ATT_1_Proposed_Resolution_to_Adopt_EIR.pdf — City Council Meeting Agenda, August 26, 2024 (part 3 of 6)

Proposed General Plan policies C-2.1, C-2.2, C-2.6, C-2.7, and C-2.9 include habitat improvement and expansion, preservation, protection, and improvement of open space, requirements to plant native species near natural open areas, greater building setbacks to support habitat.

Implementation of these policies would minimize potential impacts of operation of the General Plan Update on special-status plants. Finally, future development would be required to incorporate MM BIO-1 which requires applicants to address operational impacts to special- status plants and identify avoidance and minimization measures to offset potential impacts.

With compliance with the proposed General Plan Update goals and policies and incorporation of the mitigation measures, impacts to special-status plants during operation would be reduced to a less than significant level.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Special-Status Wildlife and Nesting Birds
Operation of the future land uses under the General Plan Update could result in adverse impacts to special-status wildlife and nesting birds due to the removal and/or change in existing habitats, increased vehicular traffic and a corresponding increase in noise and threat of road kill by traffic; an increase in human presence in preserved or open space areas; an increase in predatory and feral pets; an increase in litter, pollutants, dust, oil, and other human debris; and an increase in nighttime light trespass onto preserved open space. The General Plan Update goals and policies listed below aim to improve the conditions of the existing natural habitat and the associated species that utilize those habitats. In addition, City Ordinance No. 2021-016 is intended to terminate nonconforming oil and gas uses within the City over a five-year period.

Finally, to ensure that operational impacts associated with the future land uses are reduced to a less than significant level, future development would be required to incorporate and implement MM BIO-1.

Zoning Code Update
The Zoning Code Update is the mechanism to ensure that the goals and policies in the City’s General Plan Update are implemented through the development that would occur throughout the city over time. The Zoning Code Update would create the zoning districts associated with each of the land use designations in the General Plan Update and the specific development standards, including uses, densities and intensities, setbacks, and heights. Therefore, the Zoning Code Update would not adversely impact special-status species.

Applicable Proposed General Plan Goals and Policies
Conservation Element
Goal C-2: Biological resources. Habitats for sensitive, threatened, and endangered wildlife species are protected and enhanced to support healthy, diverse ecosystems, and carbon storage.

C-2.1: Habitat improvement and expansion. Improve on existing limited habitats and create new habitats to prevent displacing or endangering species in the future.

C-2.2: Open space areas preservation, protection, and improvement. Preserve, protect, and improve open space areas to promote biological resource values.

C-2.3: Vegetation at parks and open spaces. Manage vegetation at parks and open spaces in Culver City to support biodiversity by reducing pesticide use and reducing use of non-native species.

C-2.4: Tree planting. Plant and maintain trees to sequester carbon, reduce urban heat, provide habitat, and contribute to the city’s character.

C-2.5: Native species. Plant native species that provide valuable resources for native wildlife and increase habitat resiliency.

C-2.6: Native vegetation in open space areas. Use native vegetation and maintain standards and guidelines to protect plant and wildlife species from new development near Kenneth Hahn State Recreational Area, the IOF, Baldwin Hills, and other remaining open space areas.

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4.3. Biological Resources
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C-2.7: Building setbacks. Encourage greater building setbacks for new development to support habitat areas and adaptation.

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-2.9: Native spaces requirements near open spaces. Require developments near natural open space areas to plant native species and species that provide resources for native wildlife within landscape areas.

Goal C-3: Wildlife and plant species. Threatened and endangered wildlife and plant species are protected within the city.

C-3.1: Coordination with agencies and jurisdictions to manage wildlife. Coordinate with resource agencies and neighboring jurisdictions to manage threatened and endangered wildlife and plant species and to coordinate on decisions, information, and research related to managing threatened and endangered wildlife.

C-3.2: Resource management agency consultation. Consult with CDFW, RWQCB, USFWS, National Audubon Society, California Native Plant Society, and other resource management agencies, as necessary, during discretionary application reviews to avoid or minimize impacts to biological resources.

C-3.3: Special status species. As appropriate, require that projects subject to discretionary review survey and identify special status species that could be negatively affected during project implementation. If special status species are identified, comply with USFWS and CDFW requirements for special status species.

C-3.4: Wildlife education. Continue to educate residents about wild animals, especially in wildlife interface areas, in order to minimize human-wildlife conflicts.

Mitigation Measures
The Project could result in potentially significant impacts to special-status species and/or their habitats during construction and operation of projects developed under the General Plan Update. However, implementation of MM BIO-1 and MM BIO-2, which would apply to future development, would reduce impacts to a less than significant level.

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 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)].

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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.

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

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a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival.

Level of Significance After Mitigation
With implementation of MM BIO-1 and MM BIO-2, potential significant impacts related to special-status species and their habitats, would be reduced to a less-than-significant level.

Adversely Affect Riparian Habitat or Sensitive Natural Habitat Threshold BIO-2: 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 any riparian habitat or other sensitive natural community identified in local or regional plans, policies, or regulations or by the CDFW or USFWS.

Impact Statement 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.

Given the lack of any sensitive natural communities, including lack of riparian habitat, within the Planning Area, the Project would have no effect on these resources. Therefore, the Project would not result in 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. The General Plan Update and Zoning Code Update would have no impact.

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would have no impact with regard to 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.

Adversely Affect State or Federally Protected Wetlands
Threshold BIO-3: 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 state or federally protected wetlands (including, but not limited to, marsh, vernal pools, coastal, etc.) through direct removal, filling, hydrological interruption, or other means.

Impact Statement 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.

Based on the habitats present within the Planning Area and review of the National Wetlands Inventory, there are no wetlands present within the Planning Area. Therefore, the General Plan Update and Zoning Code Update would have no effect on these resources.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-25 SCH No. 2022030144 City of Culver City March 2024
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The planned Ballona Creek Revitalization Project would enhance the restoration and use of Ballona Creek. The City and community have been identifying opportunities to revitalize the creek over the past 15 years, which include improving access and recreational opportunities along the creek and measures to improve the ecology and water quality of the creek. The City has explored options to restore and enhance the creek to improve biological diversity, including the possible restoration of the concrete-channelized portion of Ballona Creek; however, there are engineering constraints related to managing flood events. Also, the enhancement of Ballona Creek may include its possible designation as a City park. Proposed upgrades may include a northern extension of the existing bike path, security lighting, bike path upgrades, benches, picnic tables, potable water sources, etc. Restoration/enhancement activities and/or the proposed upgrades to recreational facilities along Ballona Creek could result in the removal or disturbance of the concrete-lined channel or the channel banks. These activities may require Clean Water Act permits from the USACE and RWQCB and/or a streambed alteration agreement from CDFW, which would be obtained from the City prior to any work, and permit conditions would be implemented. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Conservation Element
Goal C-6: Ballona Creek. Ballona Creek is transformed such that it mitigates flooding, restores native ecologies, and becomes a scenic multi-purpose open space and recreational corridor.

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-6.8: Trees and landscaping along Ballona Creek. Expand tree planting along Ballona Creek to sequester carbon, adapt to climate change, and provide habitat for wildlife.

Encourage concentrated planting of trees and landscaping along areas of the creek corridor that will upgrade visual quality from prominent vantage points along public streets, and from parks and other public gathering areas.

C-6.9: Engagement related to planting along Ballona Creek. Conduct outreach with residential and other property owners along the Ballona Creek corridor to promote use of native plant materials and a plant palette for creek-adjacent properties.

C-6.10: Sustainable planting along Ballona Creek. Establish Ballona Creek as a sustainable scenic recreational and open space corridor by planting native trees and other compatible landscaping.

C-6.11: Restore Ballona Creek. Coordinate with public and private organizations to support a cohesive approach for planning, implementing, and funding Ballona Creek restoration related to recreational use and trail systems, improved water quality, and increased landscaped open space, while maintaining the priority for flood control.

C-6.13: Engaging non-profit organizations to advance common goals along Ballona Creek. Coordinate with nonprofits and other entities to help implement, fund, maintain, and realize common goals to restore Ballona Creek. Consider the Baldwin Hills Conservancy, California Coastal Conservancy, Ballona Creek Renaissance, The Bay Foundation, Heal the Bay, Friends of Ballona Wetlands, Ballona Wetlands Land Trust,

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General Plan 2045 and Zoning Code Update Project 4.3-26 SCH No. 2022030144 City of Culver City March 2024
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Santa Monica Bay Restoration Commission, Mountains Recreation & Conservation Authority, LA Waterkeeper, Ballona Wetlands Foundation, Southern California Association of Governments (SCAG), U.S. Army Corps of Engineers, Santa Monica Bay Restoration Project, Los Angeles RWQCB, and involved City and County of Los Angeles departments.

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would have a less-than-significant impact on wetlands or other waters.

Interfere with Wildlife Corridors or Wildlife Nursery Sites Threshold BIO-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would 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.

Impact Statement 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.

General Plan Update
Wildlife Corridors
Based on a review of available data sources described in the Environmental Setting section and Subsection 4.3.4.1 Methodology above, no wildlife corridors are present within the Planning Area. Given the lack of any wildlife corridors within the Planning Area, the Project would have no effect on these resources.

Nesting Birds and Wildlife Nursery Sites
As described above, nesting birds and/or nesting bird habitat have been recorded within the Planning Area, where implementation of the General Plan Update could directly or indirectly impact these biological resources. The Planning Area includes several areas that consist of trees, shrubs, and ground cover, including non-native/ornamental vegetation dispersed throughout developed land uses that could be used by breeding raptors and songbirds. Disturbing or destroying active nests is a violation of the MBTA and nests and eggs are protected by Fish and Game Code, Section 3503. While these biological resources have a low potential to occur due to the heavily developed nature of the Planning Area, future development could impact these resources if removal of active nests or harassment of a breeding bird occur during construction, resulting in a potentially significant impact.

4. Environmental Impact Analysis

4.3. Biological Resources
General Plan 2045 and Zoning Code Update Project 4.3-27 SCH No. 2022030144 City of Culver City March 2024
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Construction of development facilitated under the General Plan Update and Zoning Code Update would be required to comply with the proposed Goals and Implementing Policies listed below as well as applicable development standards. Compliance with the City’s Urban Forest Plan and Goals C-2.4, C-6.8, C-6.10, and C-6.11 would aim to enhance and expand the City’s urban forest canopy, which in turn would increase available nesting bird habitat throughout the Planning Area. In addition to the proposed 2045 General Plan goals and polices listed below, future applicants would also be required to comply with the MBTA, which would further reduce impacts to nesting birds.

Although compliance with the General Plan Update goals and policies, the Zoning Code Update and the MBTA would help to minimize impacts to nesting birds and their associated habitat, MM BIO-2 would ensure that impacts to nesting birds would be reduced to a less than significant level on a project-by-project basis. MM BIO-2 would require development under the General Plan Update to implement procedures and processes related to protecting nesting birds and their associated habitat, such as pre-construction surveys and protection and/or avoidance of nesting birds and their associated habitats. Implementation of this mitigation measure would ensure that impacts to nesting birds during construction of future development under the General Plan Update and Zoning Code Update would be less than significant.

Based on review of available information cited above, no known non-avian Wildlife Nursery Sites occur within the Planning Area.

C-2.4: Tree planting. Plant and maintain trees to sequester carbon, reduce urban heat, provide habitat, and contribute to the city’s character.

Goal C-6: Ballona Creek. Ballona Creek is transformed such that it mitigates flooding, restores native ecologies, and becomes a scenic multi-purpose open space and recreational corridor.

C-6.8: Trees and landscaping along Ballona Creek. Expand tree planting along Ballona Creek to sequester carbon, adapt to climate change, and provide habitat for wildlife.

C-6.10: Sustainable planting along Ballona Creek. Establish Ballona Creek as a sustainable scenic recreational and open space corridor by planting native trees and other compatible landscaping.

4. Environmental Impact Analysis

4.3. Biological Resources
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Mitigation Measures
MM BIO-2, provided above, is required.

Level of Significance After Mitigation
The Project impact would result in less than significant impacts with implementation of MM BIO-2 related to wildlife movement.

Conflict with Tree Preservation Policy or Ordinance
Threshold BIO-5: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would conflict with any local policies or ordinances protecting biological resources, such as a tree preservation policy or ordinance.

Impact Statement 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.

Implementation of the General Plan Update and Zoning Code Update would not introduce any potential conflicts with the existing Culver City Tree Removal Ordinance No. 2013-007 (Tree Removal), Los Angeles County Oak Tree Protection Ordinance, or the Los Angeles County Oak Woodlands Conservation Management Plan, which applies to the city’s SOI. Future development facilitated under the General Plan Update would be subject to the City and County’s tree preservation ordinances, and the County’s oak woodland management policies, as applicable, which includes adherence to tree management and trimming procedures. In addition, proposed General Plan Update policies help promote a strong urban forest across public and private properties (Goal C-2 and policy C-2.4) and enhance tree health and appearance of streets and other public spaces through the regular maintenance as well as tree and landscaping planting and care of the existing canopy. Consistency with these policies would further ensure impacts of the General Plan Update to existing and proposed tree resources would be minimized.

Therefore, the impact related to conflicts with local policies or ordinances protecting biological resources would not occur and impacts would be less than significant.

C-2.4: Tree planting. Plant and maintain trees to sequester carbon, reduce urban heat, provide habitat, and contribute to the city’s character.

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would not conflict with local policies or ordinances protecting biological resources and impacts would be less than significant.

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4.3.5 Cumulative Impacts Analysis
The geographic context for the cumulative analysis for biological resources includes the neighboring cities and unincorporated County lands located within the Westside region of Los Angeles County. Future development in this cumulative study area, including growth anticipated under the General Plan Update, would contribute incrementally to the continuing reduction in relatively natural, undisturbed open space areas, contribute to the progressive fragmentation of habitat areas, and decline in species diversity throughout the region, thus resulting in a potentially significant cumulative impact to biological resources.

Since there are limited biological resources and habitats within the Planning Area due to its largely developed nature, implementation of the General Plan Update would not significantly impact biological resources within the Planning Area. Additionally, the General Plan Update includes policies that aim to protect and enhance the biological resources within the Planning Area. Implementation of these policies would not conflict with local policies or ordinances protecting biological resources, and implementation of MM BIO-1 and MM BIO-2 would ensure that the potential impacts to special-status biological resources, including protected habitats, would be reduced to a less than significant level. For these reasons, the Project’s contribution to this potentially significant cumulative impact would not be cumulatively considerable.

Therefore, the Project would result in less than significant cumulative impacts related to biological resources.

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4. Environmental Impact Analysis
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4.4 Cultural Resources

4.4.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on cultural resources from future development allowed under the Project, including potential impacts related to historical resources and archaeological resources. The section provides context regarding the Planning Area’s prehistoric, ethnographic, and historic settings and existing resources, as well as relevant federal, state, and local regulations and programs.

4.4.2 Environmental Setting
Prehistoric Setting
Based on recent research in the region,1 the following prehistoric chronology has been divided into four general periods: the Paleocoastal (12,000 to 8,000 Before Present2 [BP]), Millingstone (8,000 to 3,000 BP), Intermediate (3,000 to 1,000 BP), and Late (1,000 BP to Anno Domino [AD] 1542) Periods. This chronology is manifested in the archaeological record by artifacts and burial practices that indicate specific technologies, economic systems, trade networks, and other aspects of culture.

Paleocoastal Period (12,000–8,000 BP)
While it is not certain when humans first came to California, their presence in Southern California by about 11,000 BP has been well documented. At Daisy Cave, on San Miguel Island, cultural remains have been radiocarbon dated to between 11,100 and 10,950 BP. During this period, the climate of Southern California became warmer and more arid and the human population, residing mainly in coastal or inland desert areas, began exploiting a wider range of plant and animal resources.
3 Millingstone Period (8,000–3,000 BP)
During this period, there is evidence for the processing of acorns for food and a shift toward a more generalized economy that is broadly focused on obtaining a wide variety of goods and resources. The first evidence of human occupation in the Los Angeles area dates to at least 9,000 years BP and is associated with the Millingstone cultures. 4,5 Millingstone cultures were

1 Homburg, Jeffrey A., Diane L. Doublas, Eric C. Brevik, Caroline Tepley, and Antony Orme. 2014.

Paleoenvironmental Reconstruction of the Ballona Lagoon. In People in a Changing Land: The Archaeology and History of the Ballona in Los Angeles, California. Volume I: Paleoenvironment and Culture History, edited by J.

Homburg, J. Douglass, and S. Reddy, pp. 85–110. Statistical Research, Inc., Tucson, Arizona. 2 Before Present (or BP) is a time scale used by archaeologists and geologists that represents the number of years before the present.
3 Byrd, Brian F., and L. Mark Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium, in California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 215– 227.
4 Wallace, W. J. 1955. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11(3):214–230.
5 Warren, C. N. 1968. Cultural Traditions and Ecological Adaptation on the Southern California Coast. Archaic Prehistory in the Western United States, edited by Cynthia Irwin-Williams. Eastern New Mexico University Contributions in Anthropology 1(3):1–14.

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characterized by the collection and processing of plant foods, particularly acorns, and the hunting of a wider variety of game animals.6,7 Millingstone cultures also established more permanent settlements that were located primarily on the coast and in the vicinity of estuaries, lagoons, lakes, streams, and marshes where a variety of resources, including seeds, fish, shellfish, small mammals, and birds, were exploited. Early Millingstone occupations are typically identified by the presence of handstones (manos) and millingstones (metates), while those Millingstone occupations dating later than 5,000 BP contain a mortar and pestle complex as well, signifying the exploitation of acorns in the region.

Intermediate Period (3,000–1,000 BP)
During this time period, many aspects of Millingstone culture persisted, but several socioeconomic changes occurred.
8,9, 10 The native populations of Southern California were becoming less mobile and populations began to gather in small sedentary villages with satellite resource-gathering camps. Increasing population size necessitated the intensified use of existing terrestrial and marine resources.
11 Evidence indicates that the overexploitation of larger, high- ranked food resources may have led to a shift in subsistence, towards a focus on acquiring greater amounts of smaller resources, such as shellfish and small-seeded plants. 12 This period is
characterized by increased labor specialization, expanded trading networks for both utilitarian and non-utilitarian materials, and extensive travel routes. Although the intensity of trade had already been increasing, it now reached its zenith, with asphaltum (tar), seashells, and steatite being traded from Southern California to the Great Basin. The use of the bow and arrow spread to the coast around 1,500 BP, largely replacing the dart and atlatl. 13 Increasing population
densities, with ensuing territoriality and resource intensification, may have given rise to increased disease and violence between 3,300 and 1,650 BP. 14 6 Byrd, Brian F., and L. Mark Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium, in California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 215– 227.
7 Wallace, W. J. 1955. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11(3):214–230.
8 Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast. Plenum Press, New York. 9 Wallace, W. J. 1955. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11(3):214–230.
10 Warren, C. N. 1968. Cultural Traditions and Ecological Adaptation on the Southern California Coast. Archaic Prehistory in the Western United States, edited by Cynthia Irwin-Williams. Eastern New Mexico University Contributions in Anthropology 1(3):1–14.
11 Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast. Plenum Press, New York. 12 Byrd, Brian F., and L. Mark Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium, in California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp. 215– 227.
13 Homburg, Jeffrey A., Diane L. Doublas, Eric C. Brevik, Caroline Tepley, and Antony Orme. 2014.

Homburg, J. Douglass, and S. Reddy, pp. 85–110. Statistical Research, Inc., Tucson, Arizona. 14 Raab, L. Mark, Judith F. Porcasi, Katherine Bradford, and Andrew Yatsko. 1995. Debating Cultural Evolution:

Regional Implications of Fishing Intensification at Eel Point, San Clemente Island. Pacific Coast Archaeological Society Quarterly 31(3):3–27.

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Late Period (1,000 BP–AD 1542)
The Late Period is associated with the florescence of the Gabrielino, who are estimated to have had a population numbering around 5,000 in the pre-contact period. 15 The Gabrielino occupied what is presently Los Angeles County and northern Orange County, along with the southern Channel Islands, including Santa Catalina, San Nicholas, and San Clemente. 16 This period saw the
development of elaborate trade networks and use of shell-bead currency. Fishing became an increasingly significant part of subsistence strategies at this time, and investment in fishing technologies, including the plank canoe, are reflected in the archaeological record. 17,18
Settlement at this time is believed to have consisted of dispersed family groups that revolved around a relatively limited number of permanent village settlements that were located centrally with respect to a variety of resources.
19 Ethnographic Setting – Indigenous Peoples
The Planning Area is in a region traditionally occupied by Indigenous Peoples. Groups of Indigenous Peoples of Los Angeles include Gabrieleño, Gabrielino, Tongva, and Kizh. "Gabrielino" and "Gabrieleño" are Spanish names deriving from the San Gabriel Mission. "Tongva" was likely a Native village in the same vicinity. The name the Indigenous Peoples may have originally called themselves is “Kizh,” meaning home. 20 However, there is pan-tribal name
for LA's Indigenous Peoples that predates the arrival of Europeans.21 For this report, the term “Gabrielino” will be used, in keeping with the State-recognized name of San Gabriel Band of Mission Indians.

Their neighbors included the Chumash and Tataviam to the north, the Juañeno to the south, and the Serrano and Cahuilla to the east. The Gabrielino are reported to have been second only to the Chumash in terms of population size and regional influence. 22 The Gabrielino language is
part of the Takic branch of the Uto-Aztecan language family.

At the time of Spanish contact, many Gabrielino practiced a religion that was centered around the mythological figure Chinigchinich.
23 This religion may have been relatively new when the
Spanish arrived, and was spreading at that time to other neighboring Takic groups. The

15 The pre-contact period is the time before contact with Europeans, which began around 12,000 years ago and ended prior to AD 1542.
16 Kroeber, A. L. 1925. Handbook of the Indians of California. Dover Publications, Inc., New York, reprinted 1976. 17 Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast. Plenum Press, New York. 18 Raab, L. Mark, Judith F. Porcasi, Katherine Bradford, and Andrew Yatsko. 1995. Debating Cultural Evolution:

Regional Implications of Fishing Intensification at Eel Point, San Clemente Island. Pacific Coast Archaeological Society Quarterly 31(3):3–27.
19 Koerper, H.C., R.D. Mason, and M.L. Peterson. 2002. Complexity, Demography, and Change in Late Holocene Orange County. In Catalysts to Complexity: Late Holocene Societies of the California Coast, edited by J.M. 20 Stickel, Gary E., PhD. 2016. Why the Original Indian Tribe of the Greater Los Angeles Area is Called Kizh not Tongva. Available at: https://www.cpp.edu/~tgyoung/Pom_Parks/Kizh%20not%20Tongva_9-27-17.pdf. 21 Los Angeles Almanac. January 2, 2019. Original Settlers of Los Angeles. Available at:
http://www.laalmanac.com/history/hi03c.php.
22 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 23 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.

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Gabrielino practiced both cremation and inhumation24 of their dead. A wide variety of grave offerings, such as stone tools, baskets, shell beads, projectile points, bone and shell ornaments, and otter skins, were interred with the deceased.

Coming ashore on Santa Catalina Island in October of 1542, Juan Rodriguez Cabrillo was the first European to make contact with the Gabrielino; the 1769 expedition of Portolá also passed through Gabrielino territory.
25 Native Americans suffered severe depopulation, and their traditional culture was radically altered after Spanish contact. Nonetheless, Gabrielino descendants still reside in the greater Los Angeles and Orange County areas and maintain an active interest in their heritage.

A Gabrielino village, or “rancheria,” known as Guaspet, Guasna, Guashna, Guachpet, Guashpet, and Guaspita, appears to have been located southwest of the city. Based on mission baptism records, the rancheria appears to have been occupied from about 1790 to 1820. 26,27 At least
193 people are known to have lived at the rancheria and been baptized. Records suggest that recruitment into the mission system did not occur until native populations in closer proximity to Mission San Gabriel had been assimilated, and after grazing expanded into the vicinity of the Planning Area, bringing native inhabitants of the region into closer contact with Spanish-era ranchers.
28 Two archaeological sites with components dating to the Spanish era (CA-LAN-62 and -211), located within about 2.0 miles from the city, may be the location of Guaspet, although this has not been confirmed in the historical record.
29 Historic Setting
Spanish Period (AD 1542–1821)
Although Spanish explorers made brief visits to the region in 1542 and 1602, sustained contact with Europeans did not commence until the onset of the Spanish Period. In 1769 Gaspar de Portolá led an expedition from San Diego, passing through the Los Angeles Basin and the San Fernando Valley, on its way to the San Francisco Bay.
30 Father Juan Crespi, who accompanied
the 1769 expedition, noted the suitability of the Los Angeles area for supporting a large settlement. This was followed in 1776 by the expedition of Father Francisco Garcés. 31 24 Inhumation is the action of burying the corpse of the dead (as opposed to cremating the remains). 25 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 26 Reedy, Seetha N. 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pg. 48–66. 27 McCawley, William, 1996. The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press, Morongo Indian Reservation.
28 Stoll, Anne Q., John G. Douglass, and Richard Ciolek-Torrello. 2009. Searching for Guaspet: A Mission Period Rancheria in West Los Angeles. SCA Proceedings, Vol. 22. 29 Reedy, Seetha N. 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pp. 48–66. 30 McCawley, William, 1996. The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press, Morongo Indian Reservation.
31 Johnson, J. R., and D. D. Earle. 1990. Tataviam Geography and Ethnohistory. Journal of California and Great Basin Anthropology, Vol. 12, No. 2, pp. 191–214.

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In the late 18th century, the Spanish began establishing missions in California and forcibly relocating and converting native peoples. Mission San Gabriel Arcángel was founded on September 8, 1771, and Mission San Fernando Rey de España on September 8, 1797. By the early 1800s, the majority of the surviving Gabrielino population had entered the mission system, either at San Gabriel or San Fernando. Mission life offered some degree of security in a time when traditional trade and political alliances were failing and epidemics and subsistence instabilities were increasing.
32 This lifestyle change also brought with it significant negative consequences for Gabrielino health and cultural integrity.

