually earn a specified number of points by completing actions from a menu. The amount of WAIRE points needed for compliance is calculated based on weighted annual truck trips (WATTs), and an annual variable and stringency rate. WAIRE points earned can be transferred to a different warehouse utilized by the same warehouse operator, to a different compliance year, or between a warehouse owner and a warehouse operator. After each compliance year, warehouse operators will submit an annual WAIRE Report detailing the WAIRE points needed and the points earned for the reporting year. If a warehouse operator fails to earn enough WAIRE points to satisfy the requirement, they are required to pay a mitigation fee per unattained WAIRE point The Warehouse Indirect Source Rule provides several compliance options that facilities can choose to meet their point requirements including, but not limited to:
(1) Ensure truck fleets that serve their facility during operations are cleaner than required by CARB regulations (verified through a voluntary fleet certification program); (2) Directly control the emissions associated with trucks visiting the facility; (3) Installation of charging/fueling infrastructure for cleaner trucks and transportation refrigeration units (TRUs), conversion of cargo handling equipment to zero-emissions technologies, etc.;
(4) Utilization of zero-emissions trucks and incorporation of the infrastructure to support them; and/or
(5) Mitigation fees if the facilities emissions exceed cap levels set in the Indirect Source Rule.

Local
Culver City General Plan
The Culver City General Plan includes nine elements that have been updated at various points between 1968 and 2014. The current plan does not have an Air Quality Element. However, the Circulation Element (amended through 1995) contains objectives and associated policies focused on traffic flow (Objective #1), public transit (Objective #2), bikeways (Objective #3), pedestrian access (Objective #4), participating in regional system improvements (Implementation Measure #1), and roadway improvement (Implementation Measure #2). 65 Consistency with these objectives and associated policies would have the potential to reduce

64 SCAQMD, 2021b. Rule 2305. Warehouse Indirect Source Rule. 65 Culver City. 1995. Culver City General Plan, Circulation Element.

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single occupancy vehicle trips and VMT, thus reducing air pollutants from mobile sources. The growth projections within the General Plan inform the development of SCAQMD’s AQMP.

Culver City Green Building Program
In 2009, Culver City adopted the Mandatory Green Building Program which contains a number of features that would indirectly reduce air pollutant emissions such as enhanced building insulation, low-flow fixtures, efficient lighting and heating, ventilation, and air conditioning (HVAC) systems.
66 The Culver City Mandatory Green Building Program also includes a specific feature for parking garages which requires all new lighting to be motion sensor controlled and efficient minimum base level lighting.

4.2.4 Project Impact Analysis
Thresholds of Significance and Methodology
Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant impact related to air quality if the project would:

Threshold AQ-1: Conflict with or obstruct implementation of the applicable air quality plan?
Threshold AQ-2: Result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard? Threshold AQ-3: Expose sensitive receptors to substantial pollutant concentrations?
Threshold AQ-4: Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
In determining whether an effect is significant, State CEQA Guidelines (Section 15064.7) state that a lead agency may consider thresholds of significance previously adopted or recommended by other public agencies, provided that the decision to use such thresholds is supported by substantial evidence. Furthermore, with regard to air quality, Appendix G checklist’s air quality section preamble reads:
“Where available, the significance criteria established by the applicable air quality management or air pollution control district may be relied upon to make … determinations.”

66 Culver City. Municipal Code Chapter 15.02.1100, Green Building Program and Requirements.

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In a February 2018 CEQA Guidance document released by SCAQMD, the SCAQMD further states that:67
“Air districts’ thresholds provide a clear quantitative benchmark to determine the significance of project and project alternative air quality impacts. They also help identify the magnitude of the impacts, facilitate the identification of feasible mitigation measures, and evaluate the level of impacts before and after mitigation measures. Since one of the basic purposes of CEQA is to inform government decision makers and the public about the potential, significant environmental effects of any proposed activities (CEQA Guidelines §15002(a)(1)), use of air district thresholds is a best practice for CEQA impact determinations.” In compliance with State CEQA guidelines and SCAQMD guidance, Culver City uses the SCAQMD’s established thresholds for evaluating air quality impacts of proposed projects and assessing the significance of quantifiable impacts as applicable under each Appendix G question.

The potential air quality impacts are, therefore, evaluated in consideration of the thresholds adopted by SCAQMD in connection with its CEQA Air Quality Handbook, Air Quality Analysis Guidance Handbook, and subsequent SCAQMD guidance.
68 Conflict with or Obstruct Implementation of the Applicable Air Quality Plan The threshold used for determining whether future projects developed under the proposed Project would conflict with or obstruct an applicable air quality plan is qualitative and is based on whether the future projects are consistent with the assumed growth, applicable control measures and air emission reduction policies in the AQMP. Therefore, future projects developed under the proposed General Plan and Zoning Code Updates would have a significant impact if they would:
• Conflict with or obstruct implementation of the AQMP or any other adopted regional and local plans adopted for reducing air quality impacts.

Cumulatively Considerable Net Increase in Criteria Pollutants Construction
Given that construction impacts are temporary and limited to the construction phase, SCAQMD has established numerical thresholds of significance for construction air pollutant emissions specific to construction activity. The numerical thresholds are based on the recognition that the Air Basin is a distinct geographic area with a critical air pollution problem for which ambient air quality standards have been promulgated to protect public health. 69 Based on the thresholds in
the SCAQMD CEQA Air Quality Handbook, future projects developed under the proposed

67 SCAQMD, 2018. Guidance on Frequently Questioned Topics in Roadway Analysis for the California Environmental Quality Act, https://www.aqmd.gov/docs/default-source/ceqa/handbook/roadway-ceqa-guidance_v10.pdf.

Accessed December 2023.
68 While the SCAQMD CEQA Air Quality Handbook contains significance thresholds for lead, Future projects developed under the proposed General Plan and Zoning Code Update would not include sources of lead emissions and would not exceed the established thresholds for lead. Unleaded fuel and unleaded paints have virtually eliminated lead emissions from commercial and residential land use projects. As a result, lead emissions are not further evaluated in this EIR.
69 SCAQMD 1993, South Coast Air Quality Management District, South Coast Air Quality Management District, CEQA Air Quality Handbook (1993), http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/ceqa- air-quality-handbook-(1993). Accessed December 2023.

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4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-28 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
General Plan and Zoning Code Updates would potentially cause or contribute to an exceedance of an ambient air quality standard if the following would occur:
• Regional construction emissions from both direct and indirect sources would exceed any of the following SCAQMD prescribed daily emissions thresholds:70 – 75 pounds per day for VOC
– 100 pounds per day for NOX
– 550 pounds per day for CO
– 150 pounds per day for SO2
– 150 pounds per day for PM10
– 55 pounds per day for PM2.5
Operational
The SCAQMD has established numerical thresholds of significance for operation air pollutant emissions. The numerical significance thresholds are based on the recognition that the Air Basin is a distinct geographic area with a critical air pollution problem for which ambient air quality standards have been promulgated to protect public health. 71 The SCAQMD has established
numeric thresholds of significance in part based on Section 182(e) of the Clean Air Act which identifies 10 tons per year of VOC as a significance level for stationary source emissions in extreme non-attainment areas for ozone.
72 As shown in Table 4.2-6, the Air Basin is designated as extreme non-attainment for ozone. The SCAQMD converted this significance level to pounds per day for ozone precursor emissions (10 tons per year × 2,000 pounds per ton ÷ 365 days per year = 55 pounds per day). The numeric thresholds for other pollutants are also based on federal stationary source significance levels. Based on the thresholds in the SCAQMD CEQA Air Quality Handbook, future projects developed under the proposed General Plan and Zoning Code Update would potentially cause or contribute to an exceedance of an ambient air quality standard if the following would occur:
• Operational emissions exceed any of the following SCAQMD prescribed daily regional numeric thresholds:
73 – 55 pounds a day for VOC
– 55 pounds per day for NOX
– 550 pounds per day for CO
– 150 pounds per day for SOX
– 150 pounds per day for PM10
– 55 pounds per day for PM2.5

70 SCAQMD, 2023. Air Quality Significance Thresholds, revision March 2023. 71 SCAQMD, 1993. CEQA Air Quality Handbook.
72 Ibid.
73 SCAQMD, 2023. Air Quality Significance Thresholds, revision March 2023.

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General Plan 2045 and Zoning Code Update Project 4.2-29 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Sensitive Receptors
Localized Significance Thresholds (LSTs)
The SCAQMD published its Final Localized Significance Threshold Methodology and Final Methodology to Calculate PM10 and PM2.5 Significance Thresholds, recommending that all air quality analyses include a localized assessment of both construction and operational impacts of the Project on nearby sensitive receptors.
74,75 LSTs are only applicable to the following criteria pollutants: NOx, CO, PM10 and PM2.5. LSTs represent the maximum emissions from a project site that are not expected to result in an exceedance of Federal or State AAQS. LSTs are based on the ambient concentrations of that pollutant within the SRA where a project is located and the distance to the nearest sensitive receptor. Culver City is primarily located in SCAQMD SRA 2 (Northwest Los Angeles County Coastal) with the southern portion of Culver City located in SCAQMD SRA 3 (Southwest Los Angeles County Coastal).

In the case of CO and NO
2, if ambient levels are below the air standards for these pollutants, a project is considered to have a significant impact if project emissions result in an exceedance of one or more of these standards. If ambient levels already exceed a State or federal standard, then project emissions are considered significant if they increase ambient concentrations by a measurable amount. This would apply to PM10 and PM2.5, both of which are nonattainment pollutants in the Basin. For these latter two pollutants, the significance criteria are the pollutant concentration thresholds presented in SCAQMD Rules 403 and 1301. The Rule 403 threshold of

10.4 µg/m
3 applies to construction emissions (and may apply to operational emissions at aggregate handling facilities). The Rule 1301 threshold of 2.5 µg/m3 applies to non-aggregate handling operational activities.

Sensitive receptors include residences, schools, hospitals, and similar uses that are sensitive to adverse air quality. Sensitive receptors could be located in proximity to future projects developed under the proposed General Plan and Zoning Code Updates and have the potential to be exposed to localized construction and operational emissions.

The SCAQMD has established screening criteria that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance thresholds and therefore not cause or contribute to an exceedance of the applicable ambient air quality standards or ambient concentration limits without project-specific dispersion modeling. If future projects developed under the proposed General Plan and Zoning Code Update would result in exceedance of the following screening criteria LSTs for the above pollutants, this would constitute a significant impact, unless dispersion modeling demonstrates no exceedance of the concentration based standards.

74 SCAQMD, 2006. Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds. 75 SCAQMD, 2008. Final Localized Significance Threshold Methodology, July 2008.

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Preliminary − Subject to Revision
Representative LST screening levels are provided below. Actual screening levels utilized by future development projects should be based on the applicable criteria (i.e., SRA, size, and receptor distance) in the SCAQMD Final Localized Significance Threshold Methodology, Appendix C. • Representative Construction Screening Levels (5-acre site within 25 meters of sensitive receptors in SRA 2):
76 – 123 pounds per day for NOX77
– 1,531pounds per day for CO
– 13 pounds per day for PM10
– 6 pounds per day for PM2.5
• Representative Operation Screening Levels (5-acre site within 25 meters of sensitive receptors in SRA 2):78
– 123 pounds per day for NOX79
– 1,531pounds per day for CO
– 3 pounds per day for PM10
– 2 pounds per day for PM2.5
Carbon Monoxide Hotspots
With respect to the formation of CO hotspots, the Project would be considered significant if the following conditions would occur at an intersection or roadway within one-quarter mile of a sensitive receptor:
• The Project would cause or contribute to an exceedance of the CAAQS 1-hour or 8-hour CO standards of 20 or 9.0 ppm, respectively.80

76 South Coast Air Quality Management District, 2009, Appendix C - Mass Rate LST Look-up Table. 77 The screening criteria for NOx were developed based on the 1-hour NO2 CAAQS of 0.18 ppm. However, since the publication of the SCAQMD’s guidance, the USEPA has promulgated a 1-hour NO2 NAAQS of 0.100 ppm based on a 98th percentile value, which is more stringent than the CAAQS. In order to determine if Project emissions would result in an exceedance of the 1-hour NO2 NAAQS, an approximated LST was estimated to evaluate the federal 1- hour NO2 standard, as the SCAQMD significance threshold has not been updated to reflect this standard.

Calculated by scaling the NO2 LST for by the ratio of 1-hour NO2 standards (federal/state) (i.e., 221 lb/day* (0.10/0.18) =123 lb/day).
78 South Coast Air Quality Management District, 2009, Appendix C - Mass Rate LST Look-up Table. 79 The screening criteria for NOx were developed based on the 1-hour NO2 CAAQS of 0.18 ppm. However, since the publication of the SCAQMD’s guidance, the USEPA has promulgated a 1-hour NO2 NAAQS of 0.100 ppm based on a 98th percentile value, which is more stringent than the CAAQS. In order to determine if Project emissions would result in an exceedance of the 1-hour NO2 NAAQS, an approximated LST was estimated to evaluate the federal 1- hour NO2 standard, as the SCAQMD significance threshold has not been updated to reflect this standard.

Calculated by scaling the NO2 LST for by the ratio of 1-hour NO2 standards (federal/state) (i.e., 221 lb/day* (0.10/0.18) =123 lb/day).
80 SCAQMD, 2023. Air Quality Significance Thresholds, revision March 2023.

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Toxic Air Contaminants
Based on the criteria set forth by the SCAQMD, future projects developed under the proposed General Plan and Zoning Code Update would expose sensitive receptors to substantial concentrations of toxic air contaminants if any of the following would occur: 81 • Future projects developed under the proposed General Plan and Zoning Code Update emit carcinogenic materials or TACs that exceed the maximum incremental cancer risk of ten in one million or a cancer burden greater than 0.5 excess cancer cases (in areas greater than or equal to 1 in 1 million) or an acute or chronic hazard index of 1.0.