On September 4, 1781, El Pueblo de la Reina de los Angeles was established (approximately 5.5 miles northeast of the Planning Area) not far from the site where Portolá and his men camped during their 1769 excursion, with a land grant of 28 acres issued to California Governor Felipe de Neve in 1781.
33 The pueblo was first established in response to the increasing agricultural needs of Spanish missions and presidios in Alta California.34 The original pueblo consisted of a central square surrounded by 12 houses and a series of agricultural fields. Thirty-six fields occupied 250 acres between the town and the river to the east.35
By 1786, the flourishing pueblo attained self-sufficiency, and funding by the Spanish government ceased. Fed by a steady supply of water and an expanding irrigation system, agriculture and ranching grew, and by the early 1800s the pueblo produced surplus wheat, corn, barley, and beans for export. A large number of livestock, including cattle and sheep, grazed in the surrounding lands.
36 Mexican Period (AD 1821–1848)
Mexico gained its independence from Spain in 1821.37 Mexico promoted the settlement of California with the issuance of land grants. In 1833, Mexico began the process of secularizing the missions, reclaiming most mission lands, and redistributing them as land grants. According to the terms of the Secularization Law of 1833 and Regulations of 1834, at least a portion of the lands would be returned to the Native populations, but this did not always occur. 38 32 Jackson, Robert H., Agriculture. 1999. Drought & Chumash Congregation in the California Missions (1782–1834), Articles, California Mission Studies Association Newsletter, 1999. 33 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
34 Alta California encompasses the former Spanish possessions along the Pacific coast and north of the peninsula of Baja California. Originally, early maps of the area showed California as an island. Later, when this mistake was corrected in the 18th century, the peninsula came to be called Baja California and the rest of the mainland, Alta California.
35 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
36 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
37 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
38 Milliken, Randall, Laurence H. Shoup, and Beverly R. Ortiz. 2009. Ohlone/Costanoan Indians of the San Francisco Peninsula and their Neighbors, Yesterday and Today, prepared by Archaeological and Historical Consultants, Oakland, California, prepared for National Park Service Golden Gate National Recreation Area, San Francisco, California, June 2009.

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Many ranchos continued to be used for cattle grazing by settlers during the Mexican Period.

Hides and tallow from cattle became a major export for Californios,39 many of whom became wealthy and prominent members of society. The Californios led generally easy lives, leaving the hard work to vaqueros
40 and Indian laborers.41,42
American Period (AD 1848–Present)
Mexico ceded California to the United States as part of the Treaty of Guadalupe Hidalgo in 1848.

California officially became one of the United States in 1850. While the treaty recognized the right of Mexican citizens to retain ownership of land granted to them by Spanish or Mexican authorities, the claimant was required to prove their right to the land before a patent was given.

The process was lengthy and generally resulted in the claimant losing at least a portion of their land to attorney’s fees and other costs associated with proving ownership. 43 When the discovery of gold in northern California was announced in 1848, a huge influx of people from other parts of North America flooded into California, and the population of Los Angeles tripled between 1850 and 1860. The increased population provided an additional outlet for the Californios’ cattle. As demand increased, the price of beef skyrocketed, and Californios reaped the benefits. However, a devastating flood in 1861, followed by droughts in 1862 and 1864, led to a rapid decline of the cattle industry; over 70 percent of cattle perished during these droughts.
44,45 These natural disasters, coupled with the burden of proving ownership, caused many Californios to lose their lands during this period. Former ranchos were subsequently subdivided and sold for agriculture and residential settlement. 46,47
Los Angeles was connected to the transcontinental railroad via San Francisco on September 5, 1876, and the population again exploded. The city would experience its greatest growth in the 1880s when two more direct rail connections to the East Coast were constructed. The Southern Pacific completed its second transcontinental railway, the Sunset Route from Los Angeles to New Orleans, in 1883.
48 In 1885, the Santa Fe Railroad completed a competing transcontinental railway to San Diego, with connecting service to Los Angeles.49 The resulting fare wars led to an unprecedented real estate boom. Despite a subsequent collapse of the real estate market, the population of Los Angeles increased 350 percent from 1880 to 1890. 50 Los Angeles continued its

39 Spanish speaking, Catholic persons of Latin American descent born in Alta California between 1769 and 1848. 40 Horsemen and cattle herders of Spanish Mexico and Alta California. 41 Pitt, Leonard. 1994. The Decline of the Californios: A Social History of the Spanish-speaking Californians, 1846- 1890. University of California Press, Berkeley.
42 Starr, Kevin. 2007. California: A History. Modern Library, New York. 43 Starr, Kevin. 2007. California: A History. Modern Library, New York. 44 McWilliams, Carey. 1946. Southern California: An Island on the Land. Gibbs Smith, Layton, Utah. 45 Dinkelspiel, Frances. 2008. Towers of Gold, St. Martin’s Press, New York. 46 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
47 McWilliams, Carey. 1946. Southern California: An Island on the Land. Gibbs Smith, Layton, Utah. 48 Orsi, Richard J. 2005. Sunset Limited – the Southern Pacific Railroad and the Development of the American West, 1850 - 1930. University of California Press, Berkeley and Los Angeles, California. 49 Mullaly, Larry and Bruce Petty. 2002. The Southern Pacific Railroad in Los Angeles, 1873 - 1996. Golden West Books, San Marino, California.
50 Dinkelspiel, Frances. 2008. Towers of Gold, St. Martin’s Press, New York.

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upward trajectory in the first few decades of the 20th century with the rise of tourism, automobile travel, and the movie industry.51
Early Settlers and La Ballona Valley
Early families that settled in La Ballona Valley came on different expeditions. Francisco Salvador Lugo, for example, came on Rivera's 1774 trip from Sinaloa, Mexico, and was one of the soldiers present at the founding of the pueblo of Los Angeles in 1781. José Manuel Machado and his wife, Maria, traveled from Sinaloa, Mexico on the Rivera expedition of 1781. Machado continued to serve as a soldier in different locations until he retired to the pueblo of Los Angeles in 1797. Jose Machado's death in 1810 forced the sons to provide for the family's future. Agustín and his brother Ygnacio Machado, after unsuccessful attempts to acquire land near the pueblo, decided to settle in La Ballona Valley and raise cattle on Rancho La Ballona which they established in 1819 with two partners, Felipe Talamantes and his son Tomás.

In 1839, the Machados began to work towards legal ownership of La Ballona. Governor Alvarado granted legal title on the condition that a house was built on the land and was occupied by the grantee and that a survey was done.
52 After Augustín Machado’s death in 1865, Rancho La
Ballona was divided into long strips of land due to the variation in soil type and quality, and to ensure that all new owners had some land that was fertile and irrigable with water from Ballona Creek.
53 Another rancho, Rancho Rincón de los Bueyes, was originally the property of Bernardo Higuera and Cornelio Lopez, and about a third the size of La Ballona. The area occupied by Rincón de los Bueyes, from Ince Boulevard east, included the natural corner created by the Baldwin Hills. The full name of the grant, however, was Corral Viejo del Rincón, and indeed, the corner was used to corral and protect the livestock. Eventually, Bernardo Higuera verbally gave this land to his brothers Policarpio and Mariano Higuera, son Francisco Higuera and Pedro Mendez. That land extended from Ince Boulevard east to La Cienega, north to Airdrome, and south to the Baldwin Hills.
54 Culver City was formed from portions of the 14,000-acre Rancho La Ballona (Machado/Talamantes property) and Rincón de Los Bueyes (Higuera/Lopez property). Rancho La Ballona stretched to Pico Boulevard (abutting Rancho San Vicente y Santa Monica) and to what we know as Ince Boulevard, where Rancho Rincón de los Bueyes began.

Harry Culver and Culver City
Harry H. Culver (1880 - 1946), the founder of Culver City, was born in Milford, Nebraska on January 22, 1880.55 The middle child of five, Culver was raised on a farm along with three

51 McWilliams, Carey. 1946. Southern California: An Island on the Land. Gibbs Smith, Layton, Utah. 52 Cerra, Julie Lugo. 1992. Culver City: The Heart of Screenland. Windsor Publications. 53 Pennington, L. W. and Baxter, W. K. 1976. A Past to Remember: The History of Culver City. 54 Culver City. 2020. History of Culver City – Rancho Rincon de los Bueyes (Higueras) website. Accessed September 1, 2020 at: https://www.culvercity.org/how-do-i/learn/about-culver-city/history-of-culver-city/early-settlers-of- culver-city/rancho-rincon-de-los-bueyes-higueras.
55 Cerra, Julie Lugo. 2013. Culver City Chronicles, Charleston, History Press, p. 35.

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brothers and a sister. His father, Jacob Hazel Culver, was a brigadier general in the National Guard and a strict disciplinarian. Culver followed in his father’s footsteps, enlisting in the military during the Spanish-American War. He studied at Doane College before spending three years at the University of Nebraska. In 1901, Culver traveled to the Philippines, where he began working in the mercantile business, worked as a reporter for the Manila Times, and served as a special agent for the Customs Department. After more than three years in the Philippines, Culver returned to the United States, performing his customs duties in Detroit and Saint Louis.

He resigned from the Customs Department in 1910 when he moved to California and began working for real estate giant I.N. Van Nuys. “As the story goes, after Van Nuys offered to make him a manager because of his exemplary work, Culver decided to venture out on his own. After intense study, Harry Culver pinpointed the area between Los Angeles and Abbot Kinney’s resort of Venice for his city.”
56 At the California Club in 1913, Harry Culver announced his plans to develop a city west of downtown Los Angeles. Culver saw an opportunity to capitalize on the excitement generated by Abbot Kinney’s Venice of America development along the California coast south of Santa Monica. Between Venice and Los Angeles sat open land, originally part of Rancho La Ballona and Rancho Rincón de los Bueyes, and as the relationship between Los Angeles and Venice took shape, Culver saw a spot in between that was ideal for a new town site. “If you draw a line from the Story Building to the Ocean Front at Venice, at the halfway mark you will find three intersecting electric lines— the logical center for what we propose to develop a townsite.” 57 Soon after Culver’s speech, Culver City was established. Culver promoted his new community by holding special events like “prettiest baby contests” and an annual marathon race. Newspaper advertisements exclaimed, “All Roads Lead to Culver City!” Culver City continued to grow and incorporated in 1917.

Cultural Resource Types
Cultural resources can include prehistoric and historic period archaeological sites, structures, districts, and landscapes, or any other physical evidence associated with human activity considered important to a culture, a subculture, or a community for scientific, traditional, religious or any other reason. For purposes of this Section, cultural resources have been categorized into two types: archaeological resources and historic resources. These resource types are further defined in the discussion below.

In general, cultural resources are evaluated for significance by determining whether they are listed in or are eligible for listing in the National Register of Historic Places (NRHP), the California Register of Historical Resources (California Register), or as part of a local register. The City of Culver City’s Historical Preservation Ordinance, enacted in 1991, is administered through the City’s Administrative Services Department, Cultural Affairs Division. The Ordinance outlines a designation process and criteria, as well as procedures for altering or modifying designated cultural resources.

56 Cerra, Julie Lugo. 2013. Culver City Chronicles, Charleston, History Press, p. 35. 57 Cerra, Julie Lugo. 2013. Culver City Chronicles, Charleston, History Press, p. 35.

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Archaeological Resources
Archaeology is the recovery and study of material evidence of human life and culture of past ages. Over time, this material evidence becomes buried, fragmented or scattered or otherwise hidden from view. It is not always evident from a field survey if archaeological resources exist within a given Planning Area. Thus, the possible presence of archaeological materials must often be determined based upon secondary indicators, including the presence of geographic, vegetative, and rock features which are known or thought to be associated with early human life and culture, as well as knowledge of events or material evidence in the surrounding area. In urban areas such as the Planning Area and its environs, archaeological resources may include both prehistoric remains and remains dating to the historic period. • Prehistoric (or Native American) archaeological resources are physical remains resulting from human activities that predate written records and are generally identified as isolated finds or sites. Prehistoric resources can include village sites, temporary camps, lithic (stone tool) scatters, rock art, roasting pits/hearths, milling features, rock features, and burials/human remains. • Historic archaeological resources can include refuse heaps, bottle dumps, ceramic scatters, privies, foundations, and graves, and are generally associated in California with the Spanish Mission Period (AD 1769) to the mid-20th century of the American Period (AD 1848–1970).

Existing Known Archaeological Resources
Results of the archival research indicate that 18 archaeological resources have been previously identified within the city. Of the 18 archaeological resources, six are historic period archaeological resources, 11 are prehistoric archaeological resources, and one is a multicomponent resource. All but three resources have been evaluated for potential eligibility on the federal, state, and/or local level (Table 4.4-1).

Historic Resources
Historic resources include standing structures, buildings, districts, roads, bridges, other infrastructure, objects, and landscapes of historic or aesthetic significance that are generally 45 or 50 years of age or older. Historic resources typically date to the historical period (i.e., AD 1769–1970) and include resources that are evaluated for significance for their architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California.

Existing Known Historic Resources
Results of the archival research indicate that 204 historic resources have been previously identified from a variety of sources within the Planning Area. One of these sources is the Culver City Historic Preservation Advisory Committee Report ("HPAC Report") which, in 1990, ranked over 100 structures (including film studio, commercial and residential properties) for designation as Cultural Resources at either "Landmark," "Significant," or "Recognized" levels. With adjustments in certain designation levels, the City adopted these by Resolution on April 22, 1991. Culver City also has three designated historic districts: 11027–11047 Braddock Drive, 4052–4070 Lafayette Place, and 4128–4181 McConnell Boulevard. Three of Culver City's "Landmark" structures are also

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TABLE 4.4-1

PREVIOUSLY RECORDED ARCHAEOLOGICAL RESOURCES WITHIN THE CITY P-
Number
(P-19-)
Permanent
Trinomial
(CA-LAN-) Description
Date
Recorded Eligibility
000053 000053 Prehistoric archaeological site described as a village or campsite on the bank of La Ballona Creek. Among the artifacts found at the site consist of a double basin metate, a slab metate, metate fragments, a mortar fragment, a discoidal stone, shell fragments, manos, projectile points, and a stone disc
1950 Unknown
000055 000055 Prehistoric archaeological site described as a camp site near Ballona Creek with shell fragments, projectile points, a bone awl, a metate, and some skeletal material
1950 Unknown
000056 000056 Prehistoric archaeological site described as a camp site near Ballona Creek. A mano, scraper, and a thin smoothed oval pebble are among the items found at the site
1950
2013
Unknown
000057 000057 Prehistoric archaeological site described as a village or camp site on the south bank of La Ballona Creek. Shell fragments, projectile points, and large bowls were found at the site
1939
1950
Unknown
000058 000058 Prehistoric archaeological site described as a village or camp site on the north bank of La Ballona Creek. Mortars, complete and broken pestles, metates, manos, a blade, and cog stones were found at the site
1950 Unknown
000067 000067 Prehistoric archaeological site described as a temporary dwelling and located on a small wash. A small amount of shell was found at this site
1950 Unknown
000068 000068 Prehistoric archaeological site described as a seasonal village on the west bank of La Ballona Creek. Amoinf the items found at the site consist of manos, mano fragments, metate fragments, a knife, bone fragments, a “rock chip”, a chert rock, and a piece of gray-green stone
1950 Unknown
002966 002966 Prehistoric archaeological site consisting of groundstone fragments, a mano, shell fragments and fire affected rock
2000 Unknown
002967 002967H Historic-period archaeological site consisting of a trash deposit containing pop bottles, sanitary seam cans, liquor bottles, household utility bottles, cosmetic bottles and jars
2000 Unknown
002968 002968 Prehistoric archaeological site consisting of a lithic scatter 2000 Unknown 003755 003755H Historic-period archaeological site consisting of a moderate density trash scatter containing broken/complete glass beverage and medicine bottles, china fragments, and construction materials 2007 Unknown
004829 004829H Historic-period archaeological site consisting of 13 features that include the remnants of two wells/cisterns, structural remnants, two metal tanks, and eight refuse deposits dating from the 1880s to the 1920s
2017 Not Eligible
for CR
100249 - Prehistoric archaeological isolate consisting of a contracting- stemmed biface made of chalcedony
1998 Unknown
N/A* N/A* Two prehistoric metate artifacts recovered in upper six feet of disturbed fill materials during construction monitoring project. 2019 Not Eligible
for CR
N/A* N/A* Three historic-period isolates consisting of glass bottle containers for liquor and soda recovered in upper 5 feet of disturbed fill materials.

Recovered during construction monitoring project.
2018 Not Eligible
for CR
SOURCES: SCCIC, 2019; ESA, 2022; ESA, 2021 *Resources currently do not have a formal P number or trinomial designation from the

CHRIS-SCCIC

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included in the NRHR. These are the Washington Building (9720–9730 Washington Blvd.), Citizen Building (9355 Culver Blvd.) and Culver Hotel (9400 Culver Blvd.).

The historic resources include a mix of residential buildings (single-family, duplex, and apartment), entertainment studios, commercial buildings (a bathhouse [this is in reference to The Plunge, a community pool], a restaurant, a theater, and hotels), a post office, churches, an airline/railroad segment, a substation, a school, a public utilities building and utilities (utility pole and cell tower), a flood control channel and historic period commercial development along Main Street.

In addition, there are a number of historic resources not included in the CHRIS-SCCIC or local City listings that have been identified through focused surveys and Historic Resources Evaluation Reports for specific plan or other private development projects. In 2014, the City Council designated the former Culver City Ice Arena, located at 4545 Sepulveda Blvd., a Cultural Resource at the "Significant" level because of its association with post-war indoor recreation that catered to youth of the baby boom generation in a developing suburban context and its association with ice skating. As for entertainment industry resources, Sony Pictures Studios and The Culver Studios both have buildings that are individually eligible at the federal, state, and/or local level. For example, individual structures were identified as eligible at The Culver Studios through a survey completed in conjunction with Comprehensive Plan Amendment Nos. 6 and 7.

Tribal Cultural Resources
The NAHC identifies and catalogs Native American cultural resources in SLFs which can include ancient places of special religious or social significance to Native Americans and known ancient graves and cemeteries of Native Americans on private and public lands in California. The records for these resources may not always be available at the CHRIS - SCCIC.

The NAHC SLF results were positive for the identification of a resource in their database and recommended that the city contact the Gabrielino Tongva Indians of California Tribal Council for more information.
58 See Section 4.17, Tribal Cultural Resources, for further information.

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

Federal
National Historic Preservation Act and National Register of Historic Places The National Historic Preservation Act of 1966 established the National Register of Historic Places (National Register) as “an authoritative guide to be used by federal, state, and local governments, private groups and citizens to identify the Nation’s historic resources and to

58 Quinn, S. 2019. Sacred Lands File Search Results and Tribal Consultation List ; Culver City GPU Project, Los Angeles County. Letter on file at the Environmental Science Associates, Irvine, CA.

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indicate what properties should be considered for protection from destruction or impairment.”59 The National Register recognizes a broad range of cultural resources that are significant at the national, state, and local levels and can include districts, buildings, structures, objects, prehistoric archaeological sites, historic-period archaeological sites, traditional cultural properties, and cultural landscapes. Within the National Register, approximately 2,500 (3 percent) of the more than 90,000 districts, buildings, structures, objects, and sites are recognized as National Historic Landmarks or National Historic Landmark Districts as possessing exceptional national significance in American history and culture. 60 Whereas individual historic properties derive their significance from one or more of the criteria discussed in the subsequent section, a historic district “derives its importance from being a unified entity, even though it is often composed of a variety of resources. With a historic district, the historic resource is the district itself. The identity of a district results from the interrelationship of its resources, which can be an arrangement of historically or functionally related properties.”
61 A district is defined as a geographic area of land containing a significant concentration of buildings, sites, structures, or objects united by historic events, architecture, aesthetic, character, and/or physical development. A district’s significance and historic integrity determine its boundaries. Other factors include:
• Visual barriers that mark a change in the historic character of the area or that break the continuity of the district, such as new construction, highways, or development of a different character;
• Visual changes in the character of the area due to different architectural styles, types, or periods, or to a decline in the concentration of contributing resources; • Boundaries at a specific time in history, such as the original city limits or the legally recorded boundaries of a housing subdivision, estate, or ranch; and • Clearly differentiated patterns of historical development, such as commercial versus residential or industrial.
62 Within historic districts, properties are identified as contributing and non-contributing. A contributing building, site, structure, or object adds to the historic associations, historic architectural qualities, or archaeological values for which a district is significant because:
• It was present during the period of significance, relates to the significance of the district, and retains its physical integrity; or
• It independently meets the criterion for listing in the National Register.

59 36 Code of Federal Regulations (CFR) 60.
60 United States Department of the Interior, National Park Service, National Historic Landmarks Frequently Asked Question, 2021.
61 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, p. 5.
62 United States Department of the Interior, National Register Bulletin #21: Defining Boundaries for National Register Properties Form, 1997, p. 12.

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A resource that is listed in or eligible for listing in the National Register is considered “historic property” under Section 106 of the National Historic Preservation Act.

Criteria
To be eligible for listing in the National Register, a resource must be at least 50 years of age, unless it is of exceptional importance as defined in Title 36 of the Code of Federal Regulations (CFR), Part 60, Section 60.4(g). In addition, a resource must be significant in American history, architecture, archaeology, engineering, or culture. The following four criteria for evaluation have been established to determine the significance of a resource:

A. Are associated with events that have made a significant contribution to the broad patterns of our history;
B. Are associated with the lives of persons significant in our past; C. Embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction; or D. Have yielded, or may be likely to yield, information important in prehistory or history. 63 Context
To be eligible for listing in the National Register, a property must be significant within a historic context. National Register Bulletin #15 states that the significance of a historic property can be judged only when it is evaluated within its historic context. Historic contexts are “those patterns, themes, or trends in history by which a specific property or site is understood and its meaning is made clear.”
64 A property must represent an important aspect of the area’s history or prehistory and possess the requisite integrity to qualify for the National Register.

Integrity
In addition to meeting one or more of the criteria of significance, a property must have integrity, which is defined as “the ability of a property to convey its significance.” 65 The National Register
recognizes seven qualities that, in various combinations, define integrity. The seven factors that define integrity are location, design, setting, materials, workmanship, feeling, and association.

To retain historic integrity a property must possess several, and usually most, of these seven aspects. Thus, the retention of the specific aspects of integrity is paramount for a property to convey its significance. In general, the National Register has a higher integrity threshold than State or local registers.

In the case of districts, integrity means the physical integrity of the buildings, structures, or features that make up the district as well as the historic, spatial, and visual relationships of the

63 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, p. 8.
64 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, pp. 7 and 8.
65 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, p. 44.

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components. Some buildings or features may be more altered over time than others. In order to possess integrity, a district must, on balance, still communicate its historic identity in the form of its character defining features.

Criteria Considerations
Certain types of properties, including religious properties, moved properties, birthplaces or graves, cemeteries, reconstructed properties, commemorative properties, and properties that have achieved significance within the past 50 years are not considered eligible for the National Register unless they meet one of the seven categories of Criteria Considerations A through G, in addition to meeting at least one of the four significance criteria discussed above, and possess integrity as defined above.
66 Criteria Consideration G is intended to prevent the listing of properties for which insufficient time may have passed to allow the proper evaluation of their historical importance.
67 The full list of Criteria Considerations is provided below:

A. A religious property deriving primary significance from architectural or artistic distinction or historical importance; or
B. A building or structure removed from its original location but which is significant primarily for architectural value, or which is the surviving structure most importantly associated with a historic person or event; or
C. A birthplace or grave of a historical figure of outstanding importance, if there is no other appropriate site or building directly associated with his or her productive life; or D. A cemetery which derives its primary significance from graves of persons of transcendent importance, from age, from distinctive design features, or from association with historic events; or
E. A reconstructed building when accurately executed in a suitable environment and presented in a dignified manner as part of a restoration master plan, and when no other building or structure with the same association has survived; or
F. A property primarily commemorative in intent if design, age, tradition, or symbolic value has invested it with its own historical significance; or
G. A property achieving significance within the past 50 years, if it is of exceptional importance.

Secretary of Interior’s Standards for the Treatment of Historic Properties The National Park Service issued the Secretary’s Standards with accompanying guidelines for four types of treatments for historic resources: Preservation, Rehabilitation, Restoration, and Reconstruction. The most applicable guidelines should be used when evaluating a project for compliance with the Secretary’s Standards. Although none of the four treatments, as a whole, apply specifically to new construction in the vicinity of historic resources, Standards #9 and #10

66 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, p. 25.
67 United States Department of the Interior, National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation, 1997, p. 41.

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of the Secretary’s Standards provides relevant guidance for such projects. The Standards for Rehabilitation are as follows:

1. A property will be used as it was historically or be given a new use that requires minimal change to its distinctive materials, features, spaces and spatial relationships.

2. The historic character of a property will be retained and preserved. The removal of distinctive materials or alteration of features, spaces, and spatial relationships that characterize a property will be avoided.

3. Each property will be recognized as a physical record of its time, place and use. Changes that create a false sense of historical development, such as adding conjectural features or elements from other historic properties, will not be undertaken.

4. Changes to a property that have acquired significance in their own right will be retained and preserved.

5. Distinctive materials, features, finishes and construction techniques or examples of craftsmanship that characterize a property will be preserved.

6. Deteriorated historic features will be repaired rather than replaced. Where the severity of deterioration requires replacement of a distinctive feature, the new feature shall match the old in design, color, texture, and where possible, materials. Replacement of missing features will be substantiated by documentary and physical evidence.

7. Chemical or physical treatments, if appropriate, will be undertaken using the gentlest means possible. Treatments that cause damage to historic materials will not be used.

8. Archeological resources will be protected and preserved in place. If such resources must be disturbed, mitigation measures will be undertaken.

9. New additions, exterior alterations, or related new construction will not destroy historic materials, features, and spatial relationships that characterize the property. The new work shall be differentiated from the old and will be compatible with the historic materials, features, size, scale and proportion, and massing to protect the integrity of the property and its environment.

10. New additions and adjacent or related new construction will be undertaken in such a manner that if removed in the future, the essential form and integrity of the historic property and its environment would be unimpaired.
68 It is important to note that the Secretary’s Standards are not intended to be prescriptive but, instead, provide general guidance. They are intended to be flexible and adaptable to specific project conditions to balance continuity and change, while retaining materials and features to the maximum extent feasible. Their interpretation requires exercising professional judgment and balancing the various opportunities and constraints of any given project. Not every Standard necessarily applies to every aspect of a project, and it is not necessary for a project to comply with every Standard to achieve compliance.