Other Emissions
The Initial Study (Appendix A of this Draft PEIR) found less than significant impacts related to other emissions (such as those leading to odors) adversely affecting a substantial number of people (Threshold AQ-4); therefore, this issue is not evaluated in this section. Please see Appendix A for further discussion.

Methodology
Construction
Construction of future development that could occur from adoption of the proposed General Plan and Zoning Code Update would have the potential to temporarily emit criteria air pollutant emissions through the use of heavy-duty construction equipment, such as excavators, cranes, and forklifts, and through vehicle trips generated from workers and haul trucks traveling to and from project sites. In addition, fugitive dust emissions would result from demolition and various soil-handling activities.

The Project is a planning-level document, and, as such, there are no specific projects, project construction dates, or specific construction plans identified. Therefore, quantification of emissions associated with buildout cannot be specifically determined at this time. Therefore, the analysis will be based on the potential for construction emissions to exceed threshold values in the context of development intensity and compliance with regulatory emissions standards.

Operational
Regional
Operation of future development that could occur from adoption of the proposed General Plan and Zoning Code Update would generate criteria air pollutant emissions from vehicle trips throughout the City, energy sources, such as natural gas combustion, and area sources, such as operation of landscaping equipment and use of consumer products, including solvents used in non-industrial applications which emit VOCs during their product use, such as cleaning supplies, kitchen aerosols, cosmetics and toiletries. Operational impacts were assessed for the full Project buildout year of 2045, as well as for the existing uses operating in future year 2045. Daily maximum criteria air pollutant emissions were compared with the SCAQMD operational thresholds to determine the operational impacts of the Project.

81 Ibid.

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VMT data, which takes into account mode and trip lengths, was developed for the transportation analysis. Emissions from motor vehicles are dependent on vehicle type. Thus, the emissions were calculated using a representative motor vehicle fleet mix for the Project based on the CARB EMFAC2021 model and default fuel type. EMFAC2021 was used to generate emissions factors for operational mobile sources based on fuel type and vehicle class. However, traffic reduction policies within the proposed General Plan Mobility Element, to which the regional travel demand model may not be fully sensitive (such as connectivity in neighborhoods, presence of bicycle and pedestrian facilities, and transportation demand management measures), may not be fully reflected in the VMT and emissions estimates. Therefore, estimated mobile source emissions are conservatively higher.

The operational area emissions from the Project were estimated using the CalEEMod software.

Area source emissions are based on hearth (i.e., fireplace) emissions, architectural coatings, landscaping equipment, and consumer product usage rates provided in CalEEMod. For future development, CalEEMod default values were used for area source emissions except that wood stoves were removed from the emissions calculations for existing uses and wood fireplaces were removed from new development as they are generally not permitted within SCAQMD’s jurisdiction for most new commercial and residential development per SCAQMD Rule 445.

Future development is assumed to comply with the Title 24 building energy efficiency standards currently programmed into CalEEMod 2022.1, which is a conservative assumption since future Title 24 standards, typically adopted every three years, would reduce building energy demand for future development permitted in 2026 and later. A municipal solid waste diversion rate of 75 percent for new development is assumed in compliance with AB 341 (refer to Section 4.18, Utilities and Service Systems, of this PEIR, for additional information regarding AB 341). Detailed emissions calculations are provided in Appendix B of this PEIR.

Local
Localized Significance Thresholds
The localized effects from the on-site portion of daily operational emissions are dependent on the exact size, nature, and location of an individual land use type, combined with reductions in localized impacts from the removal of existing land use types as applicable (i.e., conversion of light industrial uses). Because no specific development projects are identified under the proposed General Plan and Zoning Code Update, the location of development projects, and the exact nature of the potential development are unknown, determining localized impacts from operational activities at this time is speculative. Therefore, the analysis of localized impacts is discussed qualitatively in this analysis.

Intersection Hotspot Analysis
Operation of the future development resulting from the Project has the potential to generate traffic congestion and increase delay times at intersection within the local study area. The pollutant of primary concern when assessing the Project’s impacts at local intersections is CO because an elevated concentration of CO tends to accumulate near areas of heavy traffic congestion and where average vehicle speeds are low. Tailpipe emissions are of concern when assessing localized impacts of CO along paved roads.

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An adverse concentration of CO, known as a “hotspot”, would occur if there was an exceedance of the NAAQS or CAAQS. SCAQMD does not currently have guidance for conducting intersection hot spot analysis. However, Caltrans has guidance for evaluating CO hot spots in their Transportation Project-Level Carbon Monoxide Protocol (CO Protocol). Detailed guidance discussing which modeling programs to use, calculating emission rates, receiver placement, calculating 1-hour and 8-hour concentrations, and utilizing background concentrations are provided in the Caltrans’ CO Protocol.

The potential for the future development resulting from the Project to cause or contribute to CO hotspots is evaluated by comparing project intersections (both intersection geometry and traffic volumes) with prior studies conducted by SCAQMD in support of their AQMPs and considering existing background CO concentrations.

Toxic Air Contaminants Impacts (Construction and Operations) Construction and operational activities have the potential to result in health risk impacts (cancer, or other acute or chronic conditions) related to TACs exposure from airborne emissions, specifically the emissions of diesel particulate matter. Health risk is a localized impact based on exposure of sensitive receptors to construction and operational activities that emit TACs.

Because there are no specific development projects identified under the proposed General Plan and Zoning Code Update, the location of the development projects, and the exact nature of the development are unknown, determining health risk as this time is speculative. Therefore, the analysis of health risk is discussed qualitatively in this analysis based on the potential for TAC emissions to exceed threshold values in the context of development intensity, proximity to sensitive receptors, and compliance with regulatory emissions standards.

Project Impact Analysis
Conflict With or Obstruct Applicable Air Quality Plan
Threshold AQ-1: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code Updates would conflict with or obstruct implementation of the applicable air quality plan.

Impact Statement AQ-1: The Project would result in a potentially significant impact related to a conflict with or obstructing implementation of the applicable air quality plan due to growth that could exceed demographic assumptions for Culver City. While implementation of mitigation measures would serve to reduce the severity of the effects, impacts would remain significant and unavoidable.

The SCAQMD recommends that, when determining whether a project is consistent with the applicable AQMP, the lead agency should assess whether the project would directly obstruct implementation of the plans by impeding SCAQMD’s efforts to achieve attainment with respect to any criteria air pollutant for which it is currently not in attainment of the NAAQS and CAAQS (e.g., ozone, PM10, and PM2.5) and whether it is consistent with the demographic and economic assumptions (typically land use related, such as employment and population/residential units) upon which the plan is based. The SCAQMD numerical significance

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thresholds for construction and operational emissions are designed for the analysis of individual projects and not for long-term planning documents, such as the proposed General Plan and Zoning Code Update. Emissions are dependent on the exact size, nature, and location of an individual land use type, combined with reductions in localized impacts from the removal of existing land use types, as applicable (i.e., conversion of light industrial uses). Emissions associated with the operation of individual projects could exceed project-specific thresholds established by SCAQMD. SCAQMD guidance indicates that projects whose growth is included in the projections used in the formulation of the AQMP are considered to be consistent with the plan and would not interfere with its attainment even if the numerical significance thresholds would be exceeded.
82 As discussed above, the SCAQMD has adopted a series of AQMPs to lead the Air Basin into compliance with several criteria air pollutant standards and other federal requirements, while taking into account construction and operational emissions associated with population and economic growth projections provided by SCAG. The 2022 AQMP incorporates population and economic growth projections from SCAG’s 2020–2045 RTP/SCS.

CEQA requires that general plans be evaluated for consistency with the AQMP. Because the AQMP strategy is based on projections from local general plans, only new or amended general plan elements, specific plans, or individual projects under the general plan need to undergo a consistency review. Projects considered consistent with the local general plan are consistent with the air quality-related regional plan. Indicators of consistency include:
• Control Strategies: Whether implementation of a project would increase the frequency or severity of existing air quality violations; would cause or contribute to new violations; or would delay the timely attainment of AAQS or interim emissions reductions within the AQMP.
• Growth Projections: Whether implementation of the project would exceed growth assumptions within the AQMP, which in part, bases its strategy on growth forecasts from local general plans.

Construction
Control Strategies
The Air Basin is designated nonattainment for O3 and PM2.5 under the CAAQS and NAAQS, nonattainment for lead (Los Angeles County only) under the NAAQS, and nonattainment for PM10 under the CAAQS. Long-term growth associated with buildout under the General Plan and Zoning Code Update could result in the emissions of criteria pollutants that exceed SCAQMD thresholds for criteria pollutants. Future development under the General Plan and Zoning Code Update would be required to comply with CARB’s requirements to minimize short-term emissions from on-road and off-road diesel equipment, including the ATCM to limit heavy-duty diesel motor vehicle idling to no more than 5 minutes at any given time, and with SCAQMD’s regulations such as Rule 403 for controlling fugitive dust and Rule 1113 for controlling VOC emissions from architectural coatings. Furthermore, as applicable to the type of growth,

82 SCAQMD, 1993. CEQA Air Quality Handbook, Chapter 12, page 12-1.

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individual projects that are developed under the General Plan and Zoning Code Update would comply with fleet rules to reduce on-road truck emissions during construction. Compliance with these measures and requirements would be consistent with and meet or exceed the AQMP requirements for control strategies intended to reduce emissions from construction equipment and activities. Therefore, the future construction activities under the General Plan and Zoning Code Update would be consistent with the AQMP under control strategies.

Growth Projections
The Project would result in an increase in short-term employment compared to existing conditions. Although future construction activities under the General Plan and Zoning Code Update would generate construction workers, it would not necessarily create new construction jobs; construction-related jobs generated by the Project would likely be filled by employees within the construction industry within Culver City and the greater Los Angeles County region.

Construction industry jobs generally have no regular place of business, as construction workers commute to job sites throughout the region, which may change several times a year. Moreover, these jobs would be temporary in nature. Therefore, the construction jobs generated by future construction activities under the General Plan and Zoning Code Update would not conflict with the long-term employment or population projections upon which the AQMPs are based.

Operation
Control Strategies
Future development under the Project would be required to comply with CARB motor vehicle standards, SCAQMD regulations for stationary sources and architectural coatings, Title 24 energy efficiency standards, and, to the extent applicable, to the growth projections in the 2020–2045 RTP/SCS, which are incorporated into the 2022 AQMP.

As discussed above, the AQMP includes land use and transportation strategies from the 2020– 2045 RTP/SCS that are intended to reduce VMT and resulting regional mobile source emissions.

The applicable land use strategies include: planning for growth around livable corridors; providing more options for short trips/neighborhood mobility areas; supporting zero emission vehicles and expanding vehicle charging stations; and supporting local sustainability planning.

The applicable transportation strategies include: managing through the Transportation Demand Management (TDM) Program and the Transportation System Management (TSM) Plan including advanced ramp metering, and expansion and integration of the traffic synchronization network; and promoting active transportation. The majority of the transportation strategies are to be implemented by cities, counties, and other regional agencies such as SCAG and SCAQMD, although some can be furthered by individual development projects.

Development activities under the General Plan and Zoning Code Update would primarily occur on parcels that already contain some existing residential or non-residential uses. The City’s primary approach to accommodating growth is to provide strategies for thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The Project seeks to intensify and mix land uses on key segments of the commercial corridors, and to improve pedestrian experiences along the City’s

4. Environmental Impact Analysis

4.2. Air Quality
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commercial corridors through parking management strategies, active street frontage guidelines, and public realm improvements. To support the community’s housing vision, the land use vision allows for new residential and mixed-use development within the City’s industrial areas. With this approach to accommodating growth, it is anticipated that construction for infill and redevelopment of existing land uses would occur across many areas of the City, including those areas that would maintain land use designations similar to existing conditions.

By distributing growth along corridors, including in areas well served by transit, housing would be incrementally added in existing residential areas, providing access to opportunities, such as jobs, neighborhood amenities, and health care facilities. In addition to infill development and transit-oriented communities (TOC), the land use plan for the City promotes the retention and expansion of creative economy businesses and other emerging technologies in these industrial mixed-use areas and mixed-use corridors; supports the needs of neighborhood-serving retail by encouraging commercial and experiential opportunities, particularly in the Downtown area; and advances strategies that ensure a safe and effective phase out of the Inglewood Oil Field (IOF).

The General Plan and Zoning Code Update would maintain existing parks and open space resources while continuing to expand these resources in an equitable manner. Therefore, the Project would not conflict with AQMP land use and transportation strategies that are intended to reduce VMT and resulting regional mobile source emissions and would result in a less than significant impact associated with air quality. The General Plan and Zoning Code Update would be consistent with the AQMP under the first indicator.

Growth Projections
The emissions inventory for the Air Basin is formed, in part, by existing city and county general plans. The AQMP is based on population, employment and VMT forecasts by SCAG. A project might be in conflict with the AQMP if the development is greater than that anticipated in the local general plan and SCAG’s growth projections. Future development in Culver City that is consistent with the proposed General Plan and Zoning Code Update would increase vehicle trips and VMT that would result in emissions of ozone precursors and particulate matter. Individual projects under the proposed General Plan and Zoning Code Update would be required to undergo subsequent environmental review pursuant to CEQA and would be required to demonstrate compliance with the AQMP. Individual projects would also be required to demonstrate compliance with SCAQMD rules and regulations governing air quality.

Growth projections for population, housing, and jobs under the General Plan and Zoning Code Update were presented in Chapter 2, Section 2.4. The General Plan and Zoning Code Update projects a population of 62,400 persons in 2045, which would be an increase of 21,600 persons, compared to the existing (2020) population and would exceed the SCAG growth forecast of 41,600 persons in 2045.
83 The General Plan and Zoning Code Update also projects 28,310 households in 2045, for an increase of 11,310 households compared to the existing (2019) household count, which would exceed the SCAG growth forecast of 18,000 households in 2045.
84 In addition, the General Plan and Zoning Code Update projects 84,300 jobs in 2045,

83 SCAG, 2020. Connect SoCal 2020, Demographics and Growth Forecast, September 2020. 84 SCAG, 2020. Connect SoCal 2020, Demographics and Growth Forecast, September 2020.

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which would be an increase of 16,260 jobs compared to the existing (2019) job count and would exceed the SCAG growth forecast of 64,100 jobs in 2045.85 Implementation of the General Plan and Zoning Code Update is anticipated to result in a net increase of 12,706 residential units, 2,682,400 square feet of commercial uses, and 625,700 square feet of industrial uses. No change is projected for institutional square footage. Additionally, the General Plan and Zoning Code Update will build more active and shared modes of getting to, from, and through Culver City by providing more reliable, safe, affordable, clean, and connected transportation and mobility options for people of all ages and abilities.

As required by SB 1000, the Community Health and Environmental Justice Element identifies SB 1000 Priority Neighborhoods (see Figure 4.2-1). The Community Health and Environmental Justice Element also includes a number of policies relevant to air quality. These policies focus on reducing emissions and reducing exposure to pollution at sensitive land uses and would address potential impacts related to conflicts with an applicable air quality plan.

Culver City continues to coordinate with SCAQMD and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the operation of future development under the proposed General Plan and Zoning Code Update would not conflict with or obstruct the implementation of the applicable air quality plan. The proposed General Plan policies listed below would potentially reduce emissions, which would address potential impacts related to conflicts with an applicable air quality plan. Nonetheless, the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would be significant and mitigation measures would be required.

Zoning Code Update
The Zoning Code Update would establish new zoning districts and associated development standards to correspond with and implement the General Plan Update within the city. Future development would be required to comply with applicable emissions control strategies and regulations as discussed above. Nonetheless, the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City. Therefore, future development under the Project would result in a significant impact related to conflicts with or obstruction of implementation of the applicable air quality plan and mitigation measures would be required.

Applicable Proposed General Plan Goals and Policies
Community Health and Environmental Justice Element
Goal CHEJ-2: Exposure to Pollutants. All Culver City occupants and visitors enjoy clean air, water, and soil within residential and commercial neighborhoods, work and education centers, and recreational facilities.

CHEJ-2.1: Air quality monitoring. Monitor and improve poor air quality related to stationary and mobile sources of pollution.

CHEJ-2.2: Inglewood Oil Field. Reduce existing and future pollution burden from oil and gas facilities. Support implementation of an amortization program (such as the Oil

85 SCAG, 2020. Connect SoCal 2020, Demographics and Growth Forecast, September 2020.

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Termination Ordinance, or equivalent) for portions of the IOF located within the City limit and further encourage completion of potential amortization program for portions of the IOF outside of, but adjacent to, Culver City.

CHEJ-2.3: Mobile source pollution. Reduce air pollution and vehicle-related emissions, especially from diesel-based trucks, that travel in Culver City.

CHEJ-2.4: Truck route coordination. Coordinate with the City of Los Angeles and Los Angeles County to ensure that Culver City’s truck routes do not negatively impact neighboring sensitive land uses in their jurisdictions.

CHEJ-2.5: Regional partnerships to eliminate vehicle emissions. Partner with local jurisdictions and agencies, such as the City of Los Angeles’s Transportation Electrification Partnership, to develop plans and advance strategies that foster the transition of the transportation sector from fossil-fueled powered vehicles to zero emission vehicles such as battery-electric or hydrogen fuel-cell electric.

CHEJ-2.6: Minimizing pollution exposure. Support all residents, particularly SB 1000 Priority Neighborhoods, in minimizing their exposure to harmful air pollutants.

CHEJ-2.7: Sensitive land uses. Limit siting new sensitive land uses, such as schools, daycare centers, and playgrounds within 500 feet of freeways and the IOF. For sensitive land uses that cannot be sited at least 500 feet away, require design mitigations including but not limited to:
• Locate air intake systems for HVAC systems as far away from existing air pollution sources as possible.
• Use HEPA filters in the heating, ventilation, and air conditioning systems and develop a maintenance plan to ensure the filtering system is properly maintained. • For nonresidential buildings, consider using only fixed windows next to any existing sources of pollution.
• Plant landscape barriers between highways and residential areas to reduce noise and air pollution for residents.

CHEJ-2.8: Legacy pollutants. Continue to work with State, federal, and regional agencies to eliminate concentrations of regulated legacy pollutants.

CHEJ-2.9: Climate justice. Ensure SB 1000 Priority Neighborhoods are considered in all future programs related to sustainable development, greenhouse gas mitigation, and climate adaptation.

Conservation Element
Goal C-4: Air quality. Air quality is improved and air pollutant emissions are reduced.

C-4.1: Air quality coordination. Coordinate with agencies at the regional, State, and federal levels to address air quality issues.

C-4.2: Collaborate with the South Coast Air Quality Management District. Work with the South Coast Air Quality Management District to achieve the California Ambient Air Quality Standards and the National Ambient Air Quality Standards.

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C-4.3: Siting uses near freeways. Discourage siting of new sensitive uses, such as schools, daycare centers, and hospitals, within 500 feet from the I-405, I-10, and SR-90.

C-4.4: Siting of uses near IOF. Discourage new sensitive uses, such as schools, daycare centers, and hospitals within 500 feet from the oil and gas uses within the IOF.

Goal S-10: Heat and air quality. A City prepared for the combined impacts of extreme heat and poor air quality.

S-10.1: Resilient building design. Support resilient building design by helping residents weatherize homes to keep them cooler/warmer and more energy efficient and to improve indoor air quality.

S-10.4: Coordinated transportation system. Promote a transportation system coordinated with air quality improvements.

Mitigation Measures
Refer to MM AQ-1 through MM AQ-5, under Threshold AQ-2.

Level of Significance after Mitigation
Implementation of Mitigation Measures MM AQ-1 through MM AQ-5 stated above would serve to reduce the severity of the impacts to emissions of criteria pollutants associated with future development and projected growth from future development under the Project. However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would remain significant and unavoidable.

Result in Cumulatively Considerable Net Increase in Criteria Pollutant Threshold AQ-2: The Project wou ld have a significant impact if future development allowed by the General Plan and Zoning Code Updates w ould result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non -attainment under an applicable federal or state ambient air quality standard.

Impact Statement AQ-2: The Project would result in a potentially significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment during construction and operation due to regional emissions that could exceed the SCAQMD significance thresholds. While implementation of mitigation measures would serve to reduce the severity of the effects, impacts would remain significant and unavoidable.

Ozone, NO2 and VOC (as ozone precursors), PM10, and PM2.5 are pollutants of concern, as the Air Basin has been designated as a nonattainment area for state ozone, PM10, and PM2.5 and as a federal nonattainment area for ozone and PM2.5. The Air Basin is currently in attainment for state and federal CO, SO2, and NO2 and federal attainment for PM10. SCAQMD has established numerical significance thresholds for regional emissions during construction and operation. The numerical significance thresholds are based on the recognition that the Air Basin is a distinct geographic area with a critical air pollution problem for which ambient air quality

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standards have been promulgated to protect public health. Future projects developed under the General Plan and Zoning Code Update would potentially cause or contribute to an exceedance of an ambient air quality standard if emissions would exceed the SCAQMD regional significance thresholds during construction or operation. Construction and operational impacts are discussed below.

Construction
Construction has the potential to create regional air quality impacts through the use of heavy- duty construction equipment and through vehicle trips generated by construction workers and haul trips traveling to and from each specific project site. In addition, fugitive dust emissions would result from construction activities. During the finishing phase, the application of architectural coatings (i.e., paints) and other building materials would release VOCs.

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

However, as there are no specific projects currently proposed under the General Plan and Zoning Code Update and there is no knowledge as to timing of construction, location or the exact nature of future projects, analysis of construction emissions would be speculative at best.

Information regarding specific development projects, including specific buildings and facilities proposed to be constructed, construction schedules, quantities of grading, and other information would be required in order to provide a meaningful estimate of emissions. Since this information is unknown, emissions modeling is not feasible.

Applicants for future projects developed under the General Plan and Zoning Code Update would be required to comply with SCAQMD rules and regulations as well as conduct CEQA analyses, if necessary, in order to determine significance based on the individual project specifics.

Furthermore, future construction activities under the General Plan and Zoning Code Update would be required to comply with the CARB Air Toxics Control Measure, which limits diesel powered equipment and vehicle idling to no more than five minutes at a location, the CARB In- Use Off-Road Diesel Vehicle regulation, CARB Truck and Bus regulation, and CARB ACT regulation, which all require construction equipment and vehicle fleet operators to repower or replace higher-emitting equipment with less polluting models, including zero- and near-zero- emissions on-road truck technologies as they become developed and commercially available.

Additionally, construction of future development would be required to comply with SCAQMD rules and regulations including Rule 403 for the control of fugitive dust and Rule 1113 for the control of VOC emissions from architectural coatings. Mandatory compliance with these CARB and SCAQMD rules and regulations would reduce emissions, particularly for NO X, PM10, and
PM2.5, during future construction activities under the General Plan and Zoning Code Update.

The proposed General Plan policies, listed below, would potentially reduce emissions, which could potentially address impacts. However, even with mandatory compliance with CARB and SCAQMD rules regulations, it is possible that some future development projects could be large enough in scale and/or intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period emissions could exceed the SCAQMD significance thresholds. Therefore, project-related construction activities could result in a significant regional air quality impact and mitigation measures would be required.

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Operation
Operation of future development under the General Plan and Zoning Code Update would generate criteria pollutant emissions from vehicle trips traveling within the City, energy sources such as natural gas combustion, and area sources such as landscaping equipment and consumer products usage. The on-road mobile sources related to the operation of the future development include passenger vehicles, on-site use of off-road equipment, and delivery trucks. VMT data takes into account ridership, mode, and distance on freeways and local streets. Projected emissions resulting from operational activities of both existing and future development under the General Plan and Zoning Code Update are presented in Table 4.2-7, Estimated Culver City 2045 Regional Operational Emissions.

TABLE 4.2-7
ESTIMATED CULVER CITY 2045 REGIONAL OPERATIONAL EMISSIONS (POUNDS PER DAY) Source VOC NO X CO SO2 PM10 PM2.5
Existing Development plus Culver City General Plan and Zoning Code Update New Development (2045) Area (Consumer Products, Fireplaces,
Landscaping)
6,014 325 7,796 9 624 622
Energy (Natural Gas) 19 323 220 2 25 25
Mobile (Based on 2045 with GPU VMT) 357 619 3,284 13 1,424 368 Total Regional Emissionsa 6,390 1,267 11,300 24 2,073 1,015 Existing Development (2019) 6,316 2,700 15,527 28 1,991 1,004 Net Change 74 (1,433) (4,227) (4) 82 11
SCAQMD Regional Significance Threshold 55 55 550 150 150 55 Exceeds Thresholds? Yes No No No No No
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix B.

SOURCE: ESA, 2024; Fehr & Peers, 2024 (VMT data).

As shown in Table 4.2-7, the net change in operational emissions from existing conditions (2019) compared to existing plus buildout of new development under the General Plan and Zoning Code Update would not exceed the SCAQMD regional significance thresholds, with the exception of VOC emissions that would exceed the threshold. The net change in emissions at 2045 buildout would be negative for NO
X, CO, and SOX compared to existing (2019) conditions
primarily due to the focus of the General Plan and Zoning Code Update on infill development and revitalization to help Culver City achieve an integrated land use mix that accommodates growth while reducing VMT and associated emissions, improvements in vehicle emissions standards and, to a lesser extent, improvements in building energy efficiency standards. The increase in VOC emissions is primarily the result of growth in building floor area and residential units, which results in population growth and associated usage of consumer products. The increase in PM10 and PM2.5 emissions, while below the threshold, is primarily the result of growth in building floor area and residential units, which results in population growth and associated growth in total VMT, which generates a net increase in re-entrained roadway fugitive dust emissions.

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It should be noted that the SCAQMD thresholds were specifically developed for use in determining significance for individual projects and not for program-level documents, such as the General Plan and Zoning Code Update. Furthermore, development of the new residential and nonresidential uses would be based on market demand and would be constructed over the buildout duration through 2045. Overlapping emissions from the construction and operation of new phased development could occur under the General Plan and Zoning Code Update, and the SCAQMD requires such overlapping emissions to be compared to the numeric thresholds for operations. It is possible that some future development projects could be large enough in scale and/or intensity such that operational emissions and/or overlapping emissions from the construction and operation of new phased development could exceed the SCAQMD significance thresholds and result in a significant regional air quality impact and mitigation measures would be required.

The proposed General Plan policies, listed below, would potentially reduce emissions, which could potentially address impacts. As required by SB 1000, the Community Health and Environmental Justice Element includes a number of policies relevant to air quality, focusing on reducing emissions and reducing exposure to pollution at sensitive land uses. In addition, applicants of future development under the General Plan and Zoning Code Update would be required to conduct CEQA analyses, as necessary, in order to determine significance based on the individual project specifics. Through each project’s individual environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual projects that exceed the thresholds would normally result in a potentially significant impact and require mitigation.

Zoning Code Update
The Zoning Code Update would establish new zoning districts and associated development standards to correspond with and implement the General Plan Update within the city. Future development would be required to comply with applicable emissions control strategies and regulations as discussed above. Nonetheless, it is possible that some future development projects could be large enough in scale and/or intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period emissions could exceed the SCAQMD significance thresholds. It is also possible that some future development projects requiring discretionary approval could be large enough in scale and/or intensity such that operational emissions and/or overlapping emissions from the construction and operation of new phased development could exceed the SCAQMD significance thresholds.