68 United States Department of the Interior, National Park Service, the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings, 2017.

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State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) is the principal statute governing environmental review of projects occurring in the State and is codified in Public Resources Code (PRC) Section 21000 et seq. CEQA requires lead agencies to determine if a proposed project would have a significant effect on the environment, including significant effects on historical or unique archaeological resources. Under CEQA Section 21084.1, a project that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment.

CEQA Guidelines Section 15064.5 recognizes that historical resources include: (1) resources listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register; (2) resources included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); and (3) any objects, buildings, structures, sites, areas, places, records, or manuscripts which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California by the lead agency, provided the lead agency’s determination is supported by substantial evidence in light of the whole record.

If a lead agency determines that an archaeological site is a historical resource, the provisions of PRC Section 21084.1 and CEQA Guidelines Section 15064.5 apply. If an archaeological site does not meet the criteria for a historical resource contained in the CEQA Guidelines, then the site may be treated in accordance with the provisions of PRC Section 21083, if it meets the criteria of a unique archaeological resource. As defined in PRC Section 21083.2, a unique archaeological resource is an archaeological artifact, object, or site, about which it can be clearly demonstrated that without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
• Contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information;
• Has a special and particular quality such as being the oldest of its type or the best available example of its type; or
• Is directly associated with a scientifically recognized important prehistoric or historic event or person.

If an archaeological site meets the criteria for a unique archaeological resource as defined in PRC Section 21083.2, then the site is to be treated in accordance with the provisions of PRC Section 21083.2, which state that if the lead agency determines that a project would have a significant effect on unique archaeological resources, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place. 69 If

69 California Public Resources Code Section 21083.1(a).

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preservation in place is not feasible, mitigation measures shall be required. The CEQA Guidelines note that if an archaeological resource is neither a unique archaeological nor a historical resource, the effects of the project on those resources shall not be considered a significant effect on the environment.
70 A significant effect under CEQA would occur if a project results in a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5(a).

Substantial adverse change is defined as “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired.”
71 According to CEQA Guidelines Section 15064.5(b)(2),
the significance of a historical resource is materially impaired when a project demolishes or materially alters in an adverse manner those physical characteristics that:

A. Convey its historical significance and that justify its inclusion in, or eligibility for, inclusion in the California Register; or
B. Account for its inclusion in a local register of historical resources pursuant to PRC Section 5020.1(k) or its identification in a historical resources survey meeting the requirements of PRC Section 5024.1(g) Code, unless the public agency reviewing the effects of the project establishes by a preponderance of evidence that the resource is not historically or culturally significant; or
C. Convey its historical significance and that justify its eligibility for inclusion in the California Register as determined by a Lead Agency for purposes of CEQA.

In general, a project that complies with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings is considered to have impacts that are less than significant. 72 California Register of Historical Resources
The California Register is “an authoritative listing and guide to be used by State and local agencies, private groups, and citizens in identifying the existing historical resources of the State and to indicate which resources deserve to be protected, to the extent prudent and feasible, from substantial adverse change.”
73 The California Register was enacted in 1992, and its regulations became official on January 1, 1998. The California Register is administered by the California Office of Historic Preservation (OHP). The criteria for eligibility for the California Register are based upon National Register criteria.
74 Certain resources are determined to be
automatically included in the California Register, including California properties formally determined eligible for, or listed in, the National Register. To be eligible for the California

70 CEQA Guidelines, Section 15064.5(c)(4).
71 CEQA Guidelines, Section 15064.5(b)(1).
72 CEQA Guidelines, Section15064.5(b)(3).
73 California Public Resources Code, Section 5024.1[a]. 74 California Public Resources Code, Section 5024.1[b].

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Register, a prehistoric or historic-period property must be significant at the local, state, and/or federal level under one or more of the following four criteria:

1. Is associated with events that have made a significant contribution to the broad patterns of California’s history and cultural heritage;

2. Is associated with the lives of persons important in our past;

3. Embodies the distinctive characteristics of a type, period, region, or method of construction, or represents the work of an important creative individual, or possesses high artistic values; or

4. Has yielded, or may be likely to yield, information important in prehistory or history.

A resource eligible for the California Register must meet one of the criteria of significance described above, and retain enough of its historic character or appearance (integrity) to be recognizable as a historical resource and to convey the reason for its significance. It is possible that a historic resource may not retain sufficient integrity to meet the criteria for listing in the National Register, but it may still be eligible for listing in the California Register.

Additionally, the California Register consists of resources that are listed automatically and those that must be nominated through an application and public hearing process. The California Register automatically includes the following:
• California properties listed on the National Register and those formally determined eligible for the National Register;
• California Registered Historical Landmarks from No. 770 onward; and, • Those California Points of Historical Interest that have been evaluated by the State Office of Historic Preservation (OHP) and have been recommended to the State Historical Resources Commission for inclusion on the California Register.

Other resources that may be nominated to the California Register include:
• Historical resources with a significance rating of Category 3 through 5 (those properties identified as eligible for listing in the National Register, the California Register, and/or a local jurisdiction register);
• Individual historical resources;
• Historic districts; and,
• Historical resources designated or listed as local landmarks, or designated under any local ordinance, such as an historic preservation overlay zone.

California Government Code Sections 6254(r) and 6254.10 These sections of the California Public Records Act were enacted to protect archaeological sites from unauthorized excavation, looting, or vandalism. Section 6254(r) explicitly authorizes public agencies to withhold information from the public relating to “Native American graves, cemeteries, and sacred places maintained by the Native American Heritage Commission.” Section 6254.10 specifically exempts from disclosure requests for “records that relate to archaeological site information and reports, maintained by, or in the possession of the

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Department of Parks and Recreation, the State Historical Resources Commission, the State Lands Commission, the NAHC, another state agency, or a local agency, including the records that the agency obtains through a consultation process between a Native American tribe and a state or local agency.”
Regional
Los Angeles County Historic Preservation Ordinance
The Los Angeles County Board of Supervisors adopted the County’s Historic Preservation Ordinance (HPO) on September 1, 2015. The HPO establishes criteria for designating landmarks and historic districts and provides protective measures for designated and eligible historic resources. The HPO applies to all privately owned property within the unincorporated territory of the County and all publicly owned landmarks, except properties that were not listed prior to the issuance of a demolition permit or properties affiliated with religious organizations. The HPO defines a landmark as “any property, including any structure, site, place, object, tree, landscape, or natural feature, that is designated as a landmark by the Board of Supervisors.” The HPO defines a historic district as, “A contiguous or noncontiguous geographic area containing one or more contributing properties which has been designated as an historic district by the Board of Supervisors.” Landmarks and historic districts may be designated if it is 50 years of age and meets one of the following criteria:

1. It is associated with events that have made a significant contribution to the broad patterns of the history of the nation, state, county, or community in which it is located;

2. It is associated with the lives of persons who are significant in the history of the nation, state, county, or community in which it is located;

3. It embodies the distinctive characteristics of a type, architectural style, period, or method of construction, or represents the work of an architect, designer, engineer, or builder whose work is of significance to the nation, state, county, or community in which it is located; or possesses artistic values of significance to the nation, state, county, or community in which it is located;

4. It has yielded, or may be likely to yield, significant and important information regarding the prehistory or history of the nation, state, county, or community in which it is located;

5. It is listed, or has been formally determined eligible by the United States National Park Service for listing, in the National Register of Historic Places, or is listed, or has been formally determined eligible by the State Historical Resources Commission for listing, on the California Register of Historical Resources;

6. If it is a tree, it is one of the largest or oldest trees of the species located in the county; or

7. If it is a tree, landscape, or other natural land feature, it has historical significance due to an association with an historic event, person, site, street, or structure, or because it is a defining or significant outstanding feature of a neighborhood.

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Historic Districts
Property less than 50 years of age may be designated as a landmark if it meets one or more of the criteria and exhibits exceptional importance.

A geographic area, including a noncontiguous grouping of related properties, may be designated as an historic district if all of the following requirements are met:

1. More than 50 percent of owners in the proposed district consent to the designation;

2. The proposed district satisfies one or more of criteria 1 through 5; and

3. The proposed district exhibits either a concentration of historic, scenic, or sites containing common character-defining features, which contribute to each other and are unified aesthetically by plan, physical development, or architectural quality; or significant geographical patterns, associated with different eras of settlement and growth, particular transportation modes, or distinctive examples of parks or community planning.

County of Los Angeles General Plan
The Conservation and Natural Resources Element of the County’s General Plan (applicable to the SOI of the Planning Area) indicates that “Historic, cultural, and paleontological resources are an important part of Los Angeles County’s identity.” This element provides the following goal and policies for the treatment of cultural resources:

Goal C/NR 14: Protected historic, cultural, and paleontological resources.

Policy C/NR 14.1: Mitigate all impacts from new development on or adjacent to historic, cultural, and paleontological resources to the greatest extent feasible.

Policy C/NR 14.2: Support an inter-jurisdictional collaborative system that protects and enhances historic, cultural, and paleontological resources.

Policy C/NR 14.3: Support the preservation and rehabilitation of historic buildings.

Policy C/NR 14.5: Promote public awareness of historic, cultural, and paleontological resources.

Policy C/NR 14.6: Ensure proper notification and recovery processes are carried out for development on or near historic, cultural, and paleontological resources.

Local
Culver City Historic Preservation Ordinance
The City enacted a Historic Preservation Ordinance in 1991 which defines Cultural Resources.

The Historic Preservation Ordinance (Chapter 15.05 of the City’s Municipal Code [CCMC]) is administered through the City’s Community Development Department by Cultural Affairs. 75 The
Ordinance outlines a designation process, criteria, and procedures for altering or modifying designated Cultural Resources. Pursuant to the City’s Ordinance, a Cultural Resource is a

75 City of Culver City, Culver City Municipal Code, Chapter 15.05 Historic Preservation Program.

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property that has aesthetic, cultural, architectural or historical significance to the city, state, or nation, and may have been designated as a Landmark Structure, Significant Structure, or Recognized Structure. After satisfying at least one of the threshold criteria, classification is based on a ranking system, currently outlined in Resolution No. 91-R015.

A Landmark Structure is defined as a structure designated as an exceptional example of the highest architectural, historical, or cultural significance of the community. A Landmark structure or district may be designated without owner consent.

A Significant Structure is defined as a structure designated as being of substantial architectural, historical, or cultural significance to the community. If residential, a “Significant” structure or district shall be designated with written consent of the owner, provided that the consent of only a majority of the owners shall be required for a “Significant District” designation. Once the designation has been made and the designation document has been filed for recondition, owner consent is irrevocable. If the owner consent is not obtained, a residential structure or district may be designated “Recognized.” If nonresidential, a structure may be designated without owner consent.

All structures with "Landmark" or "Significant" designations are required to display a plaque identifying that building or district as either "Landmark" or "Significant.” A Recognized Structure is defined as a structure designated as being of architectural, historical, or cultural interest. A structure or district may be designated as “Recognized” without the consent of the owner. No other requirements apply to Recognized structures.

The Ordinance also identifies historic districts as falling into one of three different types: a “Landmark District,” a “Significant District,” or a “Recognized District,” with similar criteria for designation for each one. A historic district is described as a designated area consisting of one (1) or more contiguous parcels improved with structures at which events occurred that made a significant contribution to the city, state, or national history or culture, or an area that contains structures that are collectively significant examples of period, style, or method of construction that provide distinguishing characteristics of the architectural type or period represented.

In Section 15.02.020 of the CCMC, the Culver City Historic Preservation Ordinance establishes criteria for designating local historical resources and districts as Cultural Resources. To be considered for designation, a structure must be at least fifty (50) years old and the exterior of the structure is accessible or visible to the public, or the structure or district has special importance to the City.

A. Threshold criteria. To be considered for designation, the structure(s) must meet one of the following criteria:

1. The structure(s) is at least fifty (50) years old and the exterior of the structure is accessible or visible to the public; or

2. The structure or district has special importance to the City.

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B. Assessment criteria. After satisfying the threshold criteria, a structure or district shall be reviewed for compliance with one or more of the following criteria, as defined under CCMC Section 15.05.010 of this Chapter:

1. Is the structure(s) of “architectural significance”?

2. Is the structure(s) of “historical or cultural significance”?

3. Do the structures in the district collectively meet 1. or 2. above?

4.4.4 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 cultural resources if the project would:

Threshold CUL-1: Cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5.

Threshold CUL-2: Cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5.

Threshold CUL-3: Disturb any human remains, including those interred outside of formal cemeteries.

The Initial Study (Appendix A of this Draft PEIR) found no potentially significant impacts related to disturbance of human remains (Threshold CUL-3); therefore, this issue is not evaluated in this section. Please see Appendix A for further discussion.

Methodology
A project with an effect that may cause a substantial adverse change in the significance of a historical resource is a project that may have a significant effect on the environment. In general, a significant effect under CEQA would occur if a project results in a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5(a).

Substantial adverse change is defined as “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired” (CEQA Guidelines Section 15064.5(b)(1)). In addition, while assessing a project’s impacts under CEQA, it is important to consider the ability of the historical resources to retain their integrity. A project that diminishes the integrity of a resource such that the significance of a historical resource is materially impaired is a project that would result in a significant impact on the environment.

The following analysis of the Project’s potential to impact existing resources within the city is based on existing information derived from the following sources: (1) a cultural resources records search through the California Historic Resources Inventory System (CHRIS) - South Central Coastal Information Center (SCCIC); (2) a Sacred Lands File (SLF) search through the

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California Native American Heritage Commission (NAHC); and (3) recent cultural resource discoveries encountered at construction monitoring projects within the city. In addition, the City’s Cultural Affairs Division maintains information on locally identified historic resources such as Council-designated resources, historic resources identified as significant based on historic resources surveys, and resources identified as historic as part of CEQA documentation for a plan or project. Programmatic impacts are discussed in broad, qualitative terms. If necessary, a project-level CEQA analysis would be conducted for future discretionary development projects.

Projects implemented under the proposed General Plan Update and Zoning Code Update would be regulated by the various laws, regulations, and policies summarized in Section 4.4.3, Regulatory Framework. Compliance with applicable federal, state, and local laws and regulations is assumed in this analysis and local and State agencies would be expected to continue to enforce applicable requirements to the extent that they do so now.

Project Impact Analysis
Adversely Affect Significance of a Historical Resource
Threshold CUL-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would cause a substantial adverse change in the significance of a historical resource pursuant to §15064.5.

Impact Statement 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.

General Plan Update
Future development facilitated under the General Plan Update may include construction, demolition, or alteration of historic buildings/structures/objects/landscape features (hereafter referred to as “historic resources” or “historic properties”) that have the potential to cause a substantial adverse change to historical resources as defined by CEQA Guidelines Section 15064.5. New development and redevelopment facilitated under the General Plan Update could result in a substantial adverse change in the significance of a historical resource through physical demolition, destruction, relocation, or alteration of the resource. New construction through infill development on vacant property could also result in a substantial adverse change in the significance of a historical resource through alteration of the resource’s immediate surroundings. The CEQA Guidelines note that generally, a project that follows the Secretary of the Interior’s Standards for the Treatment of Historic Properties is considered as mitigated to a level of less-than-significant impact on the historical resource. Projects that propose alteration of a historical resource and that do not adhere to these standards have the potential to result in a substantial adverse change in the significance of a historical resource. Other projects that propose demolition or alteration of, or construction adjacent to, existing historic resources over 45 years in age (the California Office of Historic Preservation’s age threshold for consideration as

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historical resources), could also result in a substantial adverse change in the significance of a historical resource. Changes in the setting of historic buildings and structures can result from the introduction of new visible features, significant landscape changes, or other alterations that change the historic integrity of the setting of a significant resource.

The results of the archival research conducted for the General Plan Update Existing Conditions Background Report and summarized in Subsection 4.4.2 above, indicate that a total of 204 historic resources have been previously identified within the Planning Area. Culver City also has three designated historic districts: 11027 - 11047 Braddock Drive, 4052 - 4070 Lafayette Place, and 4128 - 4181 McConnell Boulevard. Three of Culver City's "Landmark" structures are also included in the NRHR. These are the Washington Building (9720-9730 Washington Blvd.), Citizen Building (9355 Culver Blvd.) and Culver Hotel (9400 Culver Blvd.). The historic resources include a mix of residential buildings (single-family, duplex, and apartment), entertainment studios, commercial buildings (a bathhouse [this is in reference to The Plunge, a community pool], a restaurant, a theater, and hotels), a post office, churches, an airline/railroad segment, a substation, a school, a public utilities building and utilities (utility pole and cell tower), a flood control channel and historic period commercial development along Main Street. In addition, there are a number of historic resources not included in the CHRIS System or local City listings that have been identified through focused surveys and Historic Resources Evaluation Reports for specific plan or other private development projects.

Any property that is or becomes of historic age may be a potential historical resource. A review of historic aerials indicates that there are numerous properties within the city that are more than 45 years in age. Any project that proposes the demolition, destruction, relocation, or alteration of property more than 45 years in age could result in a significant impact on historical resources.

The General Plan goal and policies listed below would help to promote the preservation of historic resources, cataloguing historic materials for public access, applying the Secretary of Interior’s Standards and other regulatory codes to qualified historic properties, and expanding the City’s Historic Preservation Program available on the City’ website. While Policy C-1.19 would require the provision of technical information that will help property owners in planning new additions that are complimentary to the existing historic structures and conform with the Secretary of Interior’s Standards, these policies do not require the identification and evaluation of historic-age properties to determine if there are historical resources within or nearby a proposed project site that could be adversely impacted by a proposed project, nor do they require the retention or rehabilitation of historical resources. Therefore, future development implemented as a result of the General Plan Update could result in a potentially significant impact related to historical resources during construction.

Mitigation is required to ensure that historical resources are properly identified and that impacts on any identified historical resources are reduced. However, impacts on historical resources that are demolished or substantially altered in an adverse manner such that they are no longer able to convey their historical significance and such that they are no longer eligible for inclusion in the California Register or no longer eligible for designation as Culver City Cultural

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Resources at either "Landmark," "Significant," or "Recognized" levels typically cannot be mitigated to a level of less than significant.76,77
Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan within the city. The Zoning Code Update would result in some increases in allowable building heights in limited areas throughout the city including properties over 45-years in age in the Hayden Tract along Jefferson Boulevard that would be designated Mixed Use Industrial and Mixed Use Corridor 2 and 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. New construction under the Zoning Code Update could result in adverse indirect impacts to historical resources resulting from substantial changes in scale within the surrounding proximity of historic properties and landscapes that may cause adverse physical or visual changes to the historic setting or views of the historical resources. Thus, for historic properties over 45 years in age, future development under the Zoning Code Update would be required to comply with all applicable requirements of the Zoning Ordinance, as well as applicable mitigation measures such as MM-CUL-1, to avoid damage and promote preservation of historic resources. While potentially significant impacts to historic resources from some future development would be reduced to a less-than-significant level with mitigation incorporated, significant impacts could still occur. Therefore, even with implementation of Mitigation Measure MM CUL-1, impacts would be significant and unavoidable.

Applicable Proposed General Plan Goals and Policies
Conservation Element
Goal C-1: Cultural Resources. Culver City’s cultural resources are protected and enhanced through proactive measures.

76 CEQA Guidelines Section 15126.4(b)(2) states that in some circumstances, documentation of an historical resource, by the way of narrative, photographs or architectural drawings, as mitigation for the effects of demolition of the resource will not mitigate the effects to the point where clearly no significant effect on the environment would occur.
77 In League of Protection of Oakland’s Architectural and Historic Resources v. City of Oakland (1997) the appellate court found that “Documentation of the historical features of the building and exhibition of a plaque do not reasonably begin to alleviate the impacts of its destruction. A large historical structure, once demolished, normally cannot be adequately replaced by reports and commemorative markers. Nor, we think, are the effects of the demolition reduced to a level of insignificance by a proposed new building with unspecified design elements which may incorporate features of the original architecture into an entirely different shopping center.

This is so particularly where, as here, the plans for the substitute building remain tentative and vague. We conclude that the stated mitigation measures do not reduce the effects of the demolition to less than a level of significance.”

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4.4. Cultural Resources
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C-1.1: Cultural resource catalog. Maintain a catalog of cultural resources within the City.

C-1.2: Cultural and historic resource inventory. Continue to inventory at regular intervals cultural and historical resources, including buildings, structures, districts, objects, and sites.

C-1.3: Historic resources in databases. Continue to work with Building and Planning Divisions and with the County Recorder’s Office to ensure all historical resources are flagged in relevant databases.

C-1.4: Historic materials cataloging. Encourage that historic materials are cataloged and available for public access.

C-1.5: Building plaques. Continue to work with the Cultural Affairs Division to ensure plaques are positioned on newly designed cultural resources.

C-1.6: Historic sign ordinance. Continue implementation of the historic sign ordinance.

C-1.7: Cultural resources funding. Identify and acquire funding to preserve cultural resources.

C-1.8: Incentives for developers. Promote the use of incentives for developers to maintain, restore, and rebuild, or rehabilitate historic structures within commercial and residential areas.

C-1.9: Cultural resource preservation. Preserve the city’s cultural resources.

C-1.10: Maintain and preserve historic structures and artifacts. Encourage maintenance and preservation of historic structures and artifacts and develop disincentives to demolish historic buildings or destroy artifacts.

C-1.11: Preservation in the planning and development review process. Coordinate with the Cultural Affairs Division to integrate preservation into the planning and development review process to ensure that cultural heritage concerns are identified at an early stage and addressed, as warranted, throughout the process. Encourage ordinances and policies that contribute to preservation goals and amended codes, where necessary, to reflect preservation goals.

C-1.12: Historic standards and building codes. Apply the Secretary of the Interior’s Standards and/or the alternative building codes, such as the Uniform Code for Building Conservation (UCBC) and/or the State Historic Building Code, to qualified historic properties.

C-1.13: Demolition of historic structures. Expand existing laws and regulations as necessary to prevent demolition of historically significant structures by neglect.

C-1.14: Historic property protection in natural disasters. Comply with California Public Resources Code Section 5028 (Natural Disaster Damage to Historic Property).

C-1.15: Public knowledge promotion. Promote public knowledge and understanding of cultural resources (including archaeological, tribal cultural resources, historic resources, and paleontological resources) present within the City.

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C-1.17: Educational institution cooperation. Cooperate with the educational institutions and other interested parties to build awareness of the legacy of the city’s past and the necessity of its retention.

C-1.18: Historical Preservation Program awareness. Continue to expand information on the Historical Preservation Program available via the City’s website.

C-1.19: Historic resource information for property owners. Provide technical information that will help property owners in planning new additions that are complementary to the existing historic structures and conform with the Secretary of the Interior’s Standards.

C-1.20: Document and resource sharing. Solicit residents to share or donate historic documents relating to Culver City to the historical society archives or other appropriate institutional oral history program.

Mitigation Measures
In order to ensure that historical resources are properly identified and that impacts on any identified historical resources are reduced, MM CUL-1 is required. This would require research and survey by a qualified architectural historian, evaluation of properties for listing in the National Register, California Register or as a Culver City Cultural Resource, and assessment of project-specific impacts under CEQA thresholds.

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.

Level of Significance after Mitigation
It is impossible to know if future development implemented under the Project would avoid substantial adverse impacts on historical resources without information on specific future projects. As a result, 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

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through the 2045 planning horizon. Implementation of Mitigation Measure MM CUL-1 stated above would help to reduce the severity of the impacts. However, even with implementation of Mitigation Measure MM CUL-1, impacts would not be substantially reduced and impacts would remain significant and unavoidable.

Adversely Affect Significance of an Archaeological Resource Threshold CUL-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would cause a substantial adverse change in the significance of an archaeological resource pursuant to §15064.5?
Impact Statement 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.

General Plan Update
As discussed in this Section, the archival research indicates that 18 known archaeological resources have been previously identified within the city, of which six are historic period archaeological resources, 11 are prehistoric archaeological resources, and one is a multicomponent resource. The NAHC has indicated that the SLF results were positive and identified one resource in their database. The NAHC recommended that the city contact the Gabrielino Tongva Indians of California Tribal Council for more information on this particular resource. See Section 4.17, Tribal Cultural Resources, for further information.

The current contents and condition of these resources are unknown as some of these resources were recorded as early as 1950 (and as late as 2019) and therefore it is likely that at least some of the resources have been partially or completely displaced or destroyed by modern development or some other cultural (e.g., looting, road construction) or natural (e.g., erosion, flood events) process. In addition, the exact boundaries of these resources and their horizontal (across the surface) and vertical (below the surface) extent may either be unknown or inconclusive for the same reason and/or if no subsurface archaeological investigations have taken place at the resource. Moreover, it is possible that additional archaeological resources are present within the city that have yet to be discovered and would need to be evaluated for eligibility for listing in the National Register, California Register or as a Culver City Cultural Resource, and for an assessment of project-specific impacts under CEQA thresholds.

Furthermore, some existing improvements within the city (e.g., roads, buildings, structures, etc.) were likely constructed prior to the existence of cultural resources protection laws and may have been built on archaeological resources; therefore, the current or prior existence of development throughout the city does not preclude the presence of archaeological resources located underneath this development. As mentioned in Table 4.4-1 above, several archaeological resources have been identified within the city at depth during archaeological

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monitoring of construction project sites that have undergone extensive development over the years.

Lastly, the city would have been a highly suitable area for the inhabitance of indigenous people.

For instance, Ballona Creek, an 8.8-mile watershed that flows through the city, would have provided native inhabitants with abundant food resources in the past, such as plants and animals, and fresh water. As a result of these findings, the potential for encountering archaeological resources in the city is considered high.

Future development that does not require ground-disturbing activities would cause no impacts on archaeological resources. However, future development initiated under the proposed General Plan Update that includes construction-related ground disturbance (e.g., demolition, grubbing/clearing, grading, excavation, trenching, and boring/drilling) are activities that have potential to impact, or cause a substantial adverse change to, archaeological resources.

Anticipated development in the city would occur through activities such as infill development on vacant property and through redevelopment, which could result in damage to prehistoric and historic archaeological resources. In addition, infrastructure improvements and other activities requiring ground disturbance could result in damage to or destruction of archaeological resources buried below the ground surface.