Therefore, future development within the City under the Project would result significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment and mitigation measures would be required.

Health Impacts
Because regional emissions from future development under the General Plan and Zoning Code Update may exceed the SCAQMD regulatory thresholds during construction and/or operational activities, there is the potential that these emissions would exceed the CAAQS and NAAQS thus resulting in a health impact. Without knowing the exact specifications for all projects that may be developed under the proposed General Plan and Zoning Code Update, there is no way to

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accurately calculate the potential for health impacts from the overall Project. As applicable, individual projects would be required to provide their own environmental assessments to determine health impacts from the construction and operation of their projects. Because there is no way to determine the potential for these projects to affect health of sensitive receptors within Culver City, the Project would result in a potentially significant health impact.

Applicable Proposed General Plan Goals and Policies
Community Health and Environmental Justice Element
Goal CHEJ-2: Exposure to Pollutants. All Culver City occupants and visitors enjoy clean air, water, and soil within residential and commercial neighborhoods, work and education centers, and recreational facilities.

CHEJ-2.3: Mobile source pollution. Reduce air pollution and vehicle-related emissions, especially from diesel-based trucks, that travel in Culver City.

CHEJ-2.4: Truck route coordination. Coordinate with the City of Los Angeles and Los Angeles County to ensure that Culver City’s truck routes do not negatively impact neighboring sensitive land uses in their jurisdictions.

CHEJ-2.5: Regional partnerships to eliminate vehicle emissions. Partner with local jurisdictions and agencies, such as the City of Los Angeles’s Transportation Electrification Partnership, to develop plans and advance strategies that foster the transition of the transportation sector from fossil-fueled powered vehicles to zero emission vehicles such as battery-electric or hydrogen fuel-cell electric.

CHEJ-2.8: Legacy pollutants. Continue to work with State, federal, and regional agencies to eliminate concentrations of regulated legacy pollutants.

CHEJ-2.9: Climate justice. Ensure SB 1000 Priority Neighborhoods are considered in all future programs related to sustainable development, greenhouse gas mitigation, and climate adaptation.

Conservation Element
Goal C-4: Air quality. Air quality is improved and air pollutant emissions are reduced.

C-4.1: Air quality coordination. Coordinate with agencies at the regional, State, and federal levels to address air quality issues.

C-4.2: Collaborate with the South Coast Air Quality Management District. Work with the South Coast Air Quality Management District to achieve the California Ambient Air Quality Standards and the National Ambient Air Quality Standards.

Goal S-10: Heat and air quality. A City prepared for the combined impacts of extreme heat and poor air quality.

S-10.1: Resilient building design. Support resilient building design by helping residents weatherize homes to keep them cooler/warmer and more energy efficient and to improve indoor air quality.

S-10.4: Coordinated transportation system. Promote a transportation system coordinated with air quality improvements.

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Mitigation Measures
The Project would result in a potentially significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment during construction and operation due to regional emissions that could exceed the SCAQMD significance thresholds. Therefore, the following mitigation measures would be required.

Construction
MM AQ-1: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of NOX, CO, PM10 and/or PM2.5 shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off-Road New Diesel Engine Emission Standards for construction equipment with more than 50 horsepower, unless it can be demonstrated to the Culver City Department of Building and Safety that such equipment is not available. Project sponsors should also consider including zero emissions (ZE) or zero net emissions (ZNE) technologies where appropriate and feasible or higher tier standard diesel equipment as it becomes developed and feasible. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine, as defined by CARB regulations.

Prior to construction, the project engineer shall ensure that all plans for construction phases (e.g., demolition, grading) that would exceed the SCAQMD significance thresholds clearly show the requirement for USEPA and/or CARB Tier 4 or higher emissions standards for construction equipment over 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the construction site for verification by the Culver City Department of Building and Safety. The construction equipment list shall state the makes, models, and numbers of construction equipment on-site. Equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with Section 2449 of the California Code of Regulations, Title 13, Article 4.8, Chapter 9.

MM AQ-2: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of volatile organic compounds (VOCs) as a result of VOC off-gassing emissions from architectural coatings and industrial maintenance coatings shall require the construction contractor to use SCAQMD Low-VOC and/or Super-Compliant VOC architectural coatings and industrial maintenance coatings such that daily volume of coatings applied would not result in emissions that exceed the SCAQMD significance threshold for VOC, unless it can be demonstrated to the City Department of Building and Safety that such coatings for a

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required application are not available. During construction, the construction contractor shall maintain a list of all architectural coatings and industrial maintenance coatings in use on the construction site and the daily volumes of coatings applied for verification by the Culver City Department of Building and Safety.

Operations
MM AQ-3: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the General Plan and Zoning Code Update area, show on the building plans that all major appliances (dishwashers, refrigerators, clothes washers, and dryers) to be provided/installed are Energy Star–certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star or equivalent appliances shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.

MM AQ-4: Applicants for new residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the City Planning Area, indicate on the building plans that the feature below has been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy. • For multifamily dwellings, electric vehicle charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the CALGreen Code (or its successor code).

MM AQ-5: Applicants for new non-residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit for new development projects within the City Planning Area, indicate on the building plans that the features below have been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy. • Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
• Facilities shall be installed to support future electric vehicle charging at each nonresidential building with 30 or more parking spaces. Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).

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Level of Significance After Mitigation
Implementation of Mitigation Measures MM AQ-1 through MM AQ-5 stated above would serve to reduce the severity of the impacts to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment. However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, impacts could exceed the significance thresholds and impacts would remain significant and unavoidable.

Expose Sensitive Receptors to Substantial Pollutant Concentrations Threshold AQ-3: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code Updates would expose sensitive receptors to substantial pollutant concentrations.

Impact Statement AQ-3: The Project would result in a potentially significant impact related to exposure of sensitive receptors to substantial pollutant concentrations during construction and operation due to localized emissions and toxic air contaminant emissions that could exceed the applicable significance thresholds. Implementation of mitigation measures would help to reduce the severity of the impacts. However, impacts would remain significant and unavoidable.

Criteria air pollutant emissions have the potential to result in health impacts on sensitive receptors located near new development within the Planning Area. As discussed previously, localized impacts are associated with on-site project activities. In addition to these localized impacts, vehicle travel associated with the Planning Area has the potential to result in exposure of sensitive receptors to CO emissions from intersection congestion. Based on the nature and extent of new development, nearby sensitive receptors could be exposed to levels of toxic air contaminants that could result in a potential increase in cancer, acute, and/or chronic risk.

Construction
Construction of future individual projects under the General Plan and Zoning Code Update has the potential to create localized air quality impacts through the use of heavy-duty construction equipment and through vehicle trips generated by construction workers and haul trips traveling to and from the project site. In addition, fugitive dust emissions would result from construction activities. During the finishing phase, the application of architectural coatings (i.e., paints) and other building materials would release VOCs. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation and, for dust, the prevailing weather conditions.

The SCAQMD provides guidance for conducting the analysis of localized emissions in their Localized Significance Threshold Methodology (June 2003, revised July 2008), which relies on on- site mass emission rate screening tables and project-specific dispersion modeling typically for sites sized one, two, and five acres. The SCAQMD has established screening criteria that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance thresholds and therefore not cause or contribute to an exceedance of the applicable ambient air quality standards without project-specific dispersion modeling. The screening criteria depend on: (1) the area in which the project is located, (2) the size of the project area,

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and (3) the distance between the project area and the nearest sensitive receptor. The localized significance thresholds are applicable to NOX, CO, PM10, and PM2.5. Example screening localized significance thresholds for projects 5 acres in size located within 25 meters of the nearest sensitive receptors for SRA 2 are listed in Section 4.2.4, above. Should individual projects exceed applicable screening level thresholds in the SCAQMD Localized Significance Threshold Methodology (or successor guidance document), project-specific dispersion modeling may be conducted to demonstrate that no exceedance of the concentration-based thresholds (from which the screening tables are derived) would occur.

Concentrations of TACs, or in federal parlance, HAPs, are also used as indicators of ambient air quality conditions. Sensitive receptors may be located within close proximity to future projects under the Project. SCAQMD recommends that construction health risk assessments be conducted for substantial sources of DPM emissions (e.g., projects with substantial construction activities, such as earth-moving and excavation construction activities) in proximity to sensitive receptors and has provided guidance for analyzing mobile source diesel emissions. Localized DPM emissions strongly correlate with localized PM2.5 emissions. However, localized analysis does not directly measure health risk impacts. Therefore, future projects under the General Plan and Zoning Code Update may potentially require project-specific dispersion modeling to evaluate potential health risk impacts associated with construction.

However, there are no specific projects currently proposed under the Project and there is no information regarding specific development projects, including specific buildings and facilities proposed to be constructed, construction schedules, quantities of grading, and other information that would be required in order to provide a meaningful estimate of emissions. Since this information is unknown, emissions modeling is not feasible and would be speculative at best.

Applicants of future project developments under the Project would be required to conduct CEQA analyses, if necessary, in order to determine significance based on the individual project’s specifics. Through the individual environmental review process, localized emissions may be quantified and compared against project-specific thresholds. Individual projects that exceed the thresholds would normally be considered significant and require mitigation. Because potential new development could occur close to existing sensitive receptors, the development that would be accommodated by the General Plan and Zoning Code Update has the potential to expose sensitive receptors to substantial pollutant concentrations. The proposed General Plan policies, listed below, would potentially reduce emissions, which could potentially address impacts.

Nonetheless, construction equipment exhaust combined with fugitive particulate matter emissions has the potential to expose sensitive receptors to substantial concentrations of criteria air pollutant emissions or DPM and result in a potentially significant impact and mitigation measures would be required.

Operational
Local Air Quality
The SCAQMD recommends the evaluation of localized air quality impacts on sensitive receptors in the immediate vicinity of a project. However, the impacts are based on specific equipment and operations. Because the exact nature, location, and operation of the future developments are unknown, quantification of potential localized operational impacts and health risks would

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not be feasible and would be speculative. Land uses that have the potential to generate substantial stationary sources of emissions that would require a permit from SCAQMD include industrial land uses, such as chemical processing facilities and gasoline-dispensing facilities.

Warehouses and distribution centers may generate substantial DPM emissions from off-road equipment use and truck idling. Under the Project, industrial-type land uses such as the aforementioned land uses may be permitted within the City Planning Area. As operation of some these future developments may occur within proximity to sensitive receptors, there is the potential for localized emissions to exceed the significance thresholds and result in a result in a potentially significant impact.

The General Plan policies, listed below, would potentially reduce emissions, which could potentially address impacts. As required by SB 1000, the Community Health and Environmental Justice Element includes a number of policies relevant to air quality, which focus on reducing emissions and reducing exposure to pollution at sensitive land uses. In addition, applicants for future development under the General Plan and Zoning Code Update would be required to conduct CEQA analyses, if necessary, in order to determine significance based on the individual project specifics. Through an individual environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual projects that exceed the thresholds would normally result in a potentially significant impact and mitigation measures would be required.

Intersection Hotspot Analysis
The potential for the Project to cause or contribute to CO hotspots is evaluated by comparing project intersections (both intersection geometry and traffic volumes) with prior studies conducted by SCAQMD in support of their AQMPs and considering existing background CO concentrations. As discussed below, this comparison demonstrates that the Project would not cause or contribute considerably to the formation of CO hotspots, that CO concentrations at project intersections would remain well below the ambient air quality standards, and that no further CO analysis is warranted or required.

As shown previously in Tables 4.2-2 and 4.2-3, CO levels in the Planning Area are substantially below the federal and state standards. Maximum CO levels in recent years are 1.5 to 2.0 ppm (1- hour average) and 1.0 to 1.3 ppm (8-hour average). CO levels decreased dramatically in the Air Basin with the introduction of the catalytic converter in 1975. No exceedances of CO have been recorded at monitoring stations in the Air Basin since 2003 86 and the Air Basin is currently
designated as a CO attainment area for both the CAAQS and NAAQS. Thus, it is not expected that CO levels at Project-impacted intersections would rise to the level of an exceedance of these standards.

Additionally, SCAQMD conducted CO modeling for the 2003 AQMP for the four worst-case intersections in the Air Basin: (1) Wilshire Boulevard and Veteran Avenue; (2) Sunset Boulevard and Highland Avenue; (3) La Cienega Boulevard and Century Boulevard; and (4) Long Beach Boulevard and Imperial Highway. In the 2003 AQMP, SCAQMD notes that the intersection of

86 SCAQMD, 2017. Final 2016 AQMP, March 2017, p. 2-38.

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Wilshire Boulevard and Veteran Avenue is the most congested intersection in Los Angeles County, with an average daily traffic volume of approximately 100,000 vehicles per day. This intersection is located near the on- and off-ramps to Interstate 405 in West Los Angeles. The evidence provided in the 2003 AQMP shows that the peak modeled CO concentration due to vehicle emissions at these four intersections was 4.6 ppm (1-hour average) and 3.2 (8-hour average) at Wilshire Boulevard and Veteran Avenue. When added to the existing background CO concentrations, the screening values would be up to 6.6 ppm (1-hour average) and 4.5 ppm (8- hour average). Based on the intersection volumes identified at these modeled intersections, if a project’s traffic levels exceed 100,000 vehicles per day at any project impacted intersection, there would be the potential for a significant impact and dispersion modeling would need to be conducted to determine the project level impact.

Based on roadway segment volumes under the buildout horizon, the roadway intersection with the maximum potential peak traffic would be that of Sepulveda Boulevard and Jefferson Boulevard. The peak roadway intersection volume at Sepulveda Boulevard and Jefferson Boulevard would be approximately 85,500 vehicles per day from buildout of future development under the General Plan and Zoning Code Update, 87 which would be below the
100,000 vehicles per day modeled in SCAQMD’s 2003 AQMP CO attainment demonstration.