The General Plan Update Conservation Element includes several policies related to the cataloguing and maintaining an inventory of cultural resources within the city. Policy C-1.21 includes the promotion of programs and policies to protect known archaeological and paleontological sites and Tribal Cultural Resources. The city has also identified standard conditions of approval that would require and specify steps to be taken to avoid damage and promote preservation if unknown archaeological resources were to be uncovered during construction. Therefore, impacts to archaeological resources are considered potentially significant and MM CUL-2 and applicable policies in the General Plan Update would serve to reduce the impact to a less-than-significant level.

Projects that identify significant archaeological resources (i.e., those resources that qualify as historical resources or unique archaeological resources pursuant to CEQA Guidelines Section 15064.5 and Public Resources Code Section 21083.2, respectively) and preserve them through avoidance, permanent conservation easements, capping, or incorporation into open space, would reduce impacts on archaeological resources to a level that is less than significant. If preservation in place is not feasible, projects that conduct data recovery programs to recover the scientifically consequential information contained in the archaeological resource would also reduce impacts to less than significant. Finally, mitigation is required to ensure that significant archaeological resources are properly identified and that the impact on any identified significant resources is reduced.

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General Plan 2045 and Zoning Code Update Project 4.4-30 SCH No. 2022030144 City of Culver City March 2024
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comply with all applicable requirements of the Zoning Ordinance, applicable mitigation measures such as MM-CUL-2, and implementing standard conditions of approval to avoid damage and promote preservation of archaeological resources. Therefore, potentially significant impacts to archaeological resources from some future Projects would be reduced to a less-than- significant level with mitigation incorporated.

Applicable Proposed General Plan Goals and Policies
In addition to Goal C-1 and relevant policies above, the following Conservation Element policy addresses archaeological resources.

C-1.21: Protect Archeological, Paleontological, and Tribal Cultural Resources. Promote programs and policies to protect known archeological and paleontological sites and Tribal Cultural Resources.

Mitigation Measures
In order to ensure that ensure that significant archaeological resources are properly identified and that the impact on any identified significant resources is reduced, MM CUL-2 is required.

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.

Level of Significance after Mitigation
With implementation of the mitigation measure described above, potential significant impacts related to archaeological resources would be reduced to a less-than-significant level.

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4.4.5 Cumulative Impacts Analysis
The cumulative analysis for impacts on cultural resources considers a broad regional system of which the resources are a part. The geographic context for the analysis of cumulative impacts associated with cultural resources is the Planning Area and the larger Los Angeles County region, where common patterns of prehistoric and historic development have occurred.

Historic Resources
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. There are 204 historic resources that have been previously identified, three designated historic districts, and three Culver City “Landmark” structures are included in the NRHR. However, the city has not been subject to a comprehensive citywide historic resources survey and all historic-age structures are potential historical resources. Therefore, there is the possibility growth anticipated under the proposed General Plan Update could adversely affect historical resources. The city cannot be sure that all impacts on historical resources can be mitigated to less-than-significant levels. 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.

Archaeological Resources
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 archaeological resources, thus resulting in a potentially significant cumulative impact. There are 18 known archaeological resources that have been previously identified within the city. Additional unrecorded archaeological resources may also exist. Future development projects that may result from implementation of the Project may involve grading, excavation, or other ground- disturbing activities, which could disturb or damage unknown archaeological resources.

Consequently, the Project may have the potential to contribute to cumulative impacts on archaeological resources. However, with implementation of MM-CUL-2, the Project’s contribution to this potentially significant cumulative impact would not be cumulatively considerable.

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Preliminary − Subject to Revision

4.5 Energy

4.5.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on energy from implementation of the Project, including potential impacts related to consumption of energy resources and conflict with State or local renewable energy plans. The section provides context regarding the Planning Area’s existing conditions, as well as relevant federal, State, and local regulations and programs.

4.5.2 Environmental Setting
Regional Context
Electricity
Electricity, a consumptive utility, is a human-made resource. The production of electricity requires the consumption or conversion of energy resources, including water, wind, oil, gas, coal, solar, geothermal, and nuclear resources, into energy. The delivery of electricity involves a number of system components, for distribution and use. The electricity generated is distributed through a network of transmission and distribution lines commonly called a power grid.

Energy capacity, or electrical power, is generally measured in watts (W) while energy use is measured in watt-hours (Wh). For example, if a light bulb has a capacity rating of 100 W, the energy required to keep the bulb on for 1 hour would be 100 watt-hours. If ten 100 W bulbs were on for 1 hour, the energy required would be 1,000 Wh or 1 kilowatt-hour (kWh). On a utility scale, a generator’s capacity is typically rated in megawatts (MW), which is 1 million watts, while energy usage is measured in megawatt-hours (MWh) or gigawatt-hours (GWh), which is 1 billion Wh.

Southern California Edison (SCE) provides electrical services to 15 counties, 180 incorporated cities (including a majority of Culver City), and approximately 15 million people throughout its 50,000-square-mile service area, across central, coastal and southern California, an area bounded by Mono County to the north, Ventura County to the west, San Bernardino County to the east, and Orange County to the south.
1 SCE produces and purchases energy from a mix of
conventional and renewable generating sources.

SCE generates power from a variety of energy sources, including large hydropower (greater than 30 MW), coal, gas, nuclear sources, and renewable resources, such as wind, solar, small hydropower (less than 30 MW), and geothermal sources. In 2022, the SCE power system experienced a peak demand of 24,345 MW (the most recent year for which data are available).2 Approximately 45 percent of the SCE 2022 electricity purchases were from renewable sources, which is higher than

1 Southern California Edison, 2023a. About Us- Who We Are. https://www.sce.com/about-us/who-we-are.

Accessed January 2024.
2 Southern California Edison, 2023b. 2022 Annual Report, p. 2.

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4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
the approximate 36 percent statewide percentage of electricity purchases from renewable sources.3,4 The annual electricity sale to customers in 2022 was approximately 84,218 GWh.5 The Los Angeles Department of Water and Power (LADWP) provides electricity to the remaining portions of the city. LADWP provides electrical service throughout the City of Los Angeles, as well as a portion of the Planning Area, serving approximately 4 million people within a service area of approximately 465 square miles. Electrical service provided by LADWP is divided into two planning districts: Valley and Metropolitan. The Valley Planning District includes the LADWP service area north of Mulholland Drive, and the Metropolitan Planning District includes the LADWP service area south of Mulholland Drive. The Planning Area is located within LADWP’s Metropolitan Planning District.

LADWP generates power from a variety of energy sources, including hydropower, coal, gas, nuclear sources, and renewable resources, such as wind, solar, and geothermal sources.

According to LADWP’s 2022 Power Strategic Long-Term Resource Plan, LADWP has a net dependable generation capacity greater than 8,101 MW.
6 On August 31, 2017, LADWP’s power
system experienced a record instantaneous peak demand of 6,502 MW.7 Approximately 35.2 percent of LADWP’s 2021 electricity purchases were from renewable sources, which is similar to the 33.6 percent statewide percentage of electricity purchases from renewable sources.8 The annual electricity sale to customers for the 2022 fiscal year was approximately 21,310 GWh.9 Natural Gas
Natural gas is a combustible mixture of simple hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas consumed in California is obtained from naturally occurring reservoirs but relies upon out-of-state imports for nearly 90 percent of its natural gas supply.
10 A majority of natural gas consumed in California is for electricity generation, along with the industrial, residential, and commercial sections.11 Among energy commodities consumed in California, natural gas accounts for approximately 31 percent of total energy

3 Southern California Edison, 2023c. 2022 Sustainability Report, p. 15. https://www.edison.com/sustainability/sustainability-report . Accessed January 2024. 4 California Energy Commission, 2023a. 2022 Total System Electric Generation. https://www.energy.ca.gov/data- reports/energy-almanac/california-electricity-data/2022-total-system-electric-generation. Accessed January 2024. 5 Southern California Edison, 2023b. 2022 Annual Report, p. 2. 6 Los Angeles Department of Water and Power, 2022. 2022 Power Strategic Long-Term Resource Plan, p. ES-5. 7 Los Angeles Department of Water and Power, 2022. 2022 Power Strategic Long-Term Resource Plan, p. ES-5. 8 California Energy Commission, 2023b. 2021 Power Content Labels. Updated January 31, 2023. 9 Los Angeles Department of Water and Power, 2023. Briefing Book 2022-2023, p. 61. https://ladwp-jtti.s3.us-west-

2.amazonaws.com/wp-content/uploads/sites/3/2023/05/18120930/2022-23_Briefing_Book_Online.pdf.

Accessed January 2024.
10 California Energy Commission, 2023c . Supply and Demand of Natural Gas in California. https://www.energy.ca.gov/data-reports/energy-almanac/californias-natural-gas-market/supply-and-demand- natural-gas-california. Accessed January 2024.
11 Ibid.

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General Plan 2045 and Zoning Code Update Project 4.5-3 SCH No. 2022030144 City of Culver City March 2024
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consumption.12 Natural gas is typically measured in terms of cubic feet (cf) or British thermal units (BTU).

Natural gas is provided to the city by Southern California Gas (SoCalGas). SoCalGas is the principal distributor of natural gas in Southern California, serving residential, commercial, and industrial markets. SoCalGas serves approximately 21.1 million customers in more than 500 communities encompassing approximately 24,000 square miles throughout Central and Southern California, from the city of Visalia to the Mexican border. 13 SoCalGas receives gas supplies from several sedimentary basins in the western U.S. and Canada, including supply basins located in New Mexico (San Juan Basin), West Texas (Permian Basin), the Rocky Mountains, and Western Canada as well as local California supplies. 14 The traditional,
southwestern U.S. sources of natural gas will continue to supply most of SoCalGas’ natural gas demand. The Rocky Mountain supply is available but is used as an alternative supplementary supply source, and the use of Canadian sources provide only a small share of SoCalGas supplies due to the high cost of transport.
15 The annual natural gas sale to customers in 2022 was approximately 897,170 million cf.16
Transportation Energy
According to the California Energy Commission (CEC), fossil gas accounted for approximately 31 percent of California’s total energy consumption in 2021 based on a carbon dioxide equivalent basis.17 In 2022 (the most recent year for which data are available), California consumed 13.6 billion gallons of gasoline and 3.1 billion gallons of diesel fuel.18 Petroleum-based fuels account for 89 percent of California’s transportation fuel use.19 California has implemented several policies, rules, and regulations to improve vehicle efficiency, increase the development and use of alternative fuels, reduce air pollutants and greenhouse gases (GHGs) from the transportation sector, and reduce vehicle miles traveled (VMT). Additionally, California is transitioning to zero- carbon, renewable sources of power while rapidly electrifying large segments of the economy. The CEC predicts that the demand for gasoline and transportation fossil fuels in general will continue to decline as the sales of electric vehicles increases. New zero-emission vehicle sales grew from less

12 California Energy Commission, 2023d. Final 2022 Integrated Energy Policy Report Update, p. 123. https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/2022-integrated-energy- policy-report-update. Accessed January 2024.
13 Southern California Gas, 2023. Company Profile. https://www.socalgas.com/about-us/company-profile. Accessed January 2024.
14 California Gas and Electric Utilities, 2023. 2023 California Gas Report, p. 36. https://www.socalgas.com/sites/default/files/Joint_Biennial_California_Gas_Report_2023_Supplement.pdf.

Accessed January 2024.
15 Ibid.
16 Ibid, p. 36. Daily natural gas usage in 2022 was 2,458 million cf; annual value derived by multiplying daily values by 365 days.
17 California Energy Commission, 2023e. Draft 2023 Integrated Energy Policy Report, p.A-1. https://efiling.energy.ca.gov/GetDocument.aspx?tn=253086. Accessed January 2024. 18 California Energy Commission, 2024. 2022 California Annual Retail Fuel Outlet Report Results (CEC-A15) Energy Assessments Division. https://www.energy.ca.gov/sites/default/files/2023-08/2010-2022%20CEC- A15%20Results%20and%20Analysis%20ADA.xlsx. Accessed January 2024. 19 California Energy Commission, 2023f. 2021–2023 Investment Plan Update for the Clean Transportation Program.

December 17, 2021.

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General Plan 2045 and Zoning Code Update Project 4.5-4 SCH No. 2022030144 City of Culver City March 2024
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than 8 percent in 2020 to more than 25 percent in the third quarter of 2023.20 According to fuel sales data from the CEC, fuel consumption in Los Angeles County (County) was approximately 3.1 billion gallons of gasoline and 0.3 billion gallons of diesel fuel in 2022.21 Existing Conditions
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 energy demand associated with building electricity and natural gas consumption and transportation fuel consumption. However, data with respect to the exact activity level (i.e., utility consumption, trip generation) and building energy standards for each use is not obtainable.

Therefore, existing energy estimates are based on default parameters in the California Emissions Estimator (CalEEMod) for area and building energy sources. Existing transportation fuel demand for mobile sources are based on VMT
22 and on-road mobile source fuel demand factors from the CARB on-road vehicle emissions factors (EMFAC2021) model. Table 4.5-1, Estimated Existing Operational Energy Demand, presents the energy demand from the existing development in Culver City.

TABLE 4.5-1

ESTIMATED EXISTING OPERATIONAL ENERGY DEMAND
Energy Type Annual Quantity 1, 2
Electricity Demand – Existing (MWh)
Residential 64,510 MWh
Commercial 522,727 MWh
Industrial 35,662 MWh
Institutional 1,330 MWh
Total Electricity 624,230 MWh
Natural Gas Demand – Existing (cf)
Residential 163.1 Mcf
Commercial 555.7 Mcf
Industrial 36.5 Mcf
Institutional <0.1 Mcf
Transportation 26.7 Mcf
Total Natural Gas 782.0 Mcf
Transportation (Gallons)
Gasoline 26.71 Mgal
Diesel 7.86 Mgal
NOTES: MWh = megawatt-hours; Mcf = million cubic feet; Mgal = million gallons 1 Detailed calculations are provided in Appendix D of this PEIR. 2 Totals may not add up due to rounding of decimals.

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

20 CEC, 2023e . Draft 2023 Integrated Energy Policy Report, November 13, 2023, p. 2. https://efiling.energy.ca.gov/GetDocument.aspx?tn=253086. Accessed January 2024. 21 California Energy Commission, 2024. 2022 California Annual Retail Fuel Outlet Report Results (CEC-A15) Energy Assessments Division. https://www.energy.ca.gov/sites/default/files/2023-08/2010-2022%20CEC- A15%20Results%20and%20Analysis%20ADA.xlsx. Accessed January 2024. 22 Fehr & Peers, 2024.

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

Federal
Energy Policy Act of 1992
The Energy Policy Act set goals, created mandates, and amended utility laws to increase clean energy use and improve overall energy efficiency in the United States. It established regulations requiring certain federal, state, and alternative fuel provider fleets to build an inventory of alternative fuel vehicles. It was amended several times in the Energy Conservation and Reauthorization Act of 1998 and in 2005 via the Energy Policy Act in 2005, which emphasized alternative fuel use and infrastructure development.

Energy Policy Act of 2005
The Energy Policy Act of 2005 includes provisions for renewed and expanded tax credits for electricity generated by qualified energy sources, such as landfill gas; provides bond financing, tax incentives, grants, and loan guarantees for clean renewable energy and rural community electrification; and establishes a federal purchase requirement for renewable energy. The Renewable Fuel Standard (RFS) program was created under the Energy Policy Act of 2005 and established the first renewable fuel volume mandate in the United States.

United States Department of Transportation, United States Department of Energy, and United States Environmental Protection Agency On the federal level, the United States Department of Transportation (USDOT), United States Department of Energy (USDOE), and United States Environmental Protection Agency (USEPA) are three agencies with substantial influence over energy policies related to transportation fuels consumption. Generally, federal agencies influence transportation energy consumption through establishment and enforcement of fuel economy standards for automobiles and light trucks through funding energy-related research and development projects, and through funding for transportation infrastructure projects.

Established by the U.S. Congress in 1975, the Corporate Average Fuel Economy (CAFE) Standards (49 CFR Parts 531 and 533) reduce energy consumption by increasing the fuel economy of cars and light trucks. The National Highway Traffic Safety Administration (NHTSA) and USEPA jointly administer the CAFE standards. The U.S. Congress has specified that CAFE standards must be set at the “maximum feasible level” with consideration given for (1) technological feasibility; (2) economic practicality; (3) effect of other standards on fuel economy; and (4) need for the nation to conserve energy. When these standards are raised, automakers respond by creating a more fuel-efficient fleet. In 2012, NHTSA established final passenger car and light truck CAFE standards for model years 2017 through 2021, which the agency projects will require in model year 2021, on average, a combined fleet-wide fuel economy of 40.3 to 41.0 miles per gallons (mpg). Fuel efficiency standards for medium- and heavy-duty trucks have been jointly developed

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by USEPA and NHTSA. The Phase 1 heavy-duty truck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through 2018, and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline, depending on the vehicle type.23 USEPA and NHTSA have also adopted the Phase 2 heavy-duty truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25 percent reduction in fuel consumption over the 2017 baseline depending on the compliance year and vehicle type.24
In March 2020, USDOT and USEPA issued the final Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, which amends existing CAFE standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establishes new standards covering model years 2021 through 2026.
25 These standards set a combined fleet wide average of 36.9 to 37 miles per gallon (mpg) for the model years affected.26 On January 20, 2021, President Biden issued Executive Order 13990 ‘‘Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis’’ directing USEPA to consider whether to propose suspending, revising, or rescinding the standards previously revised under the SAFE Vehicles Rule for Model Years 2021–2026. In February 2022, USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.
27 This final rule revises current GHG standards
beginning for vehicles in model year 2023 through model year 2026 and establishes the most stringent GHG standards ever set for the light-duty vehicle sector that are expected to result in average fuel economy label values of 40 mpg, while the standards they replace (the SAFE rule standards) would achieve only 32 mpg in model year 2026 vehicles. 28 In addition to the regulations applicable to cars and light-duty trucks described above, in 2011 USEPA and NHTSA announced fuel economy and GHG standards for medium- and heavy-duty trucks for model years 2014–2018. The standards for carbon dioxide (CO 2) emissions and fuel
consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to USEPA, this regulatory program would reduce GHG emissions and fuel consumption for the affected vehicles by 6 to 23 percent over the 2010 baselines. Building on the first phase of standards, in August 2016, USEPA and NHTSA finalized Phase 2 standards for medium and heavy-duty vehicles through model year 2027 that will improve fuel efficiency and cut carbon pollution. The Phase 2 standards are expected to lower CO
2 emissions by approximately 1.1 billion metric tons.

23 U. S. Environmental Protection Agency (USEPA), Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, 2011. https://www.nhtsa.gov/sites/nhtsa.gov/files/detailed-fact-sheet.pdf. Accessed January 2024. 24 USEPA, Federal Register / Vol. 81, No. 206 / Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles— Phase 2, 2016. 25 USEPA, Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30, 2020. https://www.federalregister.gov/documents/2020/04/30/2020-06967/the-safer-affordable-fuel-efficient-safe- vehicles-rule-for-model-years-2021-2026-passenger-cars-and. Accessed January 2024. 26 Ibid.
27 USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 28 USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

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On July 28, 2023, the NHTSA proposed new CAFE standards for passenger cars and light trucks for model years 2027 through 2032, and new fuel efficiency standards for heavy-duty pickup trucks and vans for model years 2030 through 2035. The proposed rule would require an industry fleet-wide average of approximately 58 mpg for passenger cars and light trucks in model year 2032, by increasing fuel economy by two percent year over year for passenger cars and four percent year over year for light trucks.
29 For heavy-duty pickup trucks and vans, the
proposed rule would increase fuel efficiency by 10 percent year over year.30 Energy Independence and Security Act of 2007
The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national GHG emissions by requiring the following:
• Increasing the supply of alternative fuel sources by setting mandatory Renewable Fuel Standards (RFS) that requires fuel producers to use at least 36 billion gallons of biofuel in 2022;
• Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances;
• Requiring approximately 25 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020; and • While superseded by the USEPA and the NHTSA actions described above (refer to United States Department of Transportation, United States Department of Energy, and United States Environmental Protection Agency, above) (i) establishing miles per gallon targets for cars and light trucks and (ii) directing the NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for trucks.

Additional provisions of EISA address energy savings in government and public institutions, promote research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”
31 Federal Energy Policy and Conservation Act
The Energy Policy and Conservation Act of 1975 (EPCA) is a United States Act of Congress that responded to the 1973 oil crisis by creating a comprehensive approach to federal energy policy.

The primary goals of EPCA are to increase energy production and supply, reduce energy demand, provide energy efficiency, and give the executive branch additional powers to respond to disruptions in energy supply. Most notably, EPCA established the Strategic Petroleum Reserve, the Energy Conservation Program for Consumer Products, and CAFE regulations.

29 National Highway Traffic Safety Administration, 2023. Corporate Average Fuel Economy. https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy#75896. Accessed January 2024. 30 Ibid.
31 A “green job,” as defined by the United States Department of Labor, is a job in business that produces goods or provides services that benefit the environment or conserve natural resources.

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State
California Building Standards Code (Title 24, Parts 6 and 11) The California Building Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations [CCR], Title 24, Part 6) were adopted to ensure that building construction and system design and installation achieve energy efficiency and preserve outdoor and indoor environmental quality. The current California Building Energy Efficiency Standards (Title 24 standards) are the 2022 Title 24 standards, which became effective January 1, 2023.

The 2022 Title 24 standards include efficiency improvements to the residential standards for attics, walls, water heating, and lighting; and efficiency improvements to the non-residential standards include alignment with the American Society of Heating and Air-Conditioning Engineers (ASHRAE) 90.1-2019 national standards.
32 The California Green Building Standards Code (CCR, Title 24, Part 11), commonly referred to as the CALGreen Code, became effective in 2023. The 2022 CALGreen Code includes mandatory measures for non-residential development related to site development, energy efficiency, water efficiency and conservation; material conservation and resource efficiency; and environmental quality.
33 For example, the 2022 standards encourage efficient electric heat pumps, establish electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Refer to Section 4.7, Greenhouse Gas Emissions, of this PEIR, for additional details regarding these standards.

California Appliance Efficiency Regulations
The 2012 Appliance Efficiency Regulations (CCR, Title 20, Sections 1601 through 1608) took effect February 13, 2013. The regulations include standards for both federally regulated appliances and non-federally regulated appliances.

Renewables Portfolio Standard
The State has adopted regulations to increase the proportion of electricity from renewable sources. In 2008, Executive Order S-14-08 expanded the State’s Renewable Portfolio Standard (RPS) goal to 33 percent renewable power by 2020. In 2009, Executive Order S-21-09 directed CARB (under its Assembly Bill [AB] 32 authority) to enact regulations to help the State meet the 2020 goal of 33 percent renewable energy. The 33 percent by 2020 RPS goal was codified with the passage of Senate Bill (SB) X1-2. This new RPS applied to all electricity retailers in the state, including publicly owned utilities (POUs), investor-owned utilities, electricity service providers, and community choice aggregators. SB 350 (Chapter 547, Statues of 2015) further increased the RPS to 50 percent by 2030, including interim targets of 40 percent by 2024 and 45 percent by 2027. In 2018, SB 100 further increased California’s RPS and requires retail sellers and local POUs to procure eligible renewable electricity for 44 percent of retail sales by the end of 2024, 52 percent by the end of 2027, and 60 percent by the end of 2030; and requires that CARB

32 California Energy Commission, 2022. 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings. August 2022.
33 California Building Standards Commission, 2022. Guide to the 2022 California Green Building Standards Code Nonresidential. July.

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should plan for 100 percent eligible renewable energy resources and zero-carbon resources by the end of 2045.

The California Public Utilities Commission (CPUC) and the CEC jointly implement the RPS program. The CPUC’s responsibilities include: (1) determining annual procurement targets and enforcing compliance; (2) reviewing and approving each investor-owned utility’s renewable energy procurement plan; (3) reviewing contracts for RPS-eligible energy; and (4) establishing the standard terms and conditions used in contracts for eligible renewable energy.

California Senate Bill 1389
SB 1389 (Public Resources Code Sections 25300–25323; SB 1389) requires the CEC to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the State’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the State’s economy; and protect public health and safety (Public Resources Code Section 25301(a)). The Integrated Energy Policy Report provides the results of the CEC’s assessments related to energy sector trends, building decarbonization and energy efficiency, zero-emissions vehicles, energy equity, climate change adaptation, electricity reliability in the Southern California region, natural gas assessment, and electricity, natural gas, and transportation energy demand forecasts.

California Assembly Bill 1493
In response to the transportation sector’s large share of California’s CO2 emissions, AB 1493 (commonly referred to as the Pavley regulations), enacted on July 22, 2002, requires CARB to set GHG emission standards for new passenger vehicles, light-duty trucks, and other vehicles manufactured in and after 2009 whose primary use is non-commercial personal transportation.

Phase I of the legislation established standards for model years 2009–2016 and Phase II established standards for model years 2017–2025.
34,35 As discussed above, in September 2019,
USEPA published the SAFE Vehicles Rule in the federal register (Federal Register, Vol. 84, No. 188, Friday, September 27, 2019, Rules and Regulations, Sections 51310–51363) that maintains the vehicle miles per gallon standards applicable in model year 2020 for model years 2021 through 2026. On January 20, 2021, President Biden issued Executive Order 13990 ‘‘Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis’’ directing USEPA to consider whether to propose suspending, revising, or rescinding the standards previously revised under the SAFE Vehicles Rule for Model Years 2021–2026. In February 2022, USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.
36 This final rule revises current GHG standards beginning for vehicles in model year 2023 and through model year 2026 and establish the most stringent GHG standards

34 California Air Resources Board, 2023a. California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission-standards-under- assembly-bill-1493-2002-pavley. Accessed January 2024.
35 USEPA, 2012. EPA and NHTSA Set Standards to Reduce Greenhouse Gases and Improve Fuel Economy for Model Years 2017–2025 Cars and Light Trucks.
36 USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

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ever set for the light-duty vehicle sector that are expected to result in average fuel economy label values of 40 mpg, while the standards they replace (the SAFE rule standards) would achieve only 32 mpg in model year 2026 vehicles.37
California Health and Safety Code (HSC), Division 25.5, California Global Warming Solutions Act of 2006
In 2006, the California State Legislature adopted AB 32 (codified in the California Health and Safety Code [HSC], Division 25.5 – California Global Warming Solutions Act of 2006), which focuses on reducing GHG emissions in California to 1990 levels by 2020. Under HSC Division

25.5, CARB has the primary responsibility for reducing the State’s GHG emissions; however, AB 32 also tasked the CEC and the CPUC with providing information, analysis, and recommendations to CARB regarding strategies to reduce GHG emissions in the energy sector.

In 2016, the California State Legislature adopted SB 32 and its companion bill, AB 197, which amended HSC Division 25.5 and established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and included provisions to ensure that the benefits of state climate policies reach into disadvantaged communities. Refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for details regarding these regulations.

Senate Bill 350
SB 350, signed October 7, 2015, is the Clean Energy and Pollution Reduction Act of 2015. SB 350 is the implementation of some of the goals of Executive Order B-30-15. Building off AB 32, SB 350 established California’s 2030 GHG reduction target of 40 percent below 1990 levels. To achieve this goal, SB 350 set ambitious 2030 targets for energy efficiency and renewable electricity, among other actions aimed at reducing GHG emissions. SB 350 increased California’s renewable electricity procurement goal from 33 percent by 2020 to 50 percent by 2030 prior to the current goals set by SB 100. In addition, SB 350 requires the State to double statewide energy efficiency savings in electricity and natural gas end uses by 2030.

Low-Carbon Fuel Standard
The Low-Carbon Fuel Standard (LCFS), established in 2007 through Executive Order S-1-07 and administered by CARB, requires producers of petroleum-based fuels to reduce the carbon intensity of their products, starting with 0.25 percent in 2011 and culminating in a 10 percent total reduction in 2020. Petroleum importers, refiners and wholesalers can either develop their own low carbon fuel products or buy LCFS credits from other companies that develop and sell low carbon alternative fuels, such as biofuels, electricity, natural gas, and hydrogen.

37 USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

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California Air Resources Board
CARB’s Advanced Clean Car Program
The Advanced Clean Cars emissions-control program was approved by CARB in 2012 and is closely associated with the Pavley regulations.38 The program requires a greater number of zero-emission vehicle models for years 2015 through 2025 to control smog, soot and GHG emissions. This program includes the Low-Emissions Vehicle (LEV) regulations to reduce criteria pollutants and GHG emissions from light- and medium-duty vehicles; and the zero-emission vehicle (ZEV) regulations to require manufacturers to produce an increasing number of pure ZEVs (meaning battery and fuel cell electric vehicles) with the provision to produce plug-in hybrid electric vehicles (PHEV) between 2018 and 2025. Implementation of the ZEV and PHEV regulations reduce transportation fuel consumption by increasing the number of vehicles that are partially or fully electric-powered. Effective November 26, 2019, the federal SAFE Vehicles Rule Part One: One National Program withdraws the California waiver for the GHG and ZEV programs under section 209 of the Clean Air Act, which revokes California's authority to implement the Advanced Clean Cars and ZEV mandates. On March 9, 2022, USEPA issued a notice of decision to reinstate California’s Clean Air Act waiver for its Advanced Clean Car regulations.
39 In addition, Governor Gavin Newsom signed an executive order (Executive Order No. N-79-20) on September 23, 2020, that would phase out sales of new gas-powered passenger cars by 2035 in California with an additional 10-year transition period for heavy vehicles. The State would not restrict used car sales, nor forbid residents from owning gas-powered vehicles. In accordance with the Executive Order, CARB is developing a 2020 Mobile Source Strategy, a comprehensive analysis that presents scenarios for possible strategies to reduce the carbon, toxic and unhealthy pollution from cars, trucks, equipment, and ships. The strategies will provide important information for numerous regulations and incentive programs going forward by conveying what is necessary to address the aggressive emission reduction requirements.

The primary mechanism for achieving the ZEV target for passenger cars and light trucks is CARB’s Advanced Clean Cars II (ACC II) Program. The ACC II regulations will focus on post-2025 model year light-duty vehicles, as requirements are already in place for new vehicles through the 2025 model year. A rulemaking package was presented to the Board in June 2022 and was adopted on November 30, 2022.

CARB’s Advanced Clean Trucks Program
The Advanced Clean Trucks (ACT) regulations were approved on June 25, 2020, and require that manufacturers sell zero-emissions or near-zero-emissions trucks as an increasing percentage of their annual California sales beginning in 2024. The goal of this proposed strategy is to achieve nitrogen oxide (NOx) and GHG emission reductions through advanced clean technology, and to

38 California Air Resources Board, 2023a. California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission-standards-under- assembly-bill-1493-2002-pavley. Accessed January 2024.
39 USEPA, 2022. California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Notice of Decision, 87 Fed. Reg. 14,332 (March 14, 2022).

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increase the penetration of the first wave of zero-emissions heavy-duty technology into applications that are well suited to its use. According to CARB, “Promoting the development and use of advanced clean trucks will help CARB achieve its emission reduction strategies as outlined in the State Implementation Plan (SIP), Sustainable Freight Action Plan, SB 350, and AB 32.” 40 The percentage of zero-emissions truck sales is required to increase every year until 2035 when sales would need to be 55 percent of Classes 2b–3 (light/medium- and medium-duty trucks) truck sales, 75 percent of Classes 4–8 (medium- to heavy-duty trucks) straight truck sales, and 40 percent of truck tractor (heavy-duty trucks weighing 33,001 pounds or greater) sales.

Additionally, large fleet operators (of 50 or more trucks) would be required to report information about shipments and services and their existing fleet operations.

Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling
In 2004, CARB adopted an Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling in order to reduce public exposure to diesel particulate matter emissions (Title 13 CCR Section 2485 and Title 17 CCR Section 93115). 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 location. While the goal of this measure is primarily to reduce public health impacts from diesel emissions, compliance with the regulation also results in energy savings in the form of reduced fuel consumption from unnecessary idling.

Regulation to Reduce Emissions of Diesel Particulate Matter, Oxides of Nitrogen, and Other Criteria Pollutants, from In-Use Heavy-Duty Diesel-Fueled Vehicles Because off-road vehicles that are used in construction and other related industries can last 30 years or longer, most of those that are in service today are still part of an older fleet that do not have emission controls. In 2007, CARB approved the “In-Use Off-Road Diesel Fueled Fleets Regulation” to reduce emissions from existing (in-use) off-road diesel vehicles that are used in construction and other industries. This regulation sets an anti-idling limit of five minutes for all off-road vehicles 25 horsepower and up. It also establishes emission rates targets for the off- road vehicles that decline over time to accelerate turnover to newer, cleaner engines and require exhaust retrofits to meet these targets. Revised in October 2016, the regulation enforced off-road restrictions on fleets adding vehicles with older tier engines and started enforcing beginning July 1, 2014. By each annual compliance deadline, a fleet must demonstrate that it has either met the fleet average target for that year or has completed the Best Available Control Technology requirements (BACT). Large fleets have compliance deadlines each year from 2014 through 2023, medium fleets each year from 2017 through 2023, and small fleets each year from 2019 through 2028. While the goal of this regulation is primarily to reduce public health impacts from diesel emissions, compliance with the regulation also results in energy savings in the form of reduced fuel consumption from the use of more fuel-efficient engines.

40 California Air Resources Board, 2023b. Advanced Clean Trucks Program. https://ww2.arb.ca.gov/our- work/programs/advanced-clean-trucks/about. Accessed January 2024.

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Sustainable Communities Strategy
SB 375 (Chapter 728, Statutes of 2008), which establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG, was adopted by the state on September 30, 2008. Under SB 375, CARB is required, in consultation with the State’s metropolitan planning organizations (MPOs), to set regional GHG reduction targets for the passenger vehicle and light-duty truck sector for 2020 and 2035. In February 2011, CARB adopted the GHG emissions reduction targets of 8 percent by 2020 and 13 percent by 2035 relative to 2005 GHG emissions for the Southern California Association of Governments (SCAG), which is the MPO for the region in which the city is located. 41 Of note, the proposed reduction
targets explicitly exclude emission reductions expected from the AB 1493 and the Low Carbon Fuel Standard regulations.

Under SB 375, the reduction target must be incorporated within each region’s Regional Transportation Plan (RTP), which is used for long-term transportation planning, in a Sustainable Communities Strategy (SCS). Certain transportation planning and programming activities would then need to be consistent with the SCS; however, SB 375 expressly provides that the SCS does not regulate the use of land, and further provides that local land use plans and policies (e.g., general plans and zoning codes) are not required to be consistent with either the RTP or SCS.

See detailed discussion of SCAG’s RTP/SCS below.

California Environmental Quality Act
In accordance with CEQA and CEQA Guidelines Appendix F, Energy Conservation, and to assure that energy implications are considered in project analysis and decisions, EIRs are required to include a discussion of the potential significant energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy. CEQA Guidelines Appendix F provides a list of energy-related topics that should be analyzed in an EIR. In addition, while not described or required as significance thresholds for determining the significance of impacts related to energy, Appendix F, Energy Conservation, Section II.B. indicates that environmental impacts may include:

1. The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance, and/or removal. If appropriate, the energy intensiveness of materials may be discussed,

2. The effects of the project on local and regional energy supplies and on requirements for additional capacity.

3. The effects of the project on peak and base period demands for electricity and other forms of energy.

4. The degree to which the project complies with existing energy standards.

5. The effects of the project on energy resources.

41 Southern California Association of Governments, 2023. Greenhouse Gases. https://scag.ca.gov/greenhouse-gases.

Accessed January 2024.

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The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.

Regional
Southern California Association of Governments
SB 375 requires each Metropolitan Planning Organization (MPO) to prepare a Sustainable Communities Strategy (SCS) in their regional transportation plan. In general, the SCS outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce vehicle miles traveled from automobiles and light duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, the 2020-2045 RTP/SCS, adopted on September 3, 2020, is the current RTP/SCS and is an update to the 2016-2040 RTP/SCS.

The 2020-2045 RTP/SCS focuses on the continued efforts of the previous RTP/SCS plans for an integrated approach in transportation and land use strategies in development of the SCAG region through horizon year 2045. The 2020-2045 RTP/SCS projects that the SCAG region will meet the GHG per capita reduction targets established for the SCAG region of eight percent by 2020 and 19 percent by 2035. Additionally, its implementation is projected to reduce VMT per capita for the year 2045 by 4.1 percent compared to baseline conditions for the year. Rooted in the 2008 and 2012 RTP/SCS plans, the 2020-2045 RTP/SCS includes “Core Vision” that centers on maintaining and better managing the transportation network for moving people and goods while expanding mobility choices by location housing, jobs, and transit closer together, and increasing investments in transit and complete streets. In addition, refer to Section 4.6, Greenhouse Gas Emissions, of this PEIR for additional details regarding these requirements.

South Coast Air Quality Management District
As discussed in Section 4.2, Air Quality, of this PEIR, the South Coast Air Quality Management District (SCAQMD) is responsible for air quality planning in the South Coast Air Basin (where the city is located) and developing rules and regulations to bring the Air Basin into attainment of the ambient air quality standards. As part of its efforts to reduce local air pollution, SCAQMD has promoted a number of programs to promoted energy conservation, low-carbon fuel technologies (natural gas vehicles; electric-hybrids, hydraulic-hybrids, and battery-electric vehicles), renewable energy, VMT reduction programs, and market incentive programs.

Local
Culver City Municipal Code
Culver City participates in an environmental recognition program, California Green Communities. The program helps cities develop strategies to reduce carbon emissions and increase energy efficiency in their community. In addition, the City has adopted green building ordinances to reduce GHG emissions for new development. Pursuant to the Culver City Municipal Code (CCMC) Section 15.02.105, the City requires 1 kilowatt (kw) of PV power

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installed per 10,000 square feet (sf) of new development.42 The CCMC includes an option to pay an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code. Under Section 17.320.035 of the CCMC, the City goes beyond CALGreen Building Code standards and requires at least 20 percent EV capable parking spaces, 10 percent EV ready parking spaces, and 10 percent EV charging stations for both new residential and retail developments.43 Additionally, Sections 4.408.1 and

5.408.1, Construction Waste Management, require that a minimum of 75 percent of nonhazardous construction and demolition waste be recycled and/or salvaged for reuse.

In 2009, the City adopted the Green Building Program as CCMC Chapter 15.02.100, which contains a number of GHG reducing features such as enhanced building insulation, low-flow water fixtures, and efficient lighting and heating, ventilation, and air conditioning (HVAC) systems. An example of the City’s Green Building Program requirements would be all lighting has to be either fluorescent, LED or other type of high-efficiency lighting, and specific features for parking garages would require all new lighting to be motion sensor controlled and the minimum base level lighting would use high efficiency lighting.

Culver City Bicycle & Pedestrian Action Plan
The current Circulation Element provides objectives and policies to encourage the use of public transit and provide safe and attractive pedestrian facilities thereby encouraging more people to reduce automobile travel in favor of alternative forms of transportation. 44 The City updated the
Bicycle & Pedestrian Master Plan with the Action Plan which received public input from 2017 through 2019. The Action Plan was adopted by the City Council in June 2020. 45 The Action Plan
establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network. The Action Plan includes goals to support increased access to neighborhood destinations and transit stations, empowering residents to live a more active lifestyle, and increasing affordability and collaboration for transportation within the community.

Culver City Clean Power Alliance
In February 2019 for residential customers and May 2019 for non-residential customers, Clean Power Alliance (CPA) became the new electricity supplier for the City of Culver City. With this change, CPA purchases the renewable energy resources for electricity and SCE delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity

42 Culver City Municipal Code. Title 15, Section 15.02.105, California Building Code Adopted by Reference with Local Amendments. https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-76668. Accessed March 2023.
43 Culver City Municipal Code. Title 17, Section 17.320.035, Parking Design and Layout Guidelines. https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-52279#JD_17.320.020. Accessed March 2023.
44 Culver City, 1995. Circulation Element, p. C-8.
45 Culver City, 2020. Bicycle & Pedestrian Action Plan.

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needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent, or opt out of the CPA to remain with SCE as their provider.

The Project’s energy analyses conservatively assume the Project will remain with SCE as their electricity provider and does not take additional credit for renewable energy beyond the expected SCE renewable energy percentage for year 2022 based on the required renewables by year 2024 under SB 100.
46 Culver City Reach Code
The Culver City Reach Code, codified under CCMC Section 15.02.1100, establishes building energy efficiency standards that are additional to the standards established by the State’s CALGreen Building Code and Title 24 Energy Code requirements. The Culver City Reach Code includes provisions for all new buildings with separate standards for buildings of 49,999 sf or less (Category 1) and buildings 50,000 sf or more (Category 2). The following requirements do not apply to one- and two-family residences.

For Category 1 buildings, the Reach Code provides a list of 25 items that new buildings can implement in order to meet the standards. A project must comply with at least 80 percent of all items listed. Examples include: gas heating units being 93 percent energy efficient, installing radiant barriers on all new roof sheathing, installing high efficiency lighting in all exterior and interior spaces, and installing 1 kW of solar photovoltaic.

For Category 2 buildings, the Reach Code establishes three mandatory requirements related to LEED certification. The requirements include the following:
(1) Prior to the issuance of a building permit, the applicant shall submit:
a. Evidence that a LEED Accredited Professional (AP) is one of the members of the project team
b. Evidence that the project has been registered with the United States Green Building Council’s (USGBC’s) LEED Program
c. Complete a LEED Checklist including points allocated to the “Innovation and Design” category, which demonstrates that the project meets the selected LEED® Rating System at the “Certified” level or higher.
d. A signed declaration from the LEED®-AP member of the project team, stating that the plans and plan details have been reviewed and the project meets the intent of the criteria for certification of the selected LEED® Rating System at the “Certified” level or higher.
(2) The project shall comply with USGBC’s “3 point margin of error” for LEED Certification. (3) Applicant shall submit to the Building Official copies of all correspondence between the applicant and USGBC regarding the project.

46 For the purposes of estimating energy demand, the analysis conservatively assumes the Project would not switch electricity providers from SCE to the CPA (i.e., does not take any credit for 36 percent, 50 percent, or 100 percent renewable electricity, depending on the selected CPA plan). Should the Project switch electricity providers from SCE to the CPA, the Project’s electricity-related demand would be lower than those disclosed in this section.

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4.5.4 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 energy if the project would:

Threshold ENG-1: Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

Threshold ENG-2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Methodology
Construction
Construction of new development that could occur from the General Plan Update would have the potential to increase energy consumption 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.

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 energy consumption associated with buildout cannot be specifically determined at this time. Therefore, the analysis will be based on the potential for construction energy consumption to exceed threshold values in the context of development intensity and compliance with regulatory standards.

Operation
Operation of new development that could occur from adoption of the proposed General Plan Update would require energy in the form of electricity and natural gas for building heating, cooling, cooking, lighting, water demand and wastewater treatment, consumer electronics, and other energy needs, and transportation-fuels, primarily gasoline, for vehicles traveling to, from, and within the city. Detailed emissions calculations are provided in Appendix D of this PEIR.

Electricity
The estimated electricity demand that would occur from new developments that could occur under the General Plan update is analyzed relative to SCE’s existing energy supplies available to serve the city. Annual consumption of electricity (including electricity usage associated with the supply and conveyance of water) from operations was calculated using demand factors provided in CalEEMod based on the 2022 Title 24 Standards, which went into effect on January 1, 2023.

While the Title 24 standards are typically revised every three years with more stringent energy efficiency requirements, it is not known to what extent future revisions to the Title 24 standards would reduce energy demand from new buildings. Therefore, it is not possible to accurately quantify the effects of future revisions to the Title 24 standards on energy demand from new buildings. Energy usage from water demand (e.g., electricity used to supply, convey, treat, and

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
distribute) are estimated based on the new development that could occur under the General Plan Update. The assessment also includes a discussion of the proposed General Plan Update’s compliance with relevant energy-related regulatory measures, that would minimize the amount of energy usage from new development under the General Plan Update. For the purposes of estimating energy demand, since customers can choose to opt out of the CPA, the analysis conservatively assumes the Project would not switch electricity providers from SCE to the CPA (i.e., does not take any credit for 36 percent, 50 percent, or 100 percent renewable electricity, depending on the selected CPA plan). Should the Project switch electricity providers from SCE to the CPA, the Project’s electricity-related demand would be lower than those disclosed in this section. These measures are also discussed in Section 4.2, Air Quality, and Section 4.7, Greenhouse Gas Emissions, of this PEIR.

Natural Gas
The estimated natural gas demand that would occur from new development under the General Plan Update is analyzed relative to SoCalGas’ existing and planned energy supplies in 2045 (i.e., the buildout year). Natural gas demand from new development under the General Plan Update would be generated primarily by building heating and appliances. Natural gas consumption is compared to both supply and infrastructure availability.

Transportation Fuels
Energy for transportation from visitors and residents traveling to and from new development that could occur under the General Plan Update is estimated based on transportation fuel consumption factors from EMFAC along with VMT data, which considers mode and trip lengths, developed for the transportation analysis. Fuel consumption from motor vehicles is dependent on vehicle type. Thus, the factors were calculated using a representative motor vehicle fleet mix based on the CARB EMFAC2021 model and default fuel types. EMFAC2021 incorporates the SAFE Vehicles Rule as well as the Advanced Clean Truck Program. However, traffic reduction policies within the General Plan Update 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 transportation fuel consumption estimates. Therefore, estimated mobile source transportation fuel consumption is conservatively higher. Transportation fuel consumption is compared to both supply and infrastructure availability.

Project Impact Analysis
Result in Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources
Threshold ENG-1: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code Updates would result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation.

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General Plan 2045 and Zoning Code Update Project 4.5-19 SCH No. 2022030144 City of Culver City March 2024
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Impact Statement 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.

Construction
During construction of new development that could occur under the General Plan Update, energy would be consumed in the form of electricity on a limited basis for powering lights, electronic equipment, or other construction activities necessitating electrical power.

Construction would also consume energy in the form of petroleum-based fuels associated with the use of off-road construction vehicles and equipment, construction workers traveling to and from development sites, and delivery and haul truck trips (e.g., hauling of demolition material to off-site reuse and disposal facilities).

Electricity
Construction electricity would be consumed, on a limited basis, to power lighting, electric equipment, and supply and convey water for dust control. During construction of new development that could occur under the General Plan Update, the electricity demand at any given time would vary throughout the construction period based on the construction activities being performed, and would cease upon completion of construction. Electricity use from construction would be short-term, limited to working hours, and used for necessary construction-related activities. When not in use, electric equipment would be powered off to avoid unnecessary energy consumption. Furthermore, the electricity used for off-road light construction equipment would have the co-benefit of reducing construction-related energy use from more traditional construction-related energy such as diesel fuel. Therefore, the impact from construction electrical demand would be less than significant and would not result in the wasteful, inefficient, and unnecessary consumption of energy.

Natural Gas
Construction activities, including the construction of new buildings and facilities, typically do not involve the consumption of natural gas. Accordingly, natural gas would generally not be supplied to support construction activities; thus, there would be no expected demand generated by future construction that could occur under the General Plan Update. If natural gas is used during construction, it would be in limited amounts and on a temporary basis and would specifically be used to replace or offset diesel-fueled equipment and as such would not result in substantial on- going demand. Therefore, the impact from construction natural gas demand would be less than significant and would not result in the wasteful, inefficient, and unnecessary consumption of energy.

Transportation Energy
Transportation fuels (gasoline and diesel) are produced from crude oil, which can be supplied domestically or imported from various regions around the world. Based on current proven reserves, crude oil production would be sufficient to meet over 50 years of worldwide consumption.47

47 BP, 2021. Statistical Review of World Energy 2021, 70th edition, https://www.bp.com/content/dam/bp/business- sites/en/global/corporate/pdfs/energy-economics/statistical-review/bp-stats-review-2021-full-report.pdf.

Accessed January 2024.

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General Plan 2045 and Zoning Code Update Project 4.5-20 SCH No. 2022030144 City of Culver City March 2024
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Construction of new development that could occur under the General Plan Update would utilize fuel-efficient equipment consistent with state and federal regulations, such as the fuel efficiency regulations in accordance with the Advanced Clean Cars and Advanced Clean Truck Program, which would result in more efficient use of transportation fuels (lower consumption). Construction equipment and vehicles would also be required to comply with anti-idling regulations in accordance with Section 2485 in Title 13 of the CCR, and fuel requirements in accordance with Section 93115 in Title 17 of the CCR. As such, construction of new development would comply with regulatory measures to reduce the inefficient, wasteful, and unnecessary consumption of energy, such as petroleum-based transportation fuels. While some of these regulations are intended to reduce construction emissions, compliance with the anti-idling and emissions regulations discussed above would also result in fuel savings from the use of more fuel-efficient engines.

Based on the analysis above, construction would utilize energy only for necessary on-site activities and to transport construction materials and demolition debris to, from, and within the city. As discussed above, idling restrictions and the use of cleaner, energy-efficient equipment and fuels would result in less fuel combustion and energy consumption, and thus minimize construction-related energy use. Therefore, construction of new developments that could occur under the General Plan Update would not result in the wasteful, inefficient, and unnecessary consumption of energy, and this impact would be less than significant.

Operation
During operation of existing development and new development that could occur under the General Plan Update, energy would be consumed for multiple purposes, including, but not limited to, heating, ventilation, and air conditioning; refrigeration; lighting; and the use of electronics, equipment, and appliances. Energy would also be consumed by existing development and new development under the General Plan Update during operations related to water usage, solid waste disposal, and vehicle trips. Table 4.5-2, Estimated Culver City General Plan 2045 Operational Energy Demand, shows the net change in energy demand from electricity, natural gas, gasoline, and diesel.

TABLE 4.5-2
ESTIMATED CULVER CITY GENERAL PLAN 2045 OPERATIONAL ENERGY DEMAND1 Energy Type Annual Quantity 2,3
Electricity
Existing Development (2019) plus New Development (2045) Building Energy and Water Conveyance and Treatment 802,701 MWh Existing Development (2019) 624,230 MWh
Total Net Electricity 178,471 MWh
Natural Gas
Existing Development (2019) plus New Development (2045) Building Energy and Transportation 1,208.4 Mcf
Existing Development (2019) 782.0 Mcf
Total Net Natural Gas 426.4 Mcf

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General Plan 2045 and Zoning Code Update Project 4.5-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Energy Type Annual Quantity 2,3
Transportation
Existing Development (2019) plus New Development (2045) Gasoline 18.08 Mgal
Diesel 4.99 Mgal
Existing Development (2019)
Gasoline 26.71 Mgal
Diesel 7.86 Mgal
Total Net Transportation – Gasoline (8.62 Mgal)
Total Net Transportation – Diesel (2.87 Mgal)
NOTES: MWh = megawatt-hours; Mcf = million cubic feet; Mgal = million gallons 1 Detailed calculations are provided in Appendix D of this Draft PEIR. 2 Totals may not add up due to rounding of decimals.
3 Parentheses denote a negative value
SOURCE: ESA, 2024; Fehr & Peers, 2024 (VMT data).

Electricity
Operation of new development that could occur under the General Plan Update would result in demand for electricity resources including for water supply, conveyance, distribution, and treatment. The estimated operational electricity demand, including from water demand, is provided in Table 4.5-2. As shown in Table 4.5-2, the operation of existing development and new development under the General Plan Update would result in a net increase of electricity compared to existing conditions of approximately 178,471 MWh per year.

New development under the General Plan Update would comply with the applicable provisions of Title 24 and the CALGreen Code in effect at the time of building permit issuance. The values in Table 4.5-2 assume compliance with the 2022 Title 24 Building Energy Efficiency Standards for new development under the General Plan Update. Since the standards are updated every three years, future new development under the General Plan Update would be designed to include energy saving features to comply with future Title 24 standards and CALGreen Code requirements that are not reflected in the quantified values in Table 4.5-2, which may include greater use of energy and water efficient fixtures and fittings, energy efficient mechanical systems, light pollution reduction, site development best practices, sub metering, water efficient landscapes, recycling, and superior weather resistance and moisture management. Further, implementation of policies in the General Plan Update would reduce the electricity demand from new development in the city by promoting energy efficiency designs and strategies beyond regulatory requirements and policies for renewable energy. Therefore, operations would not result in the wasteful, inefficient, and unnecessary consumption of electricity.