Furthermore, CO emissions from vehicles have substantially reduced compared to 2003 era vehicles based on improved vehicle emissions standards. As a result, CO concentrations are expected to be less than those estimated in the 2003 AQMP, which would not exceed the applicable thresholds. Thus, this comparison demonstrates that the Project would not contribute considerably to the formation of CO hotspots and no further CO analysis is required.

The Project would result in a less than significant impact with respect to CO hotspots.

Toxic Air Contaminants
Construction and operation of the Project would result in emissions of TAC, predominantly from diesel particulate emissions from on- and off-road vehicles during construction and from the operation of diesel fueled equipment or generators during operational activities. Because the exact nature, location, and operation of the future developments are unknown, and because health risk impacts from TACs are cumulative over the life of the nearby receptors, quantification of potential health risks would be speculative. However, as construction and operation of these future developments may occur within close proximity to sensitive receptors, there is the potential for risk to exceed regulatory levels. Therefore, health risk with respect to the development anticipated by the Project would be potentially significant.

Zoning Code Update
The Zoning Code Update would establish new zoning districts and associated development standards to correspond with and implement the General Plan Update within the city. Future development would be required to comply with applicable emissions control strategies and regulations as discussed above. Nonetheless, it is possible that some future development projects could be large enough in scale and/or intensity such that many pieces of heavy-duty construction equipment may be required and that construction period emissions could exceed

87 Based on ESA Traffic Noise Modeling data and VMT data from Fehr & Peers.

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the SCAQMD localized significance thresholds. It is also possible that some future development projects could be large enough in scale and/or intensity such that operational emissions from new development could exceed the SCAQMD localized significance thresholds. Therefore, future development within the City under the Project would result in a significant impact related to exposure of sensitive receptors to substantial pollutant concentrations and mitigation measures would be required.

Applicable Proposed General Plan Goals and Policies
Community Health and Environmental Justice Element
Goal CHEJ-2: Exposure to Pollutants. All Culver City occupants and visitors enjoy clean air, water, and soil within residential and commercial neighborhoods, work and education centers, and recreational facilities.

CHEJ-2.1: Air quality monitoring. Monitor and improve poor air quality related to stationary and mobile sources of pollution.

CHEJ-2.2: Inglewood Oil Field. Reduce existing and future pollution burden from oil and gas facilities. Support implementation of an amortization program (such as the Oil Termination Ordinance, or equivalent) for portions of the IOF located within the City limit and further encourage completion of potential amortization program for portions of the IOF outside of, but adjacent to, Culver City.

CHEJ-2.4: Truck route coordination. Coordinate with the City of Los Angeles and Los Angeles County to ensure that Culver City’s truck routes do not negatively impact neighboring sensitive land uses in their jurisdictions.

CHEJ-2.6: Minimizing pollution exposure. Support all residents, particularly SB 1000 Priority Neighborhoods, in minimizing their exposure to harmful air pollutants.

CHEJ-2.7: Sensitive land uses. Limit siting new sensitive land uses, such as schools, daycare centers, and playgrounds within 500 feet of freeways and the IOF. For sensitive land uses that cannot be sited at least 500 feet away, require design mitigations including but not limited to:
• Locate air intake systems for HVAC systems as far away from existing air pollution sources as possible.
• Use HEPA filters in the heating, ventilation, and air conditioning systems and develop a maintenance plan to ensure the filtering system is properly maintained. • For nonresidential buildings, consider using only fixed windows next to any existing sources of pollution.
• Plant landscape barriers between highways and residential areas to reduce noise and air pollution for residents.

CHEJ-2.8: Legacy pollutants. Continue to work with State, federal, and regional agencies to eliminate concentrations of regulated legacy pollutants.

CHEJ-2.9: Climate justice. Ensure SB 1000 Priority Neighborhoods are considered in all future programs related to sustainable development, greenhouse gas mitigation, and climate adaptation.

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Conservation Element
Goal C-4: Air quality. Air quality is improved and air pollutant emissions are reduced.

C-4.1: Air quality coordination. Coordinate with agencies at the regional, State, and federal levels to address air quality issues.

C-4.2: Collaborate with the South Coast Air Quality Management District. Work with the South Coast Air Quality Management District to achieve the California Ambient Air Quality Standards and the National Ambient Air Quality Standards.

C-4.3: Siting uses near freeways. Discourage siting of new sensitive uses, such as schools, daycare centers, and hospitals, within 500 feet from the I-405, I-10, and SR-90.

C-4.4: Siting of uses near IOF. Discourage new sensitive uses, such as schools, daycare centers, and hospitals within 500 feet from the oil and gas uses within the IOF.

Goal S-10: Heat and air quality. A City prepared for the combined impacts of extreme heat and poor air quality.

S-10.1: Resilient building design. Support resilient building design by helping residents weatherize homes to keep them cooler/warmer and more energy efficient and to improve indoor air quality.

Mitigation Measures
The Project would result in a potentially significant impact related to exposure of sensitive receptors to substantial pollutant concentrations during construction and operation due to localized emissions and toxic air contaminant emissions that could exceed the applicable significance thresholds. Therefore, the following mitigation measures would be required.

Refer to MM AQ-1 and MM AQ-3, under Threshold AQ-2.

MM AQ-6: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential localized project construction-related air quality impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing localized significance thresholds (LST) air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the Planning Department.

MM AQ-7: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-52 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
to issuance of a building permit, submit a construction-related air quality study that evaluates potential health risk impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing health risk impacts. If health risk impacts are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City’s Planning Department.

Level of Significance After Mitigation
Implementation of Mitigation Measures MM AQ-1, MM AQ-3, MM AQ-6, and MM AQ-7 would serve to reduce the severity of the impacts to exposure of sensitive receptors to substantial pollutant concentrations. However, even with implementation of Mitigation Measures MM AQ- 1, MM AQ-3, MM AQ-6, and MM AQ-7, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

4.2.5 Cumulative Impacts Analysis
The SCAQMD recommends using two methodologies to assess the cumulative impact of air quality emissions: (1) a project’s consistency with the current AQMP be used to determine its potential cumulative impacts. or (2) that project-specific air quality impacts be used to determine the project’s potential cumulative impacts to regional air quality. 88 Consistency with Air Quality Management Plan
The SCAQMD recommends assessing a project’s cumulative impacts based on whether the project is consistent with the current AQMP. CEQA Guidelines Section 15064(h)(3) provides guidance in determining the significance of cumulative impacts. Specifically, CEQA Guidelines Section 15064(h)(3) states in part that:
“A lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program which provides specific requirements that will avoid or substantially lessen the cumulative problem (e.g., water quality control plan, air quality plan, integrated waste management plan) within the geographic area in which the project is located. Such plans or programs must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency …”
For purposes of the cumulative air quality analysis with respect to CEQA Guidelines Section 15064(h)(3), the Project’s cumulative air quality impacts are determined not to be significant

88 SCAQMD, 2003. White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, Appendix D.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-53 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
based on its consistency with the SCAQMD’s adopted 2022 AQMP. As discussed above in Impact AQ-1, the City’s proposed General Plan and Zoning Code Update would not conflict with AQMP construction, land use, and transportation strategies that are intended to reduce construction emissions, VMT, and resulting regional mobile source emissions. In addition, construction and operation would not conflict with growth projections as Culver City continues to coordinate with SCAQMD and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. As such, a cumulative impact would be less than significant under this criterion.

Project-Specific Impacts
The SCAQMD CEQA Air Quality Handbook states that the “Handbook is intended to provide local governments, project proponents, and consultants who prepare environmental documents with guidance for analyzing and mitigating air quality impacts of projects.” 89 The SCAQMD CEQA Air
Quality Handbook also states that “[f]rom an air quality perspective, the impact of a project is determined by examining the types and levels of emissions generated by the project and its impact on factors that affect air quality. As such, projects should be evaluated in terms of air pollution thresholds established by the District.”
90 The SCAQMD has provided guidance on
addressing the cumulative impacts for air quality. as discussed below:91 “As Lead Agency, the AQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR… Projects that exceed the Project -specific significance thresholds are considered by the SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project- specific thresholds are generally not considered to be cumulatively significant.” The SCAQMD recommends evaluating cumulative impacts for individual projects based on whether the project exceeds the SCAQMD’s recommended daily thresholds for project-specific impacts for those pollutants for which the Air Basin is in non-attainment. Thus, the cumulative analysis of air quality impacts follows SCAQMD’s guidance such that construction or operational Project emissions would be considered cumulatively considerable if Project-specific emissions exceed an applicable SCAQMD recommended significance threshold. As discussed above in Impact AQ-2, future development that may occur under the proposed General Plan and Zoning Code Update may result in construction or operational emissions that could exceed the SCAQMD significance thresholds. Implementation of Mitigation Measure(s) MM AQ-1 through MM AQ-5 would serve to reduce the severity of the impacts. However, even with implementation of these measures, the cumulative impact would be significant and unavoidable.

89 SCAQMD, 1993. CEQA Air Quality Handbook, April 1993, page iii. 90 S CAQMD, 1993. CEQA Air Quality Handbook, April 1993, page 6-1. 91 S CAQMD, 2003. White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, Appendix D.

4. Environmental Impact Analysis

4.2. Air Quality
General Plan 2045 and Zoning Code Update Project 4.2-54 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.3-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.3 Biological Resources

4.3.1 Introduction
This section evaluates the potential local and regional environmental impacts on biological resources from implementation of the Project, including potential impacts related to candidate, sensitive, or special status species; riparian and sensitive natural habitat; State and federally protected wetlands; wildlife corridors and nursery sites; and tree preservation policies and ordinances. The section provides context regarding the existing vegetation communities and habitat, sensitive biological resources, and planning issues and proposed improvements, as well as relevant federal, State, and local regulations and programs.

4.3.2 Environmental Setting
Local Setting
The majority of the Planning Area has been heavily developed and land uses primarily consist of residential neighborhoods interspersed with commercial, industrial, and other non-residential uses. The city is bisected by various roads and major highways, most notably Interstate 405 (I- 405) and State Route 90 (SR-90) with Interstate 10 (I-10) near the city’s northern city limit. A few undeveloped or semi-open space areas remain, including Blair Hills, Culver City and Fox Hills Parks, Hillside Memorial and Holy Cross Cemeteries, and portions of the Inglewood Oil Field (IOF) within the City and SOI. Concrete-channelized portions of Ballona Creek traverse the Planning Area eventually opening into a soft-bottomed channel downstream. Outside the Planning Area limits, Ballona Creek flows into the Pacific Ocean adjacent to the Ballona Wetlands located in the city of Los Angeles.

Vegetation Communities and Habitat
Various habitats and vegetation communities are present within the Planning Area including Coastal Scrub, Coastal Scrub – Degraded, Channelized Streambed (Ballona Creek), Coast Live Oak Woodland, Non-native/Ornamental, Non-native Tree Stands, and Disturbed. Most of the city is developed and mapped as Urban/Developed while areas outside the city limits within the Planning Area are mostly undeveloped with a combination of vegetation communities listed above (except for channelized streambed). Figure 4.3-1, Vegetation Communities and Habitat in Culver City, depicts communities mapped within the Planning Area, which are described in detail below.

Coastal Scrub
Coastal scrub is restricted to the eastern portion of the Planning Area and is located mostly within the portion of the IOF in the Planning Area and Kenneth Hahn State Recreation Area.

Small, remnant patches of this natural community are situated amongst unpaved and gravel access roads and hiking trails, oil infrastructure and various hardscape (e.g., access roads).

City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); ESA (2019); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa rkw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Natural Communities and Land Uses
Channelized Streambed (Ballona Creek)
Coastal Scrub
Coastal Scrub - Degraded
Coast Live Oak Woodland
Non-native/Ornamental
Non-native Tree Stands
Disturbed
Urban/Developed

SEE DETAIL
DETAIL
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); ESA (2019); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County )
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa r kw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Natural Communities and Land Uses
Channelized Streambed (Ballona Creek)
Coastal Scrub
Coastal Scrub - Degraded
Coast Live Oak Woodland
Non-native/Ornamental
Non-native Tree Stands
Disturbed
Urban/Developed

SEE DETAIL
DETAIL
Culver City General Plan 2045
Figure 4.3-1
Vegetation Communities and Habitat in Culver City
SOURCE: City of Culver City, 2021; County of Los Angeles, 2023; ESA, 2019; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
This community is characterized by a shrub layer of plant species such as California sagebrush (Artemisia californica), coyote brush (Baccharis pilularis), bush sunflower (Encelia californica) and deerweed (Acmispon glaber) dominant intermixed with various other plant species including sticky monkey-flower (Diplacus aurantiacus), California buckwheat (Eriogonum fasciculatum), giant wild rye (Elymus condensatus), mock heather (Ericameria ericioides), toyon (Heteromeles arbutifolia), and black sage (Salvia mellifera).

A sparse herbaceous plant layer may be present as well, including various non-native grasses and forbs such as black mustard (Brassica nigra), rip-gut brome (Bromus diandrus), red brome (B. rubens), fennel (Foeniculum vulgare), and shortpod mustard (Hirschfeldia incana).

Coastal Scrub - Degraded
Coastal scrub – degraded, is also limited to the eastern portion of the Planning Area, within the portion of the IOF in the Planning Area and Kenneth Hahn State Recreation Area, interspersed throughout the remnant patches of coastal scrub natural community. This plant community is similar to the coastal scrub vegetation; however, it supports less than 50 percent cover of native species. Dominant non-native grasses and forbs present within this community include black mustard, castor bean (Ricinus communis), fennel, red brome, ripgut brome, and shortpod mustard.