For the 2019 baseline year, SCE had an annual electric sale to customers of approximately 84,654 GWh.
48 The increase in future electricity demand from existing development and new

48 Southern California Edison, 2023d. 2021 Annual Report, p. 2. https://www.edison.com/investors/financial- reports-information/annual-reports. Accessed January 2024.

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4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-22 SCH No. 2022030144 City of Culver City March 2024
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development under the General Plan Update would represent approximately 0.948 percent of the SCE network sales for 2019. Thus, it is likely that the net increase in electricity would generally be served by existing infrastructure capacity and the impact related to electrical supply and infrastructure capacity would be less than significant.

Natural Gas
The new development that could occur under the General Plan Update would result in demand for natural gas resources, as shown in Table 4.5-2. As would be the case with electricity, new development would comply with the applicable provisions of Title 24 and the CALGreen Code in effect at the time of building permit issuance to minimize natural gas demand. The values in Table 4.5-2 assume compliance with the 2022 Title 24 Building Energy Efficiency Standards for new development under the General Plan Update. Since the standards are updated every three years, future new development would be designed to include energy saving features to comply with future Title 24 standards and CALGreen Code requirements that are not reflected in the quantified values in Table 4.5-2, which could include improvements to water heating efficiency or reduced natural gas-fueled systems in buildings. Further, implementation of policies in the General Plan Update would reduce the demand for natural gas from new development in the city by promoting energy efficiency designs and strategies beyond regulatory requirements and policies for renewable energy. Therefore, operations would not result in the wasteful, inefficient, and unnecessary combustion of natural gas.

According to SoCalGas data, natural gas deliveries in baseline year 2019 was 879,285 million cubic feet (cf).
49 Based on the estimated natural gas consumption as shown in Table 4.5-2, the net increase in future natural gas demand from existing development and new development that could occur under the General Plan Update would account for approximately 0.137 percent of SoCalGas’ 2019 deliveries. According to the 2022 California Gas Report, SoCalGas is forecasted to require 742,410 million cf in the year 2035, the latest available projected year. 50 The estimated natural gas demand from existing development and new development that could occur under the General Plan Update of 1,208.4 million cf per year would account for approximately 0.163 percent of SoCalGas’ projected natural gas demand for the year 2035.

Therefore, it is anticipated that SoCalGas’ existing and planned natural gas supplies would be sufficient to support the demand for natural gas at full buildout conditions of the 2045 General Plan. Therefore, it is likely that the net increase in natural gas would generally be served by existing infrastructure capacity and the impact related to natural gas would be less than significant.

Transportation Energy
As discussed above, transportation fuels (gasoline and diesel) are produced from crude oil, which can be domestic or imported from various regions around the world, and based on

49 California Gas and Electric Utilities, 2023, 2023 California Gas Report. https://www.socalgas.com/sites/default/files/Joint_Biennial_California_Gas_Report_2023_Supplement.pdf.

Accessed January 2024.
50 California Public Utilities Commission, 2022, 2022 California Gas Report. https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_Gas_Report_202

2.pdf. Accessed January 2024.

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4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-23 SCH No. 2022030144 City of Culver City March 2024
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current proven reserves, crude oil production would be sufficient to meet over 50 years of worldwide consumption.51
The estimated operational transportation fuel demand from existing development and new development that could occur under the General Plan Update is provided in Table 4.5-2. As discussed previously, traffic reduction policies in the General Plan Update Mobility Element may not be fully reflected in the VMT and transportation fuel consumption estimates. Therefore, estimated mobile source transportation fuel consumption are conservatively higher.

The location, design, and land uses of the growth anticipated under the General Plan Update would implement land use and transportation strategies related to reducing vehicle trips for residents and employees in the city by increasing residential density and housing types at infill locations and near public transit. As discussed in Section 4.16, Transportation, of this PEIR, several transit agencies provide local and regional transit service to the residents of Culver City, including Metro, Culver CityBus, Culver CityRide, Santa Monica Big Blue Bus, Los Angeles Commuter Express, and Los Angeles Metro Bus (refer to Table 4.16-1, Metro Routes Culver City, in Section 4.16, Transportation, of this PEIR).

The General Plan Update focuses on 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 Mobility Element establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi-modal circulation which will result in 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 (Goals M-2, M-3, M-4, M-5, and M-8). Therefore, the General Plan Update would support statewide and regional efforts to improve transportation energy efficiency and reduce transportation energy consumption.

51 BP, 2021. Statistical Review of World Energy 2021, 70th edition, https://www.bp.com/content/dam/bp/business- sites/en/global/corporate/pdfs/energy-economics/statistical-review/bp-stats-review-2021-full-report.pdf.

Accessed January 2024.

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General Plan 2045 and Zoning Code Update Project 4.5-24 SCH No. 2022030144 City of Culver City March 2024
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As the Project would support statewide and regional efforts to improve transportation energy efficiency, and as discussed in further detail below, the General Plan Update would not conflict with the 2020-2045 RTP/SCS goals and benefits intended to improve mobility and access to diverse destinations, provide better “placemaking,” provide more transportation choices, and reduce vehicular demand and associated emissions. Therefore, the General Plan Update would not conflict with the actions and strategies contained in the 2020-2045 RTP/SCS. In fact, as discussed above, the general location of new development that would occur under the General Plan Update would not conflict with the recommendations in these documents and would support their goals.

As discussed in Section 4.18, Utilities and Service Systems, of this PEIR, AB 341, adopted in 2012, requires that all cities and counties in the State divert 75 percent of their solid waste streams from landfills by 2020. SB 1383, adopted in 2016, establishes goals of 50 percent organics waste reduction by 2020 and 75 percent reduction by 2025. Development of future land uses, as projected in the General Plan Update, would be required to comply with federal, state, and local statutes and regulations related to solid waste. Furthermore, the policies provided in the General Plan Update regarding solid waste disposal and associated public facilities (Policies GHG-5.1, GHG-

5.2, GHG-5.3, and PR-7.1) would further ensure compliance with applicable regulations.

Compliance with federal, state, and local waste management and reduction statutes and regulations related to solid waste would reduce waste-related transportation energy.

Based on the above, future new development under the General Plan Update would minimize operational transportation fuel demand in line with state, regional, and County goals. Therefore, the Project would not lead to wasteful, inefficient, and unnecessary consumption of energy, and this impact would be less than significant.

Applicable Proposed General Plan Goals and Policies
Land Use and Community Design Element
Goal LU-1: Transit-oriented communities. Transit-oriented communities within a half mile of high-quality transit mix well-designed development, affordable housing, community services, and improved mobility options.

LU-1.1: Higher densities near transit. Allow higher residential density and intensity in mixed use developments to support walkability and transit use.

LU-1.2: Mix of uses. Encourage more mixed use and affordable housing to support a regional jobs and housing balance, to promote walk-to-work options, and to incorporate public- and neighborhood-serving uses.

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General Plan 2045 and Zoning Code Update Project 4.5-25 SCH No. 2022030144 City of Culver City March 2024
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LU-1.3: Development near transit stations. Incentivize jobs and housing growth around high-quality transit stops and along tansit corridors to reduce reliance on personal automobiles. Incentivize affordable housing on standalone projects and mixed-income projects within transit-oriented communities.

LU-1.4: Connect transit-oriented communities. Develop strong pedestrian, Culver CityBus, other public transit, and bicycle connections to and from transit stops via pedestrian-oriented building design, safe and convenient road crossings, and street furniture and amenities.

LU-1.5: Mobility hubs at transit stations. Create mobility hubs at Metro rail stops.

LU-1.6: Parking innovation. Encourage shared parking, unbundled parking, and park once strategies to minimize parking demand, reduce vehicle trips, and capitalize on mobility investments. Locate parking behind buildings and minimize visibility from the public right-of-way.

LU-1.7: Gathering spaces near mobility hubs and transit stations. Partner with project developers to create community gathering spaces, including plazas and pocket parks, near transit stations and mobility hubs.

LU-1.8: Development standards near transit stations. Allow relaxed development standards within a half mile of high-quality transit, such as reduced setbacks and greater building heights.

Goal LU-11: Residential neighborhoods. Complete, walkable single, two-family, and three- family residential neighborhoods provide a variety of housing types and forms and allow neighborhood supportive uses that sustain the needs of residents.

LU-11.9: Pedestrian and bicycle connectivity in residential neighborhoods. Link existing residential neighborhoods by providing pedestrian and bicycle connections.

Goal LU-13: Neighborhood multifamily areas. Well-designed neighborhood multifamily areas that provide opportunities for social gathering and amenities for residents in Tellefson Park, Downtown, and West Washington.

LU-13-6: Pedestrian and bicycle connectivity in residential neighborhoods. Link existing residential neighborhoods by providing pedestrian and bicycle connections.

Goal LU-14: Public realm design. A network of attractive, pedestrian-oriented, human-scale and well-landscaped streets and civic spaces throughout the city for all ages and abilities.

LU-14-2: Create an attractive pedestrian environment. Facilitate a diverse and attractive pedestrian environment through the provision of street furniture, lighting, and other amenities.

LU-14.3: Pedestrian connections and sidewalks. Improve pedestrian connections and sidewalk infrastructure across the city, especially between residential and commercial areas, keeping in mind mobility needs of children, families, seniors, and people with disabilities.

LU-14.4: Street trees. Require new development to add street trees along streets and public spaces that provide shade, attractive landscaping, and contribute positively towards public health outcomes and climate mitigation and adaptation.

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LU-14.6: Sustainable design in the public realm. Encourage use of sustainable design features in the public realm, including sustainable building and construction materials, permeable paving, drought-tolerant landscaping, and green infrastructure.

LU-14.8: Improved street tree canopy. Increase the size and extent of the urban street tree canopy to help shade streets and sidewalks. Review approved street trees and study inclusion of larger tree choices that provide more shade. Review and modify street tree placement and tree well standards to ensure long-term success of street trees.

Goal LU-16: Landscape design for resilience. Landscape design standards for new development enhance habitat quality, reduce water use, support a diverse ecosystem, and increase resilience to a changing climate.

LU-16-2: Waterwise planting palette during new construction. During new construction and landscape renovations, prioritize xeriscaping, low-water-use plants, and native plants, minimizing the total area of high-water-use plants (e.g., turf and water features).

LU-16.5: Irrigation systems for water conservation. Install weather- or soil moisture- based irrigation controllers in all new development. Cluster plants together with similar water requirements to conserve water. Use the Water Use Classification of Landscape Species (WUCOLS) ratings to establish watering needs.

LU-16.6: Water reuse. Encourage on-site water reuse for landscape and ornamental water applications for new and renovation projects.

Goal LU-18: Collaboration with private developers. Collaboration with new private development to take collective action to achieve plan goals and to ensure new development contributes its appropriate share toward the provision of parks, public facilities, and schools.

LU-18.1: Adequate infrastructure and utilities. Ensure adequate infrastructure and utility services (electricity, water, internet) for all future development and when feasible, underground utilities (new and existing) to enhance the public realm.

LU-18-4: Green building. Continually update new construction and retrofit guidelines for green buildings.

Parks, Recreation, and Public Facilities Element
Goal PR-6: Sustainable parks and recreational system and public facilities. Environmentally sustainable practices and education are a cornerstone of the parks, recreation, and open space system and the City’s public facilities.

PR-6.4: Carbon footprint reduction. Reduce the carbon footprint of the park, recreational facilities, and other public facilities and green spaces the City owns.

Goal PR-7: Public Facilities. Public facilities in Culver City, including libraries and City-owned facilities, offer high-quality services to the community.

PR-7.1: Public facility maintenance. Maintain and continue to modernize and adjust configuration of public facilities, including City Hall, The Transportation Facility, the Public Works/Parks Maintenance Yard, and the Transfer and Recycling Station. Continue to reinvest in existing facilities to extend their useful lifetimes.

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PR-7.2: Long term operations and maintenance cost reduction. Identify ways to reduce the City’s long-term operations and maintenance costs, such as adapting more energy- efficient technologies for facilities, using low-water landscape palettes, and using recycled water for irrigation.

Infrastructure Element
Goal INF-2: Water conservation. Water conservation strategies are implemented and expanded citywide to meet sustainability targets and ensure future resiliency.

INF-2-1: Water conservation. Expand and enhance existing water conservation measures, mandates, and strategies to optimize wise use of water.

INF-2.5: Drought-tolerant landscaping. Provide resources and guidance for conventional lawn conversion to drought tolerant landscaping.

INF-2.6: Water use on non-edible irrigated landscapes. Restrict and eliminate potable water use for primarily non-edible irrigated landscapes where alternative water sources are available, including captured rainwater, grey water, and recycled water.

INF-2.8: Dual plumbing. Provide dual plumbing for all new public parks and landscape projects in anticipation of future water recycling or on-site water capture, treatment and re-use infrastructure to be used for irrigation.

Goal INF-4: Water reuse networks. Water reuse networks are expanded and optimized throughout the city at the district and parcel scales.

INF-4.1: Greywater infrastructure. Develop greywater infrastructure to support city, district, and parcel level treatment and reuse strategies.

INF-4.3: Availability of recycled water supply. Explore opportunities to increase the availability of recycled water supply (i.e., install purple-pipe infrastructure).

INF-4.4: Water provisioning. Incorporate recycled and reuse water strategies in water provisioning.

INF-4.5. Incentivize water recycling. Encourage and incentivize water recycling techniques such as rainwater capture barrels and cisterns for outdoor water purposes.

Goal INF-5: Stormwater collection and reuse systems. Stormwater collection and reuse systems are enhanced at the parcel, district, and city scale to improve water quality and reduce runoff.

INF-5.4: Green infrastructure strategies. Integrate green infrastructure strategies into City-owned landscapes. For example, use drought-resistant plants, native plants, recycled water to irrigate, permeable paving, and other low-impact development features. Promote community participation and education of green infrastructure strategies through educational and case-study landscapes that demonstrate multi- benefits.

INF-5.5: Rainwater harvesting. Expand rainwater harvesting tracking systems for capture and reuse.

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4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-28 SCH No. 2022030144 City of Culver City March 2024
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Goal INF-7: Fossil fuel free energy. Electricity and natural gas infrastructure supports a carbon positive and renewable economy.

INF-7.1: Fossil fuel free energy. Residents and businesses have affordable and easy access to carbon-free and renewable energy sources.

INF-7.2: Local energy generation. Enhance local energy generation and storage to safeguard the city’s electrification network against shocks and stressors.

INF-7.3: Energy and open space projects. Align energy conversion and enhancement projects with public open space and trails provisioning.

INF-7.4: Building electrification reach codes. Ensure compliance with adopted Building Reach Code to mandate building electrification.

Mobility Element
Goal M-2: Complete streets. A layered transportation network that is complete and convenient for all travel modes and serves the greatest public good.

M-2.1: Prioritize multimodal projects. Guide project selection and delivery based on complete streets principals and addressing the gaps identified by Bicycle Network Assessment Areas, the Bicycle and Pedestrian Action Plan (BPAP) and American with Disabilities (ADA) Transition Plan.

M-2.2: Cohesive action travel network. Ensure bikeways are integrated with regional bikeways that connect with employment centers and other key land uses and destinations.

M-2.5: Multimodal connectivity. Transform traditional bus stops into mobility centric locations that provide easy access and hassle-free connectivity between modes of transportation.

Goal M-3: Transit and other mobility services. Frequent, reliable, and high-quality public transit and mobility services that are adaptable for the dynamic future of mobility needs, markets, and solutions. Travel behavior shifts from driving to more sustainable modes by establishing comprehensive and high-quality mobility service options and infrastructure.

High-quality public transit and mobility services to accommodate the city’s growth in population, jobs, and economy.

M-3.3: Mobility options. Continually improve and innovate existing, directly operated mobility services including CityBus and CityRide services and manage and/or collaborate with mobility service providers to provide and improve other mobility services.

Goal M-4: Equitable access. A transportation system that provides affordable or free, equitable, and efficient access to employment centers, residential communities, schools, and other essential services.

M-4.1: Integrated public transportation services. Manage and operate integrated transportation services, other multimodal mobility services, and resources to provide convenient and reliable options for daily trips.

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M-4.2: First/last-mile barriers. Prioritize investments that reduce first/last-mile barriers to transit stops and encourage alternative transportation options for daily activities and/or improve access to high quality jobs.

M-4.3: Access to mobility in SB 1000 Priority Neighborhoods. Improve access to mobility services and implement multimodal improvements in Senate Bill 1000 Priority Neighborhoods.

M-4.4: Bicycle parking. Provide secure and covered bicycle parking at key destinations, including all public parking garages.

M-4.5: Equitable transit access. Work with transit agencies to enhance services in areas lacking convenient transit access, including increased service frequency and spans.

M-4.6: Accessible pedestrian facilities. Construct pedestrian facilities, including sidewalks and controlled crossings, that are ADA-compliant and connect with key land uses and regional and local transit services.

M-4.7: Mobility service geographic prioritization. Prioritize expanding alternative mobility services and resources to communities with limited access to transit and developing a connected multimodal network across the city.

M-4.8: Public transit and mobility service prioritization. Continue to prioritize dignified public transit and mobility services to accommodate people with mobility impairments, non-traditional schedules, and families that need flexible mobility options.

Goal M-5: Sustainable and accessible transportation system and transit-oriented communities. A sustainable and accessible transportation system that provides great multimodal travel experience for residents, workers, and visitors through mobility planning, transportation demand management, and transit-oriented districts, corridors, and developments.

M-5.2: Mobility paradigm shift. Shift the mobility paradigm toward sustainable modes by offering equitable alternative mobility choices and transforming the multimodal travel experience. Implement multimodal street transformations with expanded sustainable mobility services, enhanced access to mobility services, and other strategies to improve the travel experience.

M-5.3: Transportation demand management implementation. Deploy TDM measures citywide to shift the mobility paradigm by promoting and incentivizing the use of non- drive alone and sustainable mobility options.

M-5.4: Transportation demand management requirements. Require employers and new developments to effectively reduce the number of single-occupancy vehicle trips they generate and ensure safe and comfortable access for the local multimodal network, including promoting and incentivizing the use of transit, walking, and cycling over driving.

Goal M-8: Active transportation. An active transportation network that supports healthy living and expands access to social determinants of health.

M-8.5: Bicycle and Pedestrian Action Plan (BPAP) alignment. Align with the BPAP and expand the network recommendations as needed to facilitate a complete and interconnected citywide active transportation network.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-30 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Greenhouse Gas Reduction Element
Goal GHG-2: Green buildings. Green and decarbonized buildings are the standard for new construction, major renovations, and existing building retrofits.

GHG-2.1: Clean power access. Maintain access for residents and businesses to carbon- free and renewable energy sources through the Clean Power Alliance and partnerships with Southern California Edison.

GHG-2.2: All electric buildings. Foster a transition to all-electric buildings.

GHG-2.3: Water efficiency. Encourage implementation of both residential and nonresidential voluntary measures of the California Green Building Standards Code (CALGreen) to reduce or eliminate potable water use outdoors.

GHG-2.4: Energy and water efficiency. Improve the energy and water efficiency of new and existing buildings.

GHG-2.5: Productive Roofs. Maintain and distribute guidelines for solar generation or green roofs on available roof space in new developments and major renovations, in alignment with City solar photovoltaic requirements. Encourage the use of green and/or cool roofs in new construction.

GHG-2.6: Passive heating and cooling. Encourage and ensure dissemination of resources for solar energy generation and passive heating and cooling strategies.

GHG-2.7: Efficiency outreach. Educate residents and businesses on available incentive and rebate opportunities to reduce energy and water use.

Goal GHG-3: Municipal buildings and facilities. The environmental efficiencies and performance of municipal buildings, facilities, landscaping, and parks in Culver City is improved.

GHG-3.1: Green rating system. Encourage all new municipal buildings and facilities to meet a minimum LEED silver rating as certified by the US Green Building Council or equivalent green building rating system. Consider feasibility studies for zero net energy use via on-site renewable energy generation and on-site battery storage.

GHG-3.2: Benchmarking. Regularly benchmark the environmental performance of municipal buildings, landscaping, parks, and facilities.

GHG-3.3: Energy efficiency improvements. To reduce operating and maintenance costs, use benchmarking data to identify opportunities for environmental performance improvements through equipment replacements, audits, retro-commissioning, and building retrofits.

GHG-3.4: Waste diversion. Encourage municipal construction projects to achieve 75 percent waste diversion from the landfill.

GHG-3.5: Battery storage. Encourage municipal building and new facility construction and major renovation projects to evaluate the feasibility of incorporating onsite batteries that store electricity from onsite renewable energy generation to supply the building and community with electricity in the event of a disaster.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Goal GHG-4: Decarbonized transportation sector. GHG emissions from the transportation sector are eliminated.

GHG-4.1: Zero emission vehicles. Enable the shift to zero emission vehicles.

GHG-4.2: Public electric vehicle (EV) chargers. Install additional EV chargers at suitable public facilities and curbside, including Downtown parking structures, community parks, and mobility hubs.

GHG-4.3: Multi-unit residential dwelling EV chargers. Develop policies, and incentive/rebate programs designed to encourage installation of additional EV chargers in mixed-use dwellings, single-family homes, workplaces, and shopping centers.

GHG-4-4: Zero-emission vehicle fleet purchases. When buying new City vehicles, purchase zero emission vehicles when feasible.

GHG-4.5: Zero emission fuels. Transitioning existing vehicles and construction and maintenance equipment to zero emission fuels.

Goal GHG-5: Zero Waste. Increase resource capture and decrease waste sent to landfills.

GHG-5.1: Zero waste. Achieve zero waste through adoption of circular economy principles such as recovery, reuse, and sharing of resources.

GHG-5.2: Extended producer responsibility. Support producer responsibility policies that lace a shared responsibility for end-of-life product management on producers, instead of the general public, while encouraging product design changes that minimize negative impacts on human health and the environment.

GHG-5.3: Zero waste textile program. Explore establishing a zero-waste textile initiative and collection system.

Conservation Element
Goal C-2: Biological resources. Habitats for sensitive, threatened, and endangered wildlife species are protected and enhanced to support healthy, diverse ecosystems, and carbon storage.

C-2.4: Tree planting. Plant and maintain trees to sequester carbon, reduce urban heat, provide habitat, and contribute to the city’s character.

Safety Element
Goal S-2: Critical Facilities. Critical facilities have been designed to continue operating after earthquakes and other emergencies or catastrophic events.

S-2.2: Back-up power. Continue to provide back-up power and supplies at critical facilities and identify any critical facilities that may not currently have them to maintain basic functions during emergency situations.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-32 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Goal S-10: Heat and air quality. 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-10.1: Resilient building design. Achieve zero waste through adoption of circular economy principles such as recovery, reuse, and sharing of resources.

S-10.4: Coordinated transportation system. Promote a zero-emission transportation sector to improve air quality.

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would have no impact on wasteful, inefficient, or unnecessary consumption of energy resources, during construction or operation.

Conflict with State or Local Renewable Energy Plan
Threshold ENG-2: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code Updates would conflict with or obstruct a state or local plan for renewable energy or energy efficiency.

Impact Statement 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.

Construction
The construction of new development that could occur under the General Plan Update would utilize construction contractors who must demonstrate compliance with applicable regulations.

Contractors would need to ensure that construction equipment used for development would comply with federal, state, and regional requirements where applicable. With respect to truck fleet operators, the USEPA and NHSTA have adopted fuel-efficiency standards for medium- and heavy-duty trucks that will be phased in over time. Phase 1 heavy-duty truck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through 2018 and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline, depending on the vehicle type.
52 The USEPA and NHTSA also adopted
the Phase 2 heavy-duty truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25 percent reduction in fuel consumption over the 2017 baseline depending on the compliance year and vehicle type.53 These regulations would have an overall

52 U. S. Environmental Protection Agency (USEPA), 2011. Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, 2011. https://www.nhtsa.gov/sites/nhtsa.gov/files/detailed-fact-sheet.pdf. Accessed January 2024. 53 USEPA, 2016. Federal Register / Vol. 81, No. 206, Greenhouse Gas Emissions and Fuel-Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles— Phase 2, 2016.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
beneficial effect on reducing fuel consumption from trucks over time as older trucks are replaced with newer models that meet the standards.

In addition, construction equipment and trucks are required to comply with CARB regulations regarding heavy-duty truck idling limits of five minutes per occurrence and location.

Additionally, CARB regulations regarding in-use off-road equipment require older, less efficient equipment to be replaced or repowered with newer, more efficient models or engines. These regulations would result in an increase in energy savings in the form of reduced fuel consumption from more fuel-efficient engines. Although these requirements are intended to reduce criteria pollutant emissions, compliance with the anti-idling and emissions regulations would also result in the efficient use of construction-related energy. Thus, based on the information above, construction of new development under the General Plan update would comply with existing energy standards and the impact would be less than significant.

Operations
The General Plan Update provides an approach to reducing GHG emissions and facilitates associated benefits of reducing energy demand from community activities, including future development under the Project. Future development that could occur under the General Plan Update would be designed in a manner that is consistent with the relevant goals and policies from the Greenhouse Gas Reduction Element (Goals GHG-2, GHG-3, GHG-4, and GHG-5), Land Use and Community Design Element (Goal LU-16), Parks, Recreation, and Public Facilities Element (Goals PR-6 and PR-7), Infrastructure Element (Goals INF-2, INF-4, INF-5, and INF-7), Conservation Element (Goal C-2), and Safety Element (Goals S-2 and S-10) that are designed to encourage development that results in the efficient use of energy resources. Additionally, new development would comply with Title 24 requirements and CALGreen to reduce energy consumption by implementing energy efficient building designs, pre-wiring residences with electric vehicle charging ports, implementing solar-ready rooftops, reducing indoor and outdoor water demand, and installing energy-efficient appliances and equipment.

With respect to operational transportation-related fuel usage, future development under the General Plan Update would support statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption through relevant goals and policies outlined in the Land Use and Community Design Element (Goals LU-1, LU-11, LU-13, LU-14, and LU-18) and Mobility Element (Goals M-2, M-3, M-4, M-5, and M-8). Additionally, vehicles associated with new development would be required to comply with transportation fuel economy standards, which are designed to result in more efficient use of transportation fuels.

Furthermore, the General Plan Update would not conflict with the 2020-2045 RTP/SCS goals and benefits intended to improve mobility and access to diverse destinations, provide better “placemaking,” provide more transportation choices, and reduce vehicular demand and associated emissions. The 2020-2045 RTP/SCS includes land use and transportation strategies that are intended to reduce VMT and resulting fuel consumption. The applicable land use strategies in the Land Use and Community Design Element (Goals LU-1, LU-11, LU-13, LU-14, and LU-18) include planning for growth around transit 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

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
strategies from the Mobility Element includes managing through a Transportation Demand Management (TDM) Program (Goal M-5) and including promoting active transportation (Goal M-8). The majority of the 2020-2045 RTP/SCS 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.

As discussed in Section 4.16, Transportation, of this PEIR, implementation of the General Plan Update would improve connections to local and regional transit service and encourage the use of alternative modes of transportation, including walking and biking through supportive land use development. The Planning Area contains existing non-vehicular transportation, such as pedestrian and bicycle facilities and transit services. Several transit agencies provide local and regional transit service for residents, employees and visitors of Culver City, including Metro, Culver CityBus, Culver CityRide, Santa Monica Big Blue Bus, Los Angeles Commuter Express, and Los Angeles Metro Bus.

The Culver City Transit Center is located at the southeast corner of the Slauson Avenue and Sepulveda Boulevard intersection north of the Westfield Mall and SR-90. The Transit Center is an outdoor facility that connects multiple bus services, including Metro Lines 110, 108/358, and 217; and Culver CityBus Lines 3, 4, and 6. City Bus Lines 2 and Rapid 6 also provide service to Slauson Avenue and Sepulveda Boulevard which is next to the Transit Center. Services from the Transit Center connect riders to Metro Rail B (Red), A (Blue), C (Green), and E Line (Expo).

Additionally, riders can take Culver CityBus Line 6 or Rapid 6 to the Los Angeles International Airport (LAX) City Bus Center to transfer for free on LAX Shuttle C, which serves all passenger terminals at LAX. Free parking is available at the Culver City Transit Center and the adjacent Westfield Mall parking lot.

The Robertson Transit Hub is located on the east side of Robertson Boulevard between Venice Boulevard and Washington Boulevard. The Transit Hub connects riders to multiple services including Culver City Bus Line 7, Metro Line 17, and Big Blue Bus Line 17. The Transit Hub is adjacent to Metro E Line (Expo) Culver City Station and Metro's Culver City Bike Hub, which provides secure parking for 64 bicycles as well as a variety of bicycle commuter-related services including bike rentals, repairs, classes, and community events. Metro's Culver City Bike Hub also provides a lounge and restroom facility for all rail/bus operators.

The West Los Angeles Transit Center, or the Washington Fairfax Hub, is a terminal located just outside of Culver City limits, directly underneath Interstate Highway 10 on Washington Boulevard and Fairfax Avenue. Although outside of Culver City limits, the West Los Angeles Transit Center serves as an important transit node. Many transit lines begin and terminate at the West Los Angeles Transit Center, including Metro Lines 14, 35, 37, 38, 105, 217, 705 and 780 and Culver City Bus Lines 1 and 4. Refer to Table 4.16-1, Metro Routes (Culver City), in Section

4.16, Transportation, of this PEIR, for a summary of transit service in Culver City.

The General Plan Mobility Element includes policies in-line with the 2020-2045 RTP/SCS to encourage the use of active transportation and transit, and to limit increases in VMT. Land development patterns, including the density and mix of land uses, coupled with the accessibility

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
or alternative modes of transportation (e.g., presence of pedestrian and bicycle infrastructure, transit services), have a direct effect on the number, and length, of vehicle trips. The General Plan Update reduces VMT by encouraging local government and employers to implement TDM policies that promote VMT reductions and by promoting active transportation by improving bicycle and pedestrian infrastructure (Goals M-2, M-3, M-4, M-5, and M-8). Further, the location, design, and land uses from growth anticipated under the General Plan Update would implement land use and transportation strategies from the Land Use and Community Design Element related to reducing vehicle trips for residents and employees of the City through 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 (Goals LU-1, LU-11, LU-13, LU-14, LU-16, and LU-18).

The General Plan Update seeks to intensify and mix land uses on key segments of the commercial corridors and allow for new residential and mixed-use development within the City’s industrial areas by distributing growth along corridors, including in areas well served by transit. As discussed under Impact Statement ENG-1, the General Plan Update focuses on 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 General Plan Update seeks to intensify and mix land uses on key segments of the commercial corridors and allow for new residential and mixed- use development within the City’s industrial areas. 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 incremental infill and 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 IOF. The Mobility Element establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi-modal circulation which would result in 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.

The General Plan Update outlines strategies for greater integration of uses in different parts of the city and a better connection between employment and residential uses. It recognizes the physical elements that help define the character of Culver City, including existing residential neighborhoods, special study areas, and industrial and transit corridors. This structure helps establish a clear multi-modal network throughout the city by focusing on both community destinations as well as the efficiency, safety, and convenience of the modes of transportation in between. Higher densities, especially in mixed-use designations, increase capacity for residential development near community-serving commercial, retail, and office uses as well as schools, parks, and recreational facilities. In addition, proposed improvements to the bicycle, pedestrian, and road networks would make it easier for residents to travel throughout the community.

Therefore, the Project would not conflict with RTP/SCS land use and transportation strategies that are intended to reduce VMT and resulting fuel consumption.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Based on the information above, operation of new development under the General Plan Update would comply with plans for energy efficiency and renewable energy and this impact would be less than 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 state and local plans for renewable energy or energy efficiency. Therefore, future development under 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.

Applicable Proposed General Plan Goals and Policies
See goals and policies provided under Threshold ENG-1.

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would have no impact on conflicts with or obstruction of a state or local plan for renewable energy or energy efficiency.

4.5.5 Cumulative Impacts Analysis
The Project along with other cumulative projects would incrementally contribute to the need for regional energy production and distribution facilities. However, as with the Project, all cumulative development would be required to incorporate energy conservation features to comply with applicable mandatory regulations including CALGreen Code and state energy standards under Title 24. Further, electricity and natural gas facilities are operated and maintained by private utility companies that plan for and accommodate anticipated growth. As described above in ENG-1, implementation of the General Plan Update would result in an increase of energy and natural gas usage that would generally be served by existing supply and infrastructure capacity and impacts would be less than significant. All cumulative development projects and development under the Project would be required to comply with CALGreen and Title 24 energy efficiency requirements and other regulations, which would reduce energy consumption by promoting energy efficiency and the use of renewable energy, and incorporate mitigation measures, if applicable. As such, the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy nor would it result in a cumulatively considerable contribution to energy use and impacts would be less than significant.

The Project along with other cumulative projects would incrementally contribute to the demand for transportation fuels and would be expected to increase overall VMT. While growth within the Planning Area and region is anticipated to increase the demand for transportation fuels, the Project, as well as other cumulative development projects would be required to demonstrate consistency with federal and state fuel efficiency goals and incorporate, if applicable, any mitigation measures as required under CEQA. The Project would intensify and mix land uses on

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-37 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
key segments of the commercial corridors and allow for new residential and mixed-use development within the City’s industrial areas. 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. Siting land use development projects at infill sites is consistent with the state’s overall goals to reduce VMT pursuant to SB 375. Additionally, the General Plan Update reduces VMT by encouraging local government and employers to implement TDM policies that promote VMT reductions and by promoting active transportation by improving bicycle and pedestrian infrastructure. Therefore, the Project would be consistent with the guidance provided in the SCAG 2020-2045 RTP/SCS to reduce transportation fuel and VMT. Related projects would also need to demonstrate consistency with these goals and incorporate project design features or mitigation measures as required under CEQA, which would also ensure related projects contribute to transportation energy efficiency. Therefore, the impact on the implementation of a state or local plan for renewable energy or energy efficiency would be less than cumulatively considerable. As the Project would incorporate land use characteristics consistent with state goals for reducing VMT, the Project would not have a cumulatively considerable impact related to transportation energy, and impacts would be less than significant.

4. Environmental Impact Analysis

4.5. Energy
General Plan 2045 and Zoning Code Update Project 4.5-38 SCH No. 2022030144 City of Culver City March 2024
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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.6-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.6 Geology and Soils

4.6.1 Introduction
This section provides an analysis of the potential environmental impacts on geology and soils from implementation of the Project, including potential impacts related to risk of geologic hazards, soil erosion or loss of topsoil, unstable soils, expansive soils, and paleontological resources. The section provides context regarding the existing soils and geologic conditions, including geologic and seismic hazards in the Planning Area, as well as relevant federal, state, and local regulations and programs.

4.6.2 Environmental Setting
Geological Setting
The Planning Area is located within the Peninsular Ranges Geomorphic Province and Los Angeles Basin. The Peninsular Ranges are characterized by northwest-trending blocks of mountain ridges and sediment-floored valleys. The dominant geologic structure features are northwest-trending fault zones that either fade out to the northwest or terminate at east trending faults that form the southern margin of the Transverse Ranges. The Los Angeles Basin is bound by the San Gabriel Foothills to the north; the Santa Ana Mountains and San Joaquin Hills to the east and southeast; and the Santa Monica Mountains to the northwest. Erosion of the surrounding mountains over time has resulted in the deposition of alluvial materials (unconsolidated sediments) in low-lying areas by the Los Angeles River and Ballona Creek.

The predominant rock type that underlies the Peninsular Ranges province is a Cretaceous age igneous rock (granitic rock) referred to as the Southern California batholith. Older Jurassic age metavolcanic and metasedimentary rocks and older Paleozoic limestone, altered schist, and gneiss are present within the province. Cretaceous
-a
ge marine sedimentary rocks and younger
Tertiary
-
age rocks comprised of volcanic, marine, and non
-m
arine sediments overlie the older
rocks. More recent Quaternary sediments, primarily of alluvial origin, comprise the low- lying
valley and drainage areas within the region.

The Planning Area is located on the western side of the Los Angeles Basin, approximately 1.5 miles from the Pacific Ocean. The topography of the Planning Area is relatively flat with areas of rolling hills that vary in elevation from 40 feet above mean sea level (amsl) on the west to approximately 100 feet amsl in the central part. The highest point within the Planning Area is in Baldwin Hills, rising to above 400 feet amsl.

A review of the geologic setting of the Planning Area indicate that younger alluvium deposits (Qa) exist within the northern, southern, and western portions of the Planning Area while older alluvium (Qoa), Paleosol (Qop), artificial fill (af), and Sand Pedro Sand (Qsp) sediments are present in the southern portion. Lastly, landslide debris (Qls) and Inglewood Formation deposits (Qi) are also found within the northeastern portion of the city.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Soils and Geologic Hazards
Surface soils are mapped and classified by the United States Department of Agriculture’s (USDA’s) Natural Resource Conservation Service (NRCS). While the following describes the more predominant soil types within the Planning Area, the general classifications could be grouped into more specific soil types by location, climate, and slope depending on localized conditions.

Figure 4.6-1, Soils Types within the Planning Area, shows the types and locations of the different soil types throughout the Planning Area. As shown in Figure 4.6-1, there are four predominant soil types within the Planning Area, which consist of the Cropley-Urban land complex, Longshore- Pachic Haploxerolls complex, Mined Land/Oil Wells, and Urban Land. The most dominant soil type is Urban Land, which is further classified into ten subcategories, as shown in Figure 4.6-1.

Expansive Soils
Expansive soils include clay minerals that are characterized by their ability to undergo significant volume change (shrink or swell) due to variation in moisture content. Changes in soil moisture content can result from rainfall, irrigation, pipeline leakage, surface drainage, perched groundwater, drought, or other factors. Expansive soils are typically very fine-grained and have a high percentage of clay. Structural damage may occur incrementally over a prolonged period, usually as a result of inadequate soil and foundation engineering or the placement of structures directly on expansive soils. Soils with high clay content, such as clayey soils in Baldwin Hills, are subject to significant volume change due to variation in soil moisture content. 1 Subsidence and Differential Settlement
Subsidence is characterized as a sinking of ground surface relative to surrounding areas and can generally occur where deep soil deposits are present. Subsidence in areas of deep soil deposits is typically associated with groundwater withdrawal or other fluid withdrawal from the ground such as oil. Subsidence can result in ground cracks and damage to subsurface vaults, pipelines, and other improvements. According to the City’s Multi-Jurisdictional Hazard Mitigation Plan (MJHMP), prepared in collaboration with Culver City Unified School District (CCUSD) and approved by the California Office of Emergency Services (CalOES) and Federal Emergency Management Agency (FEMA) in 2017, the Planning Area does not have any historical occurrences of land subsidence.
2 Settlement is the lowering of the land-surface elevation as a result of loading (e.g., placing heavy loads, typically fill or structures), which often occurs with the development of a site. Settlement or differential (i.e., unequal) settlement could occur if buildings or other improvements are built on low-strength foundation materials (including imported fill) or if improvements straddle the boundary between different types of subsurface materials (e.g., a boundary between native material and fill). Although settlement generally occurs slowly enough that its effects are not dangerous to inhabitants, it can cause significant building damage over time.

1 Culver City. 2017. IOF Specific Plan Project Draft Environmental Impact Report. Available at https://www.culvercity.org/files/assets/public/documents/city-manager/inglewood-oil-field/environmental- review-process/toc091117.pdf. Accessed March 2023.
2 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan.

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.

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
Soils
Cropley-Urban land complex, 0 to 5 percent
slopes
Longshore-Pachic Haploxerolls complex, 20 to 55
percent slopes
Mined land, oil wells
Urban land, frequently flooded, 0 to 5 percent
slopes
Urban land-Anthraltic Xerorthents, loamy
substratum-Grommet complex, 0 to 5 percent
slopes
Urban land-Aquic Xerorthents, graded-Pacheco,
warm complex, 0 to 2 percent slopes
Urban land-Ballona-Typic Xerorthents, fine
substratum complex, 0 to 5 percent slopes
Urban land-Biscailuz-Hueneme, drained complex,
0 to 2 percent slopes
Urban land-Biscailuz-Pico complex, 0 to 2 percent
slopes
Urban land-Sepulveda-Longshore, graded
complex, 3 to 12 percent slopes
Urban land-Typic Xerorthents, terraced complex,
10 to 35 percent slopes
Urban land-Typic Xerorthents, terraced-Windfetch
complex, 2 to 9 percent slopes
Urban land-Windfetch-Centinela complex, 0 to 5
percent slopes
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).

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.

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
Soils
Cropley-Urban land complex, 0 to 5 percent
slopes
Longshore-Pachic Haploxerolls complex, 20 to 55
percent slopes
Mined land, oil wells
Urban land, frequently flooded, 0 to 5 percent
slopes
Urban land-Anthraltic Xerorthents, loamy
substratum-Grommet complex, 0 to 5 percent
slopes
Urban land-Aquic Xerorthents, graded-Pacheco,
warm complex, 0 to 2 percent slopes
Urban land-Ballona-Typic Xerorthents, fine
substratum complex, 0 to 5 percent slopes
Urban land-Biscailuz-Hueneme, drained complex,
0 to 2 percent slopes
Urban land-Biscailuz-Pico complex, 0 to 2 percent
slopes
Urban land-Sepulveda-Longshore, graded
complex, 3 to 12 percent slopes
Urban land-Typic Xerorthents, terraced complex,
10 to 35 percent slopes
Urban land-Typic Xerorthents, terraced-Windfetch
complex, 2 to 9 percent slopes
Urban land-Windfetch-Centinela complex, 0 to 5
percent slopes
Culver City General Plan 2045
Figure 4.6-1
Soil Types within the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021; CGS, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Regional and Local Faulting
Seismic hazards occur when accumulated stress between portions of the earth’s crust is released, resulting in the sudden ground movement perceived as an earthquake. Primary seismic hazards are the direct result of the release of this accumulated stress and are typically characterized as earthquake fault rupture (displacement of the ground surface at the earthquake site) and seismic shaking (the ground movement itself, which can cause damage a significant distance from the earthquake site). Earthquakes can also cause secondary seismic hazards, such as liquefaction and earthquake-induced landslides.

The Planning Area is located within Southern California, a tectonically active region with high seismic activity. Figure 4.6-2, Regional Earthquake Faults, shows the various regional faults located throughout the greater Los Angeles region, including those within the Planning Area.

Seismic hazards relate to faults, which are areas where large sections of the earth’s surface called tectonic plates move past each other. The deformation of the plates and the accumulated stress between them causes faults in a wider area than the precise boundary between plates. In California, the Pacific and North American plates are sliding horizontally past each other, creating what is known as a “strike-slip fault.”
3 The boundary between the two plates is known as the San Andres Fault, although the stress caused by this movement has created thousands of fault areas throughout the state. Most of California lies on the North American plate, although the coastal areas of Central and Southern California, including Culver City, sit on the Pacific Plate.

Locally, there are a number of faults in the vicinity of the Planning Area, which include the Overland Fault, Charnock Fault, Newport-Inglewood Fault, Palos Verdes Fault, Sierra Madre Fault, Whittier-Elsinore Fault, and the San Andrea Fault (see Figure 4.6-2). While the Overland Fault, Charnock Fault, and Newport-Inglewood Fault traverse the Planning Area, only the Newport- Inglewood Fault is capable of producing earthquakes that could cause significant ground shaking within the Planning Area.
4 The local faults capable of producing earthquakes that could cause significant ground shaking within the Planning Area are described in greater detail below:

Newport-Inglewood Fault Zone. The Newport-Inglewood Fault Zone, a designated Alquist-Priolo fault, runs from the Santa Monica Mountains near Beverly Hills southeast to Newport Beach, passing through the northeastern portion of the Planning Area, including the Hayden Tract. The fault zone is made up of three distinct segments and several faults and fractures and is responsible for the topography of the Blair Hills and Baldwin Hills area and nearby Ladera Heights. The Newport-Inglewood Fault Zone caused the 1933 Long Beach earthquake, which was the last major event along this fault. The Southern California Earthquake Center estimates that a future major event along this fault could measure 6.0 to 7.4 on the moment magnitude scale.
5 As a major fault passing through the city, it can cause surface rupture in the community.

3 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 4 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 5 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023.

Culver City General Plan 2045
Figure 4.6-2
Regional Earthquake Faults
SOURCE: City of Culver City, Information Technology Department, GIS; March 3, 2016D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling N

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Palos Verdes Fault Zone. The Palos Verdes Fault Zone extends from the Palos Verdes peninsula south out into the Pacific Ocean, running approximately 10 miles from the Planning Area at its closest point.6 This fault zone has not produced a significant earthquake in recorded history, although the last event is believed to have happened within the past 10,000 years. The Southern California Earthquake Data Center estimates that this fault can produce an earthquake measuring 6.0 to 7.0 or more on the moment magnitude scale. Due to its location, this fault zone is unlikely to result in fault surface rupture in the Planning Area, but it can produce earthquakes that could cause significant ground shaking in the Planning Area.

Sierra Madre Fault Zone. The Sierra Madre Fault Zone runs along the southern edge of the San Gabriel Mountains from La Canada-Flintridge to Claremont, approximately 16 miles from the Planning Area at its closest point.
7 The last major event along the Sierra Madre Fault Zone is believed to have happened within the past 10,000 years, although no specific event is known.

The Southern California Earthquake Data Center estimates that it can produce an event measuring 6.0 to 7.0 on the moment magnitude scale. Due to its location, this fault zone is unlikely to result in fault surface rupture in the Planning Area, but it can produce earthquakes that could cause significant ground shaking in the Planning Area.

Whittier-Elsinore Fault Zone. The Whittier-Elsinore Fault Zone runs from the Chino Hills region to the California-Mexico border and is approximately 22 miles from the Planning Area at its closest point.
8 The last major event along this fault was a 1910 earthquake measuring an estimated 6.0 on the moment magnitude scale. This fault is believed to cause a major seismic event approximately 250 years ago with a probable magnitude of 6.5 to 7.5.9 Due to its location, this fault zone is unlikely to result in fault surface rupture in the Planning Area, but it can produce earthquakes that could cause significant ground shaking in the Planning Area.

San Andreas Fault Zone. The San Andreas Fault is the largest and most well-known of California’s faults, which runs from Cape Mendocino to the Salton Sea. The fault is approximately 40 miles from the Planning Area at its closest point.
10 It has caused numerous major earthquakes
throughout California’s history, including the 1906 San Francisco earthquake and the 1989 Loma Prieta earthquake. The central portion of the San Andreas Fault was responsible for an earthquake measuring an estimated 7.9 on the moment magnitude scale, the strongest in California’s recorded history in 1857 near Parkfield (approximately 170 miles from the Culver City). The Southern California Earthquake Data Center estimates that a future major event along the southern part of the San Andreas Fault could measure 6.8 to 8.0 on the moment magnitude scale.

Due to its location, this fault zone is unlikely to result in fault surface rupture in the Planning Area, but it can produce earthquakes that could cause significant ground shaking in the Planning Area.

6 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 7 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 8 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 9 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 10 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
A major earthquake along any of these faults could cause significant damage in the Planning Area. As detailed in the MJHMP, the list above is not a comprehensive list of all known faults capable of producing a significant earthquake near the city. There is a risk of earthquakes from faults that have not yet been discovered. For example, the 1994 Northridge earthquake caused more property damage than any other earthquake in the United States and was the ninth most damaging earthquake in history, occurred along a then-undiscovered fault. 11 The Northridge
Earthquake measured 6.7 on the moment magnitude scale, had a Mercalli intensity of IX, killed 57 people, caused over 5,000 injuries, spawned multiple strong aftershocks, caused an estimated $20 billion or more in damages, and caused extensive damage in Culver City. 12 The Interstate 10
overpasses at La Cienega Boulevard, Venice Boulevard, Fairfax Avenue, and Washington Boulevard, immediately north of the city, were significantly damaged and had to be rebuilt.

Alquist-Priolo Earthquake Fault Zones
The purpose of the Alquist-Priolo Earthquake Fault Zones Act is to prevent the construction of buildings used for human occupancy across the surface trace of active faults. The law requires the State Geologist to establish regulatory zones (known as Earthquake Fault Zones [EFZs]) around the surface traces of active faults and to issue appropriate maps. The zones vary in width and average about one-quarter mile wide. For the purposes of the Act, an active fault is one that has ruptured in the last 11,000 years. As shown in Figure 4.6-3, Alquist-Priolo Fault Zones within the Planning Area, there are identified Alquist-Priolo fault zones associated with the Newport- Inglewood fault within the northeastern portion of the Planning Area, which runs through the Hayden Tract. As stated above, the Newport-Inglewood Fault Zone is a designated Alquist-Priolo Fault Zone, which extends from the Santa Monica Mountains to Newport Beach.

Seismic Hazards
As discussed above, Southern California is a seismically active region, where the Planning Area is located between two major, active faults: the Newport-Inglewood Fault to the east and northeast and the Palos Verdes Fault to the west and southwest. The predominant tectonic activity associated with these and other faults within the regional tectonic framework is right-lateral, strike-slip and/or reverse movement. Other potentially active fault zones in proximity to the Planning Area include the Sierra Madre Fault, Whittier-Elsinore Fault, and the San Andrea Fault.

An earthquake event on one of the active or potentially active faults near the Planning Area could result in earthquake damage to structures caused by surface rupture, ground shaking, ground failure, land sliding and slope instability, and/or inundation from seiche or tsunami. The level of damage in the Planning Area resulting from an earthquake would depend upon the magnitude of the event, the epicenter distance from the Planning Area, the response of geologic materials, and the strength and construction quality of structures. Seismically induced water inundation is described in Section 4.9, Hydrology and Water Quality, of this Draft PEIR.

11 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. 12 Culver City and CCUSD. 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed March 2023. #
City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Alquist Priolo Fault
Alquist Priolo Fault Zone
City of Los Angeles
West Los
Angeles
College
Ballo
na
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
City of Los Angeles
GreenValleyCir
°00 .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.

Washing
ton Blvd.

Unincorporated
County
Venice Blvd.

La Cie
nega Blvd.

Venice Blvd.

Wa
shin
gton
Blvd.

La Cienega Blvd
.

Sepulv
eda Blvd.

Culver City General Plan 2045
Figure 4.6-3
Alquist-Priolo Fault Zones within the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021; CGS, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Ground Shaking
An earthquake of moderate to high magnitude generated within the region could cause significant ground shaking within the Planning Area. The exact degree of shaking experienced at a given location would depend on a host of site-specific factors, such as: the magnitude of the seismic event, the duration of the seismic event, the distance from a given site to the zone of rupture (i.e., hypocenter), local site-specific geologic conditions (i.e., nature, thickness, and extent of underlying soil and/or bedrock), and broader, often regional geologic factors such as basin geometry. In general, the severity of seismic ground shaking tends to abate with increasing distance from the event hypocenter. Seismic ground shaking, if sufficiently intense and sustained, can result in significant damage to, or catastrophic failure of buildings or other human-made structures.

Surface Fault Rupture
Surface fault rupture, or a break in the ground’s surface and associated displacement caused by fault movement, is directly correlated to earthquake magnitude. Earthquakes having a magnitude of 5.5 or greater are generally required for surface fault rupture to occur. The Newport-Inglewood Fault is capable of causing surface fault rupture within the Planning Area, where the areas at risk are identified and mapped under the Alquist-Priolo Earthquake Fault Zones program, as shown in Figure 4.6-3.

Ground Failure
Landslides and Slope Instability
Slope failures, commonly referred to as landslides, include many phenomena that involve the downslope displacement and movement of material, either triggered by static (i.e., gravity) or dynamic (i.e., earthquake) forces. A slope failure is a mass of rock, soil, and debris displaced downslope by sliding, flowing, or falling. Exposed rock slopes undergo rockfalls, rockslides, or rock avalanches, while soil slopes experience shallow soil slides, rapid debris flows, and deep-seated rotational slides. Landslides may occur on slopes of 15 percent or less; however, the probability is greater on steeper slopes that exhibit historic landslide features such as scarps, slanted vegetation, and transverse ridges. Landslide-susceptible areas are characterized by steep slopes and downslope creep of surface materials. Debris flows consist of a loose mass of rocks and other granular material that, if saturated and present on a steep slope, can move downslope. The rate of rock and soil movement can vary from a slow creep over many years to a sudden mass movement.

Slope stability can depend on many complex variables. The geology, structure, and amount of groundwater in the slope affects slope failure potential, as do external processes (i.e., climate, topography, slope geometry, and human activity). Earthquake motions can induce significant horizontal and vertical dynamic stresses in slopes that can trigger failure. Earthquake-induced landslides can occur in areas with steep slopes that are susceptible to strong ground motion during an earthquake.

As shown in Figure 4.6-4, Potential Landslide Zones Withinin the Planning Area, the eastern portion of the Planning Area, including the Baldwin Hills, Blair Hills, and Culver Crest neighborhoods are at an elevated landslide risk. Past landslides in part of the Planning Area have been comparatively small, although still potentially large enough to significantly damage or destroy buildings.

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); CGS (2019).

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.

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
Potential Landslide Zone
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); CGS (2019).

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.

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
Potential Landslide Zone
Culver City General Plan 2045
Figure 4.6-4
Potential Landslide Zones within the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021; CGS, 2019D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Subsidence/Liquefaction
Liquefaction occurs when the force of an earthquake’s shaking causes groundwater to mix with the soil. This mixture temporarily becomes fluid and loses its strength, which may in turn, cause buildings and other structures built on or in it to tilt, collapse, or otherwise suffer damage.

Liquefaction can also occur independently of an earthquake if any other sudden and significant stress causes the mixing of groundwater and soil. The risk of liquefaction depends on many different factors, including the height of the groundwater table and the types of soil in an area.

Most of the city is in an area of elevated liquefaction risk, as shown in Figure 4.6-5, Potential Liquefaction Zones in the Planning Area. Only a small portion of the Sphere of Influence (SOI) within West Los Angeles College is within a potential liquefaction zone. While the likelihood of liquefaction occurring in a future seismic event is dependent on several factors, there is a possibility for widespread and damaging liquefaction in the community.

Lateral Spreading
Ground cracking, ground lurching and lateral spreading are secondary features resulting from strong to moderately strong ground shaking and may be associated with liquefaction. Ground cracking usually occurs in near-surface materials, reflecting differential compaction or liquefaction of underlying materials. The potential for ground cracking exists in those areas that have a moderate to high potential for liquefaction. Ground lurching results when soft, water- saturated surface soils are thrown into undulatory motion. Lateral spreading (a form of landslide) is referred to as limited displacement ground failure, often associated with liquefaction. Compact surface materials may slide on a liquefied or low shear strength layer at a shallow depth, moving laterally several feet down slopes of less than two degrees. Such a condition may be present where conditions conducive to shallow liquefaction exist. Therefore, areas near Ballona Creek, which are in the potential liquefaction zone, may also be subject to lateral spreading.

Paleontological Resources
Paleontology is a branch of geology that studies the life forms of the past, especially prehistoric life forms, through the study of plant and animal fossils. Paleontological resources represent a limited, non-renewable, and impact-sensitive scientific and educational resource. As defined in this section, paleontological resources are the fossilized remains or traces of multi-cellular invertebrate and vertebrate animals and multi-cellular plants, including their imprints from a previous geologic period and are greater than 5,000 years in age. Fossil remains such as bones, teeth, shells, and leaves are found in the geologic deposits (rock formations or geologic units) where they were originally buried. Paleontological resources include not only the actual fossil remains, but also the fossil localities, and the geologic formations containing those localities.

#
City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Potential Liquefaction Zone
City of Los Angeles
West Los
Angeles
College
Ballo
na
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.

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.

Washing
ton Blvd.

Unincorporated
County
Venice Blvd.

La Cie
nega Blvd.

Venice Blvd.

Wa
shin
gton
Blvd.

La Cienega Blvd
.

Sepulv
eda Blvd.

Culver City General Plan 2045
Figure 4.6-5
Potential Liquefaction Zones in the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021; CGS, 2019D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Natural History Museum of Los Angeles County Records Search, Geologic Map and Literature Review
Results of the archival research through the Natural History Museum of Los Angeles County (LACM) indicate that four known fossil localities have been previously identified within the city.

In addition, eight other fossil localities (LACM 1159, 3366, 3367, 3368, 3369, 3370, 4232, and 4247) are located outside the city (either immediately adjacent or within several miles) but from the same sedimentary deposits (older Quaternary alluvium deposits and the San Pedro Sand) that occur within and throughout the city.
13 The resources encountered in the city and within
the vicinity include the remains of a mammoth, mastodon, camel, human, horses, saber-toothed cat, duck, and multiple invertebrates (clams, gastropods, etc.).14 The geologic map and literature review indicate that within the northern, southern, and western portions of the city, younger alluvium deposits (Qa) exist. Additionally, in the southern portion of the city, older alluvium (Qoa), Paleosol (Qop), artificial fill (af), and Sand Pedro Sand (Qsp) sediments are present. Lastly, landslide debris (Qls) and Inglewood Formation deposits (Qi) are also found within the northeastern portion of the city. In sum, the geologic map and literature review indicate the following:
• The northern, southern, and western portions of the city have a low to high potential for yielding fossil localities associated with younger alluvium. The deeper the excavations extend in these portions of the city which may reach into older alluvium deposits, the higher the chances are for encountering fossils.
• The northeastern portion of the city has a high potential for producing fossils associated with the Inglewood Formation and an undetermined potential for encountering landslide debris.
• The southern portion of the city has a high potential for yielding fossiliferous deposits associated with older alluvium and San Pedro Sand. Paleosol soils also exist within the southern portion of the city; however, the potential for finding fossils is undetermined.

Lastly, artificial fill is also found within the southern portion of the city, but there is no potential for finding fossils since these are modern and disturbed soils.

Other Paleontological Resources Identified within the City Other paleontological resources have been identified recently within the city that were discovered at depth during construction of private redevelopment projects. For example, in 2018, several paleontological specimens (e.g., gastropod and clam shells) were recovered during construction of a mixed-use project at depths of 25 to 41 feet below ground surface (bgs).15 In the same year at a separate private redevelopment project, approximately 100 specimens consisting of marine mammals (otariid, or seals; and cetacean, or whales or dolphins), terrestrial

13 Mcleod, Samuel, 2019. Paleontological Resources for the Proposed Culver City General Plan Update Project, in Culver City, Los Angeles County, Project Area. Letter on file at ESA. 14 Mcleod, Samuel, 2019. Paleontological Resources for the Proposed Culver City General Plan Update Project, in Culver City, Los Angeles County, Project Area. Letter on file at ESA. 15 ESA, 2018. Archaeological and Paleontological Monitoring Report for the Ivy Station Project, City of Culver City and City of Los Angeles, County of Los Angeles California. Prepared for: Culver City Triangle Investor, Inc., c/o Lowe Enterprises Real Estate Group.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
mammals (Bison sp.), invertebrate, and plant fossils, were encountered between 15 feet to 32 feet bgs.16 Microvertebrate fossils were also identified through screening of sediments at this same property, and included amphibians, snakes, gophers, kangaroo rats, harvest mice, wood rats, voles, and rabbits.

During construction of another redevelopment project in the city, more than 20 fossilized bone specimens (including teeth, a patella, vertebrae, and miscellaneous long bones) and multiple invertebrates (e.g., clams, gastropods, etc.) were recovered between 20 to 55 feet bgs in undisturbed sediments. From this same property, a partial mandible (lower jawbone) of a saber- toothed cat (Smilodon) was also recovered from approximately 28 to 32 feet below the surface.
17 4.6.3 Regulatory Framework
This section provides the relevant federal, State, regional, and local regulations applicable to the Project.

Federal
United States Geological Survey Landslide Hazard Program The United States Geological Survey (USGS) created the Landslide Hazard Program in the mid- 1970s; the primary objective of the program is to reduce long-term losses from landslide hazards by improving our understanding of the causes of ground failure and suggesting mitigation strategies. The federal government takes the lead role in funding and conducting this research, whereas the reduction of losses due to geologic hazards is primarily a state and local responsibility. In Los Angeles County, plans and programs designed for the protection of life and property are coordinated by the Los Angeles County Office of Emergency Management.

Earthquake Hazards Reduction Act
The Earthquake Hazards Reduction Act was enacted in 1977 to “reduce the risks to life and property from future earthquakes in the United States through the establishment and maintenance of an effective earthquake hazards and reduction program.” To accomplish this, the Act established the National Earthquake Hazards Reduction Program (NEHRP). NEHRP implementation activities are conducted primarily by FEMA. This program was substantially amended by the NEHRP Reauthorization Act of 2004 (Public Law 108-360).

NEHRP’s mission includes improved understanding, characterization, and prediction of hazards and vulnerabilities; improvement of building codes and land use practices; risk reduction through post-earthquake investigations and education; development and improvement of design and construction techniques; improvement of mitigation capacity; and accelerated application of research results. The NEHRP designates the National Institute of Standards and

16 ESA, 2021. Archaeological and Paleontological Monitoring Report for the 8777 Washington Project; Culver City, County of Los Angeles, California. Prepared for: CLPF-8777 Washington, L.P. 17 ESA, 2020. Progress Report - Archaeological and Paleontological Construction Monitoring Services for the Culver Studios Innovation Plan Project; Culver City, Los Angeles County, California. Prepared for The Culver Studios Owner, LLC.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Technology (NIST) as the lead agency of the program. As lead agency, it develops, evaluates, and tests earthquake resistant design and construction practices for implementation in the building codes and engineering practice. Under NEHRP, FEMA is responsible for developing earthquake risk reduction tools and promoting their implementation, as well as supporting the development of disaster-resistant building codes and standards. USGS monitors seismic activity, provides earthquake hazard assessments, and conducts and supports targeted research on earthquake causes and effects. Programs under NEHRP help inform and guide planning and building code requirements such as emergency evacuation responsibilities and seismic code standards.

Disaster Mitigation Act of 2000
The Disaster Mitigation Act of 2000 (DMA2K) (Public Law 106-390) amended the Robert T.

Stafford Disaster Relief and Emergency Assistance Act of 1988 to establish a Pre-Disaster Mitigation (PDM) program and new requirements for the federal post-disaster Hazard Mitigation Grant Program (HMGP). DMA2K encourages and rewards local and state pre-disaster planning. It promotes sustainability and seeks to integrate state and local planning with an overall goal of strengthening statewide hazard mitigation. This enhanced planning approach enables local, tribal, and state governments to identify specific strategies for reducing probable impacts of natural hazards such as floods, fire, and earthquakes. In order to be eligible for hazard mitigation funding after November 1, 2004, local governments are required to develop a Hazard Mitigation Plan that incorporates specific program elements of the DMA2K law.

Antiquities Act
Federal regulations regarding paleontological resources are generally applicable to a project if that project includes federally owned or federally managed lands or involves a federal agency license, permit, approval, or funding. The Antiquities Act of 1906 (54 U.S.C. 320301-320303 and 18 U.S.C. 1866(b)) requires protection of historic landmarks, historic and prehistoric structures, as well as other objects of historic or scientific interest on federally administered lands, the latter of which would include fossils. The Antiquities Act establishes a permit system for the disturbance of any object of antiquity on federal land and also sets criminal sanctions for violation of these requirements. In 1958, the Federal-Aid Highways Act of 1958 extended the Antiquities Act to specifically apply to paleontological resources.

Code of Federal Regulations, Title 40
Title 40: Protection of Environment is the section of the Code of Federal Regulations (CFR) that deals with the United States Environmental Protection Agency’s (USEPA) mission of protecting human health and the environment. Title 40 Code of CFR Section 1508.2 identifies paleontological resources as a subset of scientific resources.

National Pollutant Discharge Elimination System Program The National Pollutant Discharge Elimination System (NPDES) Program has been responsible for substantial improvements to our nation and state’s water quality since 1972. The NPDES permit sets erosion control standards and requires implementation of nonpoint source control of surface drainage through the application of a number of Best Management Practices (BMPs).

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NPDES permits are required by Section 402 of the Clean Water Act.18 See Section 4.9, Hydrology and Water Quality, for more information about the NPDES Program.

State
Alquist-Priolo Earthquake Fault Zoning Act
The Alquist-Priolo Earthquake Fault Zoning Act (formerly the Alquist-Priolo Special Studies Zone Act) was signed into law December 22, 1972 (revised in 1994) and codified into State law in the California Public Resources Code (PRC) as Division 2, Chapter 7.5 to address hazards from earthquake fault zones. The primary purpose of this act is to mitigate the hazard of fault rupture by prohibiting the location of structures for human occupancy across the trace of an active fault.

This act was a direct result of the 1971 San Fernando Earthquake, which was associated with extensive surface fault ruptures that damaged numerous homes, commercial buildings, and other structures. The act requires the State Geologist (California Geologic Survey) to delineate regulatory zones known as “earthquake fault zones” along faults that are “sufficiently active” and “well defined”, and to issue and distribute appropriate maps to all affected cities, counties, and state agencies for their use in planning and controlling new or renewed construction.

Pursuant to this act and as stipulated in Section 3603(a) of the California Code of Regulations, structures for human occupancy are not permitted to be placed across the trace of an active fault. The act also prohibits structures for human occupancy within 50 feet of the trace of an active fault, unless proven otherwise by an appropriate geotechnical investigation and report that the development site is not underlain by active branches of the active fault, as stipulated in Section 3603(a) of the California Code or Regulations. Furthermore, the act requires that cities and counties withhold development permits for sites within an earthquake fault zone until geologic investigations demonstrate that the sites are not threatened by surface displacement from future faulting, as stipulated in Section 3603(d) of the California Code of Regulations.

California Building Code
The California Building Code (CBC), which is codified in Title 24 of the California Code of Regulations, Part 2, was promulgated to safeguard the public health, safety, and general welfare by establishing minimum standards related to structural strength, means of egress facilities, and general stability of buildings. The purpose of the CBC is to regulate and control the design, construction, quality of materials, use/occupancy, location, and maintenance of all buildings and structures within its jurisdiction. Title 24 is administered by the California Building Standards Commission, which, by law, is responsible for coordinating all building standards. Under State law, all building standards must be centralized in Title 24 or those standards are not enforceable. The provisions of the CBC apply to the construction, alteration, movement, replacement, location, and demolition of every building or structure or any appurtenances connected or attached to such buildings or structures throughout California.

The 2022 edition of the CBC is based on the 2021 International Building Code (IBC) published by the International Code Council. The code is updated triennially, and the 2022 edition of the CBC

18 United States Environmental Protection Agency (USEPA), Clean Water Act, Section 402: National Pollutant Discharge Elimination System. Available at: https://www.epa.gov/cwa-404/clean-water-act-section-402-national- pollutant-discharge-elimination-system. Accessed March 2023.

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was published by the California Building Standards Commission on July 1, 2022, and became effective January 1, 2023. Every three years, the State adopts new codes (known collectively as the California Building Standards Code) to establish uniform standards for the construction and maintenance of buildings, electrical systems, plumbing systems, mechanical systems, and fire and life safety systems. Sections 17922, 17958, and 18941.5 of the California Health and Safety Code require that the latest edition of the California Building Standards Code apply to local construction 180 days after publication. The significant changes to Title 24 in the 2022 edition can be found at California Department of General Services website. 19 All proposed structures are required to be designed and constructed in accordance with the 2022 edition of the CBC, as amended by the City of Culver City, and with other applicable laws and regulations. Specific relevant CBC requirements, in addition to designing and constructing buildings to code, include but are not limited to, the following:

1. CBC Section 1803 (Detailed Geotechnical Investigations): CBC Section 1803 requires the preparation of a detailed geotechnical investigation, prepared to ASTM standards by a State licensed Geotechnical Engineer and using ASTM procedures, prior to design and construction.

As required therein, the detailed geotec hnical investigation must: (1) address fault rupture, seismic ground shaking, liquefaction, lateral spreading, settlement, subsidence, slope stability, and expansive and collapsible soils; and (2) include a literature review, subsurface testing (e.g., borings), laboratory testing of collected soils, analysis, and geotechnical engineering recommendations for project foundations, footings, and other construction and design elements. Per City requirements, the detailed geotechnical investigation must be submitted with the Site Improvement/Grading Plan. Compliance with the geotechnical engineering recommendations in a detailed geotechnical investigation would ensure that the site-specific geotechnical and so ils hazards at a project site are taken into account during design and construction and properly mitigated.
20,21

2. CBC Section 1805.1.3 (Groundwater Control) : Where dewatering is required, CBC Section 1805.1.3 requires that the design of the system to lower the groundwater table shall be based on accepted principles of engineering that consider issues that include, but are not necessarily limited to, permeability of the soil, rate at which water enters the drainage system, rated capacity of pumps, head against which pumps are to operate, and the rated capacity of the disposal area for the system. Consideration of these issues would ensure that any dewatering systems are properly sized and designed to accommodate the dewatering required.

3. CBC Section 1304 (Excavation, Grading and Fill): CBC Section 1304 identifies specific slope limitations, compaction requirements, placement of fill requirements, and other grading requirements for excavation, grading and fill. These requirements have been formulated to ensure the safe and proper support of new buildings/structures.

4. CBC Section J104.3 (Grading Permit Requirements – Geotechnical/Soils Report): Per CBC Section J104.3, a geotechnical report prepared by a registered design professional shall be

19 Department of General Services, 2022. Building Standards Commission, California Building Standards Code.

Available at: https://www.dgs.ca.gov/BSC/Codes#@ViewBag.JumpTo/. Accessed March 2023. 20 The geotechnical and soils issues listed are those required by CBC Section 1803.5.12 be addressed in detailed geotechnical reports for projects in USGS Seismic Design Categories D through F (e.g., areas subject to potentially strong seismic ground shaking).
21 The geotechnical investigation determined the Project Site is in Seismic Design Category D.

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required for a grading permit. The report shall contain at least: (1) the nature and distribution of existing soils; (2) conclusions and recommendations for grading procedures; (3) soil design criteria for any structures or embankments required to accomplish the proposed grading; and (4) where necessary, slope stability studies, and recommendations and conclusions regarding site geology. Per City of Culver City requirements, a final compaction report is also required.

Compliance with these requirements would ensure that grading occurs in a safe manner and would provide for the safe and proper support of new buildings/structures. • CBC Section J104.5 (Grading Permit Requirements – Liquefaction Study) : For sites with mapped maximum considered earthquake spectral response accelerations at short periods greater than 0.5g, a study of the liquefaction potential of the site shall be provided and the recommendations incorporated into the grading plan. Compli ance with this requirement would ensure that any grading and other earthwork takes into account the potential for liquefaction at the site and, along with the design of foundations, footings, and other design elements, would mitigate potential liquefaction hazard.

California Environmental Quality Act
CEQA requires that public agencies identify the environmental consequences of their proposed projects and project approvals and as such, paleontological resources are afforded consideration under CEQA. Appendix G of the CEQA guidelines (Title 14, Division 6, Chapter 3, California Code of Regulations: 15000 et seq.) includes as one of the questions to be answered in the Environmental Checklist (Appendix G, Section V, Part c) the following: “Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?” PRC Section 5097.5 specifies that any unauthorized removal of paleontological remains is a misdemeanor. Other State requirements for paleontological resource management are in PRC Chapter 1.7, Section 5097.5 through 5097.9 (Stats. 1965, c. 1136, p. 2792), Archaeological, Paleontological, and Historical Sites. This statute defines any unauthorized disturbance or removal of a fossil site or remains on public land as a misdemeanor and specifies that State agencies may undertake surveys, excavations, or other operations as necessary on State lands to preserve or record paleontological resources.

California Department of Transportation
Jurisdiction of the California Department of Transportation (Caltrans) includes State and interstate routes within California. Any work within the right-of-way of a federal or State transportation corridor is subject to Caltrans regulations governing allowable actions and modifications to the right-of-way. Caltrans standards incorporate the CBC and contain numerous rules and regulations to protect the public from seismic hazards such as surface fault rupture and ground shaking. In addition, Caltrans standards require that projects be constructed to minimize potential hazards associated with cut and fill operations, grading, slope instability, and expansive or corrosive soils, as described in the Caltrans Highway Design Manual.

California Multi-Hazard Mitigation Plan
The State of California Multi-Hazard Mitigation Plan, also known as the State Hazard Mitigation Plan (SHMP), was approved by FEMA in 2013 and most recently updated in 2018. The SHMP outlines present and planned activities to address natural hazards. The adoption of the SHMP qualifies the State of California for federal funds in the event of a disaster. The state is required

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under DMA2K, described above, to review and update its SHMP and resubmit for FEMA approval at least once every five (5) years to ensure the continued eligibility for federal funding.

The SHMP provides goals and strategies which address minimization of risks associated with natural hazards and response to disaster situations. The SHMP notes that the primary sources of losses in the State of California are fire and flooding.

California Penal Code Section 622.5
California Penal Code Section 622.5 provides the following: “Every person, not the owner thereof, who willfully injures, disfigures, defaces, or destroys any object or thing of archeological or historical interest or value, whether situated on private lands or within any public park or place, is guilty of a misdemeanor.”
California Public Resources Code Section 5097.5 and Section 30244 Requirements for paleontological resource management are included in PRC Section 5097.5 and Section 30244. These statutes prohibit the removal of any paleontological site or feature from public lands without permission of the jurisdictional agency, define the removal of paleontological sites or features as a misdemeanor, and require reasonable mitigation of adverse impacts on paleontological resources from developments on public (state, county, city, district) lands.

Hospital Facilities Seismic Safety Act of 1973
The Alfred E. Alquist Hospital Facilities Seismic Safety Act (HSSA) was passed in 1973 to ensure that hospitals in California conform to high construction standards and are reasonably capable of providing services to the public after a disaster. The HSSA requires the establishment of rigorous seismic design regulations for hospital buildings and requires that new hospitals and additions to hospitals have the capacity, as far as is practical, to remain functional after a major earthquake. State law requires that all existing hospital buildings providing general acute care as licensed under provisions of Section 1250 of the California Health and Safety Code be in compliance with the intent of the HSSA by the year 2030.

National Pollutant Discharge Elimination System Construction General Permit In California, the State Water Resources Control Board (SWRCB) and its Regional Water Quality Control Board (RWQCB) administer the National Pollution Discharge Elimination System (NPDES) program. In the Planning Area, the NPDES stormwater permitting program is implemented and enforced by the LARWQCB (Region 4). The NPDES permit system was established as part of the Federal Clean Water Act to regulate both point source discharges and non-point source discharges to surface water of the United States, including the discharge of soils eroded from construction sites.

The NPDES program consists of characterizing receiving water quality, identifying harmful constituents (including siltation), targeting potential sources of pollutants (including excavation and grading operations), and implementing a comprehensive stormwater management program. Construction and industrial activities typically are regulated under statewide general permits that are issued by the SWRCB. Additionally, the SWRCB issues Water Discharge

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Requirements that also serve as NPDES permits under the authority delegated to the RWQCBs, under the Clean Water Act. See Section 4.9, Hydrology and Water Quality, for more information about the NPDES.

Seismic Hazards Mapping Act
In order to address the effects of strong ground shaking, liquefaction, landslides, and other ground failures due to seismic events, the State of California passed the Seismic Hazards Mapping Act of 1990 (PRC Sections 2690–2699.6). Under the Seismic Hazards Mapping Act, the State Geologist is required to delineate “seismic hazard zones.” Cities and counties must regulate certain development projects within these zones until the geologic and soil conditions of their project sites have been investigated and appropriate mitigation measures, if any, have been incorporated into development plans. The State Mining and Geology Board provides additional regulations and policies to assist municipalities in preparing the Safety Element of their General Plans and to encourage the adaptation of land use management policies and regulations to reduce and mitigate seismic hazards to protect public health and safety. Under PRC Section 2697, cities and counties must require, prior to the approval of a project located in a seismic hazard zone, submission of a geotechnical report defining and delineating any seismic hazard.

Society of Vertebrate Paleontology Guidelines
The Society of Vertebrate Paleontology (SVP) has established standard guidelines that outline professional protocols and practices for conducting paleontological resource assessments and surveys, monitoring and mitigation, data and fossil recovery, sampling procedures, and specimen preparation, identification, analysis, and curation. 22 Most practicing professional
vertebrate paleontologists adhere closely to the SVP’s assessment, mitigation, and monitoring requirements as specifically provided in its standard guidelines. Most state regulatory agencies with paleontological resource-specific Laws, Ordinances, Regulations, and Standards (LORS) accept and use the professional standards set forth by the SVP.

Paleontological Resources Significance Criteria
As defined by the SVP, significant nonrenewable paleontological resources are:23 Fossils and fossiliferous deposits, here defined as consisting of identifiable vertebrate fossils, large or small, uncommon invertebrate, plant, and trace fossils, and other data that provide taphonomic, taxonomic, phylogenetic, paleoecologic, stratigraphic, and/or biochronologic information. Paleontological resources are considered to be older than recorded human history and/or older than middle Holocene (i.e., older than about 5,000 radiocarbon years).

22 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp- content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed March 2023. 23 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp- content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed March 2023.

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As defined by the SVP, significant fossiliferous deposits are:24 A rock unit or formation which contains significant nonrenewable paleontological resources, here defined as comprising one or more identifiable vertebrate fossils, large or small, and any associated invertebrate and plant fossils, traces, and other data that provide taphonomic, taxonomic, phylogenetic, ecologic, and stratigraphic information (ichnites and trace fossils generated by vertebrate animals, e.g., trackways, or nests and middens which provide datable material and climatic information). Paleontological resources are considered to be older than recorded history and/or older than 5,000 years BP [before present].

Based on the significance definitions of the SVP, all identifiable vertebrate fossils are considered to have significant scientific value.
25 This position is adhered to because vertebrate fossils are relatively uncommon, and only rarely will a fossil locality yield a statistically significant number of specimens of the same genus. Therefore, every vertebrate fossil found has the potential to provide significant new information on the taxon it represents, its paleoenvironment, and/or its distribution. Furthermore, all geologic units in which vertebrate fossils have previously been found are considered to have high sensitivity. Identifiable plant and invertebrate fossils are considered significant if found in association with vertebrate fossils or if defined as significant by project paleontologists, specialists, or local government agencies.

A geologic unit known to contain