Channelized Streambed (Ballona Creek)
Ballona Creek traverses roughly three linear miles through the Planning Area. The portions of the creek are fully-concrete-lined and up to 200 feet in width, bank-to-bank. Outside city limits, the creek eventually opens up into a soft-bottomed channel with concrete-lined side slopes near Marina Del Rey and terminates at the Pacific Ocean, adjacent to the Ballona Wetlands. The portion of the creek within the Planning Area is virtually devoid of vegetation, aside from weedy, herbaceous species present along the adjacent upland or arising from anomalies in the concrete channel.

Coast Live Oak Woodland
A small, remnant swath of coast live oak woodland was documented within a steep but shallow canyon in the eastern portion of the Planning Area, within the portion of the IOF in the City’s Sphere of Influence (SOI). A dense tree and shrub layer characterizes this community with coast live oak (Quercus agrifolia) as the dominant plant species in the tree layer; however, the community is otherwise very similar to the adjacent coastal scrub vegetation in species composition.

Non-Native/Ornamental
Non-native/Ornamental vegetation is interspersed throughout the Planning Area and includes partially developed, open space areas including various public parks (i.e., Blair Hills Park, Culver City Park, Fox Hills Park, and Veterans Memorial Park), heavily disturbed portions of the Kenneth Hahn State Recreation Area, and the Hillside Memorial and Holy Cross Cemeteries. Vegetation in these areas generally includes large, maintained lawns, augmented with ornamental trees and shrubs, and cultivated gardens.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Non-Native Tree Stand
Non-native tree stands are present in small patches throughout the IOF and Kenneth Hahn State Recreation Area. Tree (or tree-like plant) species present within these areas include, but are not limited to, Peruvian pepper tree (Schinus molle), eucalyptus (Eucalyptus spp.), pine (Pinus spp.), Mexican fan palm (Washingtonia robusta), and Spanish dagger (Yucca aloifolia).

Disturbed
Disturbed areas are generally restricted to isolated patches within the eastern portion of the Planning Area, primarily within the boundaries of the portion of the IOF in the Planning Area and the Kenneth Hahn State Recreation Area. Disturbed areas include those with limited vegetation, which tends to be predominately various non-native grasses and forbs such as black mustard, castor bean, fennel, red brome, rip-gut brome and shortpod mustard. Additional weedy plant species found in these areas include wild oats (Avena spp.), filarees (Erodium spp.), Mediterranean barley (Hordeum murinum), Bermuda grass (Cynodon dactylon), and wild radish (Raphanus sativus).

Urban/Developed
The vast majority of the Planning Area is heavily developed, much of which is devoid of vegetation. Vegetation within these areas is limited to ornamental trees, including street trees, and irrigated landscaping.

Sensitive Biological Resources
A desktop analysis, including a database search and review of available resources, was completed to discern known occurrences of sensitive biological resources within the Planning Area and provide a background for determining what resources have the potential to occur. The database search results are provided in Appendix C.

Special-Status Species
Special-status species are defined as those that, because of their recognized rarity or vulnerability to various forms of habitat loss or population decline, are considered by federal, State, or other agencies to be under threat from human-associated developments. Some of these species receive specific protection that is defined by federal or State endangered species legislation, and others have been designated as special-status based on adopted local policies (i.e., city and county) or the educated opinion of respected resource interest groups (i.e., California Native Plant Society [CNPS]). Special-status species are defined as follows:
• Plants or wildlife listed or proposed for listing as threatened or endangered, or are candidates for possible future listing as threatened or endangered, under the federal Endangered Species Act (FESA) or the California Endangered Species Act (CESA); • Plants of wildlife that meet the definitions of rare or endangered under California Environmental Quality Act (CEQA) Guidelines Section 15380; • Wildlife designated by California Department of Fish and Wildlife (CDFW) as species of special concern, included on the Watch List, or considered Special Animals.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
• Wildlife "fully protected" in California (Fish and Game Code Sections 3511, 4700, and 5050); • Bird species protected by the Migratory Bird Treaty Act (MBTA); • Plants that meet the definitions of rare or endangered under CEQA Guidelines Section 15380;
• Plants considered by CNPS and CDFW to be rare, threatened, or endangered (California Rare Plant Rank [CRPR] 1A, 1B, 2A and 2B plants) in California; • Plants listed by CNPS as those for which more information is needed to determine their status and plants of limited distribution (CRPR 3 and 4 plants); and • Plants listed as rare under the California Native Plant Protection Act (Fish and Game Code 1900 et seq.)
Figure 4.3-2, California Natural Diversity Database Species Occurrences in Culver City, depicts occurrences of special-status plants and wildlife that have been previously reported within the immediate vicinity of the Planning Area.

Special-Status Plants
Based on the results of the desktop analysis, five special-status plants have either been detected within the immediate vicinity of the Planning Area or have the potential to occur based on the presence of suitable habitat.
1 These species are presented in Table 4.3-1, Special-Status Plants in Culver City, which provides a brief description of each species, the preferred habitat, and the general location(s) within the Planning Area where each has been previously observed or has potential to occur.

Special-Status Wildlife
Based on the results of the desktop analysis, a total of 16 special-status wildlife species have either been detected within the immediate vicinity of the Planning Area or have the potential to occur based on the presence of suitable habitat. These special-status wildlife species are presented in Table 4.3-2, Special-Status Wildlife in Culver City, which provides a brief description of each species, the preferred habitat, and the general location(s) within the Planning Area where each has been previously observed or has potential to occur.

1 Four species have been historically reported within the Planning Area; however, suitable habitat for these species is no longer present. The species include: Ventura marsh milk vetch (Astragalus pycnostachyus var. lanosissimus), salt marsh birds beak (Chloropyron maritimum ssp. maritimum), Coulter’s goldfields (Lasthenia glabrata ssp. coulteri), and salt spring checkerbloom (Sidalcea neomexicana). These species are not discussed further.

City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); USFWS (2019); CDFW (2019); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa rkw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
California Natural Diversity Database Species Potential Occurrences Crotch bumble bee
Nuttall's scrub oak
hoary bat
southern tarplant
coastal California gnatcatcher
pallid bat
western ridged mussel
Information for Planning and Consultation Species Occurrence coastal California gnatcatcher
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); USFWS (2019); CDFW (2019); ESRI (2021).

City of Los Angeles
#
GreenValleyCir
°0 0.45 0.90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County )
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa r kw
ay
Washington Pl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
Jefferson Blvd.

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
California Natural Diversity Database Species Potential Occurrences Crotch bumble bee
Nuttall's scrub oak
hoary bat
southern tarplant
coastal California gnatcatcher
pallid bat
western ridged mussel
Information for Planning and Consultation Species Occurrence coastal California gnatcatcher
Culver City General Plan 2045
Figure 4.3-2
California Natural Diversity Database Species
Occurrences in Culver City
SOURCE: City of Culver City, 2021; County of Los Angeles, 2023; USFWS, 2019; CDFW, 2019; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.3-1

SPECIAL-STATUS PLANTS IN CULVER CITY
Species
Status/Element
Ranking Habitat Potential within Planning Area
Southern tarplant
(Centromadia parryi
ssp. australis)
CRPR 1B Generally, this species is
associated with wetlands, such
as vernal pools; however, it is
commonly found in heavily
disturbed areas within or adjacent
to scrub, chaparral and grassland
communities.

This species may occur in the scrub and
chaparral habitat within portions of the IOF in
the Planning Area and Kenneth Hahn State
Recreation Area. This species was observed
in 1994 within 1 mile of the Kenneth Hahn
State Recreation Area (CDFW 2024).

Many-stemmed
dudleya
(Dudleya multicaulis)
CRPR 1B This species is known to occur
within scrub and chaparral, and
cismontane woodland
communities.

There is limited potential for this species to
occur in the scrub and chaparral habitat
within portions of the IOF in the Planning
Area and Kenneth Hahn State Recreation
Area. This species was historically observed
within the Hollywood USGS quadrangle;
however, it may have since been destroyed.

Furthermore, most occurrences within Los
Angeles County are situated at the base of
the San Gabriel Mountains, far from the
boundary of the GPU Planning Area
(Calflora, 2019).

Southern California
black walnut
(Juglans californica)
CRPR 4 This species is known to occur
along riparian corridors; within
scrub and chaparral, and
cismontane woodland
communities.

This species may occur in the scrub and
chaparral habitats within portions of the IOF
and Kenneth Hahn State Recreation Area.

Nuttall’s scrub oak
(Quercus dumosa)
CRPR 1B This species is known to occur
within scrub and chaparral, and
cismotane woodland
communities.

This species was previously detected in the
coastal scrub habitat within the Kenneth
Hahn State Recreation Area in 2014 (CDFW
2024) and may occur within the IOF, as well.

San Bernardino Aster
(Symphyotrichum
defoliatum)
CRPR 1B This species is known to occur
within meadows and seeps,
marshes and swamps, and mesic
areas within scrub and chaparral,
and woodland and coniferous
forest communities.

There is limited potential for this species to
occur in the coastal scrub vegetation within
portions of the IOF in the Planning Area and
Kenneth Hahn State Recreation Area. This
species was historically observed within the
Cienega neighborhood of Los Angeles;
however, it may have been destroyed as a
result of urbanization. The close proximity of
suitable habitat within the GPU Planning
Area to this historical occurrence suggests
that this species may occur within areas of
suitable habitat (Calflora, 2019).

NOTES: CRPR = California Rare Plant Rank;
CRPR 1B – Plants rare, threatened or endangered in California and elsewhere. CRPR 4 – Plants of limited distribution; Locally Important – Identified as rare in the Baldwin Hills.

SOURCE: California Native Plant Society. 2024. Inventory of Rare and Endangered Plants (online edition, v8-01a). California Native Plant Society.

Sacramento, CA. http://www.rareplants.cnps.org/. Accessed February 2024.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.3-2

SPECIAL-STATUS WILDLIFE IN CULVER CITY
Species
Status/Element
Rankinga Habitat Potential within Planning Area
Invertebrates
Crotch bumble bee
(Bombus crotchii)
SCE This species occurs in various
forms of scrub and chaparral
communities.

This species has been previously
reported within approximately 1
mile of the Kenneth Hahn State
Recreation Area and portions of
the IOF in the Planning Area,
within the Baldwin Hills in 1951
and again in 1953 (CDFW 2024).

Marginal habitat for this species is
present in the scrub and chaparral
habitat within these areas.

Reptiles
Coastal western whiptail
(Aspidoscelis tigris ssp.
stejnegeri)
SSC This species occurs in various
forms of scrub and chaparral, and
cismontane woodland communities.

This species has the potential to
occur in the scrub and chaparral
habitat within portions of the IOF
in the Planning Area and Kenneth
Hahn State Recreation Area.

Coast horned lizard
(Phrynosoma coronatum
ssp. blainvillei)
SSC This species occurs in various
forms of scrub and chaparral
communities.

This species has the potential to
occur in the scrub and chaparral
habitat within portions of portions
of the IOF in the Planning Area
and Kenneth Hahn State
Recreation Area.

Birds
Cooper’s hawk
(Accipiter cooperii)
WL This species forages in a variety of
habitats, including scrub and
chaparral and grassland
communities and utilizes various
trees, both native and ornamental
for nesting.

This species may forage and nest
within the various habitats present
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area.

Southern California
rufous-crowned sparrow
(Aimophila ruficeps)
WL This species forages and nests
within various scrub and chaparral
communities on rocky, steep
slopes.

This species may forage and nest
in the scrub and chaparral habitat
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area.

Northern harrier
(Circus cyaneus)
SSC This species forages in a variety of
habitats including scrub and
chaparral and grassland
communities, and utilizes various
trees, both native and ornamental
for nesting.

This species may forage and nest
within the various habitats present
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area.

White-tailed kite
(Elanus leucurus)
FP This species is most commonly
found foraging within open
grassland communities and utilizes
nearby trees, both native and
ornamental, to nest.

This species could forage within
the various habitats present within
portions of the IOF in the Planning
Area and Kenneth Hahn State
Recreation Area, but the habitat
has low suitability.

Loggerhead shrike
(Lanius ludovicianus)
SSC This species can be found foraging
and nesting within scrub, chaparral,
and grassland communities.

This species may forage and nest
within the various habitats present
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area.

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Species
Status/Element
Rankinga Habitat Potential within Planning Area
California horned lark
(Eremophila alpestris ssp.
actia)
WL This species can be found foraging
and nesting within grassland
communities.

This species could forage and
nest within the various habitats
present within portions of the IOF
in the Planning Area and Kenneth
Hahn State Recreation Area.

Coastal cactus wren
(Campylorhynchus
brunneicapillus ssp.
couesi)
SSC This species can be found foraging
or nesting in coastal scrub
communities, primarily those
supporting cactus species
(Cylindropuntia spp. and Opuntia
spp.).

This species may forage and nest
in the coastal scrub habitat within
portions of the IOF in the Planning
Area and Kenneth Hahn State
Recreation Area. A large
population of this species was
recorded as occurring within the
greater Baldwin Hills area until the
early 1990s, last documented in
1996. It is thought that this
population may be destroyed
(Cooper et al 2012).

Coastal California
gnatcatcher
(Polioptila californica)
FT, SSC This species is most commonly
found foraging and nesting within
coastal scrub communities, in
particular, those dominated by
California sagebrush (Artemisia
californica) with gentle slopes.

This species has the potential to
forage and nest in the coastal
scrub vegetation within portions of
the IOF in the Planning Area and
Kenneth Hahn State Recreation
Area. This species has been
previously documented within the
IOF on two occasions, in 1980
(CDFW 2024) and again in 2014
(USFWS 2024).

Mammals
Pallid bat
(Antrozous pallidus)
SSC, SA This species occurs in various
scrub and chaparral, cismontane
woodland communities, and roosts
in abandoned buildings/structures,
metal clad structures and tree
cavities.

This species may forage and nest
in the scrub and chaparral habitat
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area. This
species was documented within 1
mile of the Planning Area in 1925
and again in 1932 (CDFW 2024).

Hoary bat
(Lasiurus cinereus)
SA This species occurs in various
scrub and chaparral, cismontane
woodland communities; and roosts
within coniferous and deciduous
trees.

This species may forage and nest
in the scrub and chaparral habitat
within portions of the IOF in the
Planning Area and Kenneth Hahn
State Recreation Area. This
species was documented within 1
mile of the Planning Area in 1939
(CDFW 2024).

San Diego black-tailed
jackrabbit
(Lepus californicus ssp.
bennettii)
SSC This species occurs in various
forms of scrub, chaparral and
grassland/agricultural communities.

This species may occur in the
scrub and chaparral habitat within
portions of the IOF in the Planning
Area and Kenneth Hahn State
Recreation Area.

Los Angeles pocket
mouse
(Perognathus
longimembris ssp.
brevinasus)
SSC This species occurs in various
forms of scrub, chaparral and
grassland communities.

This species may occur in the
scrub and chaparral habitat within
portions of the IOF in the Planning
Area and Kenneth Hahn State
Recreation Area.

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Species
Status/Element
Rankinga Habitat Potential within Planning Area
San Diego desert woodrat
(Neotoma lepida ssp.
intermedia)
SSC This species occurs in various
forms of scrub, chaparral and
grassland communities.

This species may occur in the
scrub and chaparral habitat within
portions of the IOF in the Planning
Area and Kenneth Hahn State
Recreation Area. This species
was documented within the
greater Baldwin Hills area in 2001
(LA County 2008).

NOTES:
a Federal: FT – Federally Threatened; State: SCE – State Candidate Endangered; SSC – Species of Special Concern, SA – Special Animal, FP – Fully Protected, WL – Watch List.

SOURCE: California Department of Fish and Wildlife. 2024. California Natural Diversity Database (CNDDB). http://www.dfg.ca.gov/biogeodata/cnddb/mapsanddata.asp. Accessed February 2024.

Los Angeles County. 2008. Baldwin Hills Community Standards District, Public Draft Environmental Impact Report. State Clearinghouse No. 2007061133. November 2008.

U.S. Fish and Wildlife Service. 2023a. Critical Habitat Portal. http://ecos.fws.gov/crithab/. Accessed November 2023.

Nesting Birds
Various birds protected by the MBTA may utilize the Planning Area to forage and breed. Most avian species, such as the California scrub jay (Aphelocoma californica), California quail (Callipepla californica), wrentit (Chamaea fasciata), northern flicker (Colaptes auratus), spotted towhee (Pipilo maculatus), and bushtit (Psaltriparus minimus) are more likely to occur within the native scrub and chaparral habitat located within the Kenneth Hahn State Recreation Area and the IOF; however, others, such as the red-tailed hawk (Buteo jamaicensis), common raven (Corvus corax), northern mockingbird (Mimus polyglottos), and mourning dove (Zenaida macroura) are regularly observed foraging and nesting in heavily developed residential areas, dominated by mature street trees and other ornamentally planted trees and shrubs found throughout much of the Planning Area.

Sensitive Natural Communities
CDFW defines sensitive natural communities as those that have a reduced range or are imperiled as a result of development, agriculture, energy production and mining, or an influx of invasive and other non-native species. For rarity, the ranking involves the knowledge of range and distribution of a given type of vegetation, and the proportion of occurrences that are of good ecological integrity. No sensitive natural communities are present within the Planning Area.

Critical Habitat
No critical habitat is present within the Planning Area. The closest critical habitat is for the western snowy plover (Charadrius nivosus ssp. nivosus) and is located approximately 2.75 miles to the southwest, south of Marina del Rey, near Los Angeles International Airport. 2 2 U.S. Fish and Wildlife Service. 2023a. Critical Habitat Portal. http://ecos.fws.gov/crithab/. Accessed November 2023.

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Wetlands and Other Jurisdictional Features
Based on the vegetation communities within the Planning Area and review of the National Wetlands Inventory,3 wetlands are not known to be present within the Planning Area. However, certain activities within the channelized portion of Ballona Creek would be regulated by agencies such as the U.S. Army Corps of Engineers (USACE), Los Angeles Regional Water Quality Control Board (RWQCB), and CDFW. Therefore, any impact to the bed and banks of the channel would require coordination with these regulatory agencies and compliance with applicable regulations when planning new development or when planning any improvement, including restoration of the creek, which may affect jurisdictional areas associated with the creek.

Wildlife Corridors
Corridors provide opportunities for individual animals or groups of animals to disperse or migrate among areas of suitable habitat. These areas of suitable habitat may be extensive but are otherwise partially or wholly separated by unsuitable habitat. Appropriate cover, minimum physical dimensions, and tolerably low levels of disturbance and mortality risk (e.g., limited night lighting and noise, low vehicular traffic levels) are common requirements for corridors.

Resources and conditions in corridors may be quite different than in the areas they connect, but if used by the wildlife species of interest, the corridor would still provide an important function.

Corridors adequate for one species may be inadequate for others.

There are no designated or major wildlife movement corridors within or adjacent to the Planning Area as identified by Los Angeles County Department of Regional Planning (2014) or South Coast Wildlands.
4 Terrestrial wildlife movement between the Project site and other areas of open space are extremely constrained due to urbanization of the area.

4.3.3 Regulatory Framework
This section provides the relevant federal, State, regional, and local regulations applicable to the Project.

Federal
The Federal Endangered Species Act of 1973 (USC, Title 16, Sections 1531 through 1543)
The FESA of 1973 and subsequent amendments provide guidance for the conservation of endangered and threatened species and the ecosystems upon which they depend. In addition, the FESA defines species as threatened or endangered and provides regulatory protection for listed species. The FESA also provides a program for the conservation and recovery of threatened and endangered species as well as the conservation of designated critical habitat that the USFWS determines is required for the survival and recovery of these listed species.

3 USFWS, 2023b. National Wetlands Inventory. https://fwsprimary.wim.usgs.gov/wetlands/apps/wetlands- mapper/. Accessed November 1, 2023.
4 South Coast Wildlands. 2008. South Coast Missing Linkages: A Wildland Network for the South Coast Ecoregion.

Produced in cooperation with partners in the South Coast Missing Linkages Initiative. Available online [http://www.scwildlands.org.]

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Clean Water Act (33 USC 1251 through 1376) Sections 401 and 404 – Waters of the United States
The Clean Water Act (CWA) authorizes various State and federal agencies and tribes to implement programs in order to restore and maintain the chemical, physical, and biological integrity of the nation’s waters. Section 404 of the CWA establishes a permit program administered by USACE that regulates the discharge of dredged or fill material into waters of the United States, including wetlands. Section 401 requires a landowner or other entity seeking to obtain a federal license or permit that allows activities resulting in a discharge to waters of the United States to also obtain a state water quality certification.

Migratory Bird Treaty Act (16 USC 703 through 711)
The MBTA (16 U.S. Code [USC] Sections 703–711) includes provisions for the protection of migratory birds, including the non-permitted take of migratory birds, under the authority of the USFWS and CDFW. The MBTA makes it unlawful at any time, by any means or in any manner, to pursue, hunt, take, capture, kill migratory birds, and prohibits the removal of nests occupied by migratory birds. Over 800 species, including geese, ducks, shorebirds, raptors, songbirds, and many common species are protected under the MBTA.

In practice, federal permits potentially impacting migratory birds typically have conditions that require pre-disturbance surveys for nesting birds, and, in the event nesting is observed, a buffer area with a specified radius must be established within which no disturbance or intrusion is allowed until the young have fledged and left the nest, or it has been determined that the nest has failed. Activities that would require such a permit would include, but not be limited to, the destruction of migratory bird nesting habitat during the nesting season when eggs or young are likely to be present. If not otherwise specified in the permit, the size of the buffer area varies with species and local circumstances (e.g., presence of busy roads, intervening topography), and is based on the professional judgment of a qualified biologist.

State
California Endangered Species Act – California Fish and Game Code Section 2050 et seq.

The CESA establishes the policy of the State to conserve, protect, restore, and enhance threatened or endangered species and their habitats. For projects that would affect a listed species under both the CESA and the FESA, compliance with the FESA would satisfy the CESA if the CDFW determines that the federal incidental take authorization is “consistent” with the CESA under California Fish and Game Code Section 2080.1. For projects that would result in take of a species listed under the CESA only, the project operator would have to apply for a take permit under Section 2081(b).

California State Fish and Game Code Section 1602
Under this section of the California Fish and Game Code, the landowner or other entity is required to notify CDFW prior to undertaking any project that would divert, obstruct, or change the natural flow, bed, channel, or bank of any river, stream, or lake.

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California Fully Protected Species
California fully protected species are described in Sections 3511, 4700, 5050, and 5515 of the California Fish and Game Code. These statutes prohibit take or possession of fully protected species. The CDFW is unable to authorize incidental take of fully protected species when activities are proposed in areas inhabited by those species.

California State Fish and Game Code Sections 2080 and 2081 Section 2080 of the California Fish and Game Code states that “No person shall import into this state [California], export out of this state, or take, possess, purchase, or sell within this state, any species, or any part or product thereof, that the Commission [State Fish and Game Commission] determines to be an endangered species or threatened species, or attempt any of those acts, except as otherwise provided in this chapter, or the Native Plant Protection Act, or the California Desert Native Plants Act.”
California State Fish and Game Code Sections 3503, 3503.5, 3513, and 3800 Sections 3503, 3503.5, and 3800 of the California Fish and Game Code prohibit the take or possession of birds, their nests, or eggs. Disturbance that causes nest abandonment and/or loss of reproductive effort (killing or abandonment of eggs or young) is considered a "take." Such a take would also violate federal law protecting migratory birds. Incidental Take Permits (i.e., Management Agreements) are required from the CDFW for projects that may result in the incidental take of species listed by California as endangered, threatened, or candidate species.

The permits require that impacts to protected species be minimized to the extent possible and mitigated to a level of insignificance.

Clean Water Act, Section 401
Under Section 401 of the CWA, the local RWQCB (for this project, the Los Angeles RWQCB) must certify that actions receiving authorization under Section 404 of the CWA or other federal licenses and permits that may result in any discharge into waters of the United States also meet state water quality standards. The RWQCB requires projects to avoid impacts to wetlands if feasible and requires that projects do not result in a net loss of wetland acreage or a net loss of wetland function and values. Compensatory mitigation for impacts to wetlands and/or waters of the state is typically required.

Porter-Cologne Water Quality Control Act
The RWQCB also has jurisdiction over waters not considered waters of the U.S. Dredging, filling, or excavation of state-only waters constitutes a discharge of waste and prospective dischargers are required to obtain authorization through an Order of Waste Discharge or waiver thereof from the RWQCB and to comply with other requirements of Porter-Cologne Act.

Regional
Los Angeles County General Plan
The Los Angeles County (County) General Plan 2035 provides the policy framework for how and where the unincorporated portions of the county will grow through the year 2035. The current

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County General Plan was adopted in 2015. The County General Plan Conservation and Natural Resources Element (Chapter 9) guides the long-term conservation of natural resources and preservation of available open space areas. Section III of Chapter 9 describes the goals and policies for biological resources occurring within unincorporated county land. The main types of biological resources in the unincorporated areas are regional habitat linkages; forests; coastal zone; riparian habitats, streambeds and wetlands; woodlands; chaparral; desert shrubland; alpine habitats; Significant Ecological Areas (SEAs); and Coastal Resource Areas (CRAs). The County General Plan works to protect and enhance these resources and ensure that the legacy of the unique biotic diversity is passed on to future generations.

Los Angeles County – Baldwin Hills Community Standards District On October 28, 2008, the County’s Board of Supervisors adopted the Baldwin Hills Community Standards District (BHCSD) and certified the associated Environmental Impact Report. The BHCSD establishes development standards and operating procedures for oil and gas operations in the unincorporated County portion of the IOF, which includes approximately 900 acres and over 700 wells. The BHCSD ensures that oil field operations are conducted in a safe manner and are compatible with the surrounding uses, including uses within Culver City and the City’s portion of the IOF. The County is currently in the process of amending the BHCSD to effectively prohibit any new drilling, redrilling or deepening within the County’s portion of the IOF and establish oil and gas activities as a nonconforming use. 5 Los Angeles County Significant Ecological Areas
As part of the Conservation and Open Space and Land Use Elements of the County General Plan, the County has identified and adopted policies since 1970 for the establishment of SEAs. These SEAs were developed to maintain biological diversity by establishing natural biological parameters (key species, habitat types, and linkages) and recommend management practices.

The final boundaries and categories for the 21 SEAs (and 9 Coastal Resource Areas) were established in 2015 with the County Board of Supervisors approval of the General Plan 2035.

The Planning Area does not include any mapped SEAs. The nearest mapped SEA is located approximately 5.5 miles to the north within the Santa Monica Mountains SEA. 6 The closest
Coastal Resource area is about 2 miles to the southwest within the Ballona Wetlands. SEA regulations are not applicable within the Planning Area.

Los Angeles County Oak Tree Protection Ordinance
Portions of the city’s SOI are located within unincorporated Los Angeles County. The Los Angeles County Oak Tree Ordinance was established to recognize oak trees as significant historical, aesthetic, and ecological resources. The goal of the ordinance is to create favorable conditions for the preservation and propagation of this unique and threatened plant heritage. By making this part of the development process, healthy oak trees will be preserved and maintained. The Los Angeles County Oak Tree Ordinance applies to all unincorporated areas of the County. Trees

5 Los Angeles County, Long Range Planning Department, 2023. Baldwin Hills Community Standards District Amendment Website. Available at: Baldwin Hills CSD - LA County Planning. Accessed December 2023. 6 Los Angeles County, 2015. General Plan 2035, Figure 9-3. Significant Ecological Areas and Coastal Resource Areas Policy Map. https://planning.lacounty.gov/generalplan/generalplan. Accessed November 2023.

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subject to County permit requirements include those defined by Title 22.14.150 as: “Valley Oak (Quercus lobata), Coast Live Oak (Quercus agrifolia), any other tree of the oak genus (Quercus)” which is 25 inches or more in circumference (eight inches in diameter) as measured four and one-half feet above mean natural grade; or, in the case of an oak with more than one trunk, whose combined circumference of any two trunks is at least 38 inches (12 inches in diameter) as measured four-and-one-half feet above mean natural grade.

Additionally, the Los Angeles County Oak Tree Ordinance defines the “Protected Zone” of a tree as, “the area within the dripline of an oak tree and extending therefrom to a point at least five feet outside the dripline, or 15 feet from the trunk of a tree, whichever distance is greater” (Title

22.14.150). For the purposes of determining tree impacts, trees that have protected zones that have been encroached upon would also be considered impacted. Under the Los Angeles County Ordinance, a person must obtain a permit to cut, destroy, remove, relocate, inflict damage upon, or encroach into the protected zone of any tree of the oak tree genus that is 8 inches or more in diameter, 4.5 feet above mean natural grade, or in the case of oaks with multiple trunks, a combined diameter of 12 inches or more of the two largest trunks.

Los Angeles Oak Woodlands Conservation Management Plan
To further the County’s compliance with Public Resources Code Section 21083.4, which provides for the conservation of oak woodlands, the County adopted the Los Angeles County Oak Woodlands Conservation Management Plan (OWCMP) in 2012. The OWCMP develops a consistent policy for the management of oak woodlands by providing a voluntary conservation strategy in order to meet the requirements of the California Oak Woodlands Conservation Act (AB 242). The OWCMP extends CEQA consideration of impacts to oak woodlands comprised of oaks greater than 5 inches at DBH and recognizes that conservation of oak woodland habitat extends beyond the protection of individual trees.

Los Angeles Hillside Management Areas
The Hillside Management Area (HMA) Ordinance, which is part of the Project, applies to all unincorporated areas that contain terrain with a natural slope of 25 percent or greater. The goal of the ordinance is to ensure that development preserves the physical integrity and scenic value of HMAs, provides open space, and enhances community character. Locating development outside of HMAs to the greatest extent feasible will be the first emphasis of sensitive hillside design. Where avoidance is not feasible, development of HMAs will be located in the lowest and flattest areas of the hillside in order to minimize impacts on steeper hillside areas. Last, development will utilize a variety of sensitive hillside design techniques to ensure compatibility with the hillside and enhance community character.

Local
Culver City Urban Forest Master Plan
The Urban Forest Master Plan reflects the commitment of the Culver City community to foster a robust and resilient urban forest today and for the future. The Plan articulates a clear vision for the future of Culver City’s urban forest based on analysis of the City’s historical and existing urban forest, as well as on synthesis of current research, best management practices and

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community input. The Plan provides guiding principles for both long-term and day-to-day management, comprehensive tree designations, technical standards, and resources for City and community members. The Plan reflects current best practices, technologies, and city policies while allowing for future revision to maintain its relevance for the next 50 years. The Plan is designed to support Culver City’s environmental goals in regards to stormwater management and carbon sequestration; it also envisions increased shade for pedestrians and motorists, improved air quality, and increased opportunity for healthy recreation.

4.3.4 Project Impact Analysis
Thresholds of Significance and Methodology
Thresholds of Significance
In accordance with Appendix G of the State CEQA Guidelines, a project would have a significant impact related to biological resources if the project would:

Threshold BIO-1: Have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS.

Threshold BIO -2: Have a substantial adverse effect on any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the CDFW or USFWS.

Threshold BIO-3: Have a substantial adverse effect on state or federally protected wetlands (including, but not limited to, marsh, vernal pools, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Threshold BIO-4: Interfere substantially with the movement of any native resident or migratory fish or wildlife species or with established native resident or migratory wildlife corridors or impede the use of native wildlife nursery sites.

Threshold BIO-5: Conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Threshold BIO-6: Conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan.

The Initial Study (Appendix A of this Draft PEIR) found no potentially significant impacts related to conflict with adopted habitat conservation plans or natural community conservation plans (Threshold BIO-6); therefore, this issue is not evaluated in this section. Please see Appendix A for further discussion.

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Methodology
This analysis is based on information obtained largely from literature review. The study began with a literature review conducted to determine special-status plant and animal species known to occur in the vicinity of the Planning Area. In accordance with industry accepted standards, database records were reviewed by conducting a query of the California Department Fish and Wildlife (CDFW) California Natural Diversity Database (CNDDB) (2024), CNPS Rare Plant Inventory (2024), and U.S. Fish and Wildlife Service (USFWS) Information Planning and Conservation System (2024) was conducted for the Beverly Hills, Hollywood, Inglewood and Venice USGS 7.5-minute topographic quadrangle maps.7 A review of the most current edition (June 2023) of CDFW California Sensitive Natural Communities developed for the CNDDB was conducted to determine if any of the plant communities mapped within the Planning Area are considered sensitive, those with a State Rarity Rank of 1-3.8 The following documents prepared for projects located within the vicinity of the Planning Area were also reviewed:
• Baldwin Hills Park, Master Plan;
• Baldwin Hills Community Standards District, Environmental Impact Report; • Results of Focused Presence/Absence Coastal California Gnatcatcher Surveys for Segment C of the Proposed Park to Playa Trail Project, Los Angeles County, California; • Results of Special Status Plant Surveys for the Blair Hills Corridor (Segment C) Portion of the Proposed Park to Playa Trail Project, Los Angeles County, California; and • Urban Biodiversity Assessment: Baldwin Hills Biota Update. Los Angeles: University of Southern California for Baldwin Hills Conservancy (Proposition 84) and Baldwin Hills Regional Conservation Authority (Proposition A).
9 The analysis for each impact discussion considers the following three principal components of the State CEQA Guidelines to determine the potential significant impact under CEQA:
• Magnitude of the impact (e.g., substantial/not substantial) • Uniqueness of the affected resources (e.g., rarity of the resource); and • Susceptibility of the affected resource to perturbation (e.g., sensitivity of the resource).

The evaluation of the significance of impacts considers the interrelationship of these three components. Mitigation measures were considered and applied, if necessary, and then a final

7 USFWS. 2024. Information Planning and Conservation System. https://ipac.ecosphere.fws.gov/ location/index. Accessed February 2024.
8 California Department of Fish and Wildlife, California Sensitive Natural Community List, Vegetation Classification and Mapping Program. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline, accessed November 2023.
9 Longcore, T. (ed). 2016. Urban Biodiversity Assessment: Baldwin Hills Biota Update. Los Angeles: University of Southern California for Baldwin Hills Conservancy (Proposition 84) and Baldwin Hills Regional Conservation Authority (Proposition A).

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determination of significance reached. Mitigation measures considered included those recommended by CDFW in response to the Project’s Notice of Preparation of a Draft EIR.

Biological resources may either be directly or indirectly affected by a project. Impacts may occur as a result of construction of projects anticipated under the General Plan Update and as a result of operation after construction is complete. Furthermore, direct and indirect impacts may either be permanent or temporary. Permanent impacts result in an irreversible impact to or irreversible removal of biological resources, such as the elimination of a plant or animal community or habitat loss. Temporary impacts are those considered reversible, such that biological resources can be successfully restored.

Project Impact Analysis
Adversely Affect Candidate, Sensitive, or Special Status Species Threshold BIO-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would have a substantial adverse effect, either directly or through habitat modifications, on any species identified as a candidate, sensitive, or special status species in local or regional plans, policies, or regulations, or by the CDFW or USFWS.

Impact Statement BIO-1: The Project has the potential to impact existing habitats and associated special-status species within the Planning Area during construction and operation of future development. However, with implementation of Mitigation Measures BIO-1 and BIO-2, the Project would result in less than significant impacts related to special-status species.

General Plan Update
Construction
Special-Status Species
The vast majority of the Planning Area is heavily developed and contains minimal biological resources; however, fragmented, isolated swathes of coastal scrub and chaparral vegetation remain throughout portions of the IOF and Kenneth Hahn State Recreation Area. New development and improvements anticipated as a result of development occurring under the General Plan Update within or adjacent to these areas may harm special-status species.

As described above in Tables 4.3-1 and 4.3-2, there are 21 special-status species that have the potential to occur within the Planning Area, where new development consistent with the General Plan Update could directly or indirectly impact these biological resources. Adverse impacts on special-status wildlife are generally associated with the degree of habitat loss including a habitat’s physical character, quality, and diversity, in addition to abundance of vegetation. As anticipated by the land uses designated in the General Plan Update, shown on Figure 2-6, Draft General Plan Land Use Map, construction of some projects could result in direct removal of suitable wildlife habitat for special-status species (which may include nesting avian species), resulting in the potential mortality of wildlife species existing within the habitat as well as the displacement of more mobile wildlife species to other habitat areas nearby. While the majority of special-status biological resources have a low potential to occur within the

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Preliminary − Subject to Revision
Planning Area as result of the largely developed nature of the Planning Area, new development projects could significantly impact these resources, when analyzed on a project-by-project basis due to specific onsite conditions.

However, construction of new projects facilitated by the General Plan Update would be required to comply with the proposed Goals and Implementing Policies listed below. Specifically, compliance with Goal C-2 Biological Resources and Goal C-3 Wildlife and Plant Species would require new projects under the 2045 General Plan to identify special-status species located within a new project’s impact area including special-status species that are also either State or federally listed as Endangered, Threatened, or Rare.

In addition, future development would be required to comply with all applicable laws, regulations, and ordinances related to special-status species. Development within areas identified as supporting listed special-status species would be required to comply with CESA and/or FESA through applicable regulatory permitting processes. The specific mitigation measures required to allow take of a listed species or to eliminate its habitat would be determined at the time of permitting prior to construction of the individual project. The compensatory mitigation measures would likely include habitat restoration and/or preservation, purchase of habitat at a mitigation bank, payment into lieu fee program credits, or limitations regarding the extent and timing of project construction.

The City is focused on the protection and enhancement of the biological resources within the City’s portion of the IOF as part of ongoing maintenance and use, with a long-term vision for decommissioning and a change in use. As part of the Draft IOF Specific Plan, biological resources could be protected under a Special Status Species and Habitat Protection Plan, project-specific surveys, compliance with USFWS and CDFW requirements, monitoring of nesting birds or sensitive species, avoidance of trees during nesting season, and habitat restoration after completion of drilling activities. As further detailed in Section 4.8, Hazards and Hazardous Materials, in the summer of 2018, the City Council held a special community meeting to receive an update and review the status of the Specific Plan and related Environmental Impact Report.

After receiving public comment and discussing the status, the City Council directed that the Specific Plan be placed on hold. City Council requested staff to identify qualified expert(s) and obtain a proposal to prepare an informational study that could outline options for addressing the potential amortization of oil-related activities and end-of-field life considerations for IOF, which would provide further protection and enhancement of biological resources.

In October 2021, the City adopted an Oil Termination Ordinance intended to implement an amortization program that would terminate and phase out nonconforming oil and gas activities within the City’s portion of the IOF. The Oil Termination Ordinance prohibited any new or expanded oil and gas activity such as drilling of new wells, redrilling or deepening of existing wells, or erection of any structure or facilities related to oil and gas production, with some specific exceptions, as of November 24, 2021. All previously established nonconforming oil uses must be terminated and fully removed within a phase-out time period. On November 14, 2022, the City Council approved a settlement framework with the operator of the Culver City portion of the IOF that requires the operator to plug and abandon all wells and complete the overall

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
closure of the City’s portion of the IOF by December 31, 2029, with the potential for an extension to December 21, 2032 under special circumstances.

The adopted Oil Termination Ordinance (Zoning code amendment P2021-0036-ZCA) included a requirement for “the remediation, restoration and revegetation of the areas of the Oil Use Premises affected by the plugging and removal activities to as near a natural state as practicable, free from all oil, rotary mud, oil-soaked earth, asphalt, concrete, litter, debris and other substances associated with oil operations.” The remediation of the oil field and change in land use from oil operations to open space could directly or indirectly impact special-status species and native habitats. For example, the disturbance or removal of suitable habitat for special-status birds, bats, and small mammals could result in injury or mortality of individuals as well as temporary habitat loss. However, in the long-term, revegetation of remediated areas with native vegetation would provide more habitat for both common and special-status plants and wildlife.

Although compliance with the proposed goals and policies of the General Plan Update and the applicable laws and regulations would help to minimize impacts to special-status species, MM BIO-1 and MM BIO-2 are recommended to ensure that impacts to special-status species from implementation of the General Plan Update would be reduced to a less than significant level.

These mitigation measures require development under the General Plan Update to implement procedures and processes related to protecting special-status species, such as preconstruction surveys, compensatory mitigation for loss of designated habitats, and protection and/or avoidance of special-status species. Implementation of the mitigation measures would ensure that construction impacts to special-status species with implementation of the General Plan Update would be less than significant.

Operations
Special-Status Plants
Operation of some of the future land uses under the General Plan Update would likely include routine landscaping and maintenance, which could have the potential to adversely impact special-status plants where such land uses are proximate to suitable habitat. Potential adverse impacts may result from introducing non-native or invasive species into habitat areas that support special-status plant species and could result in invasive species outcompeting the special-status native species for water, nutrients, and sunlight. The Oil Termination Ordinance is intended to terminate nonconforming oil and gas uses within the City’s portion of the IOF.

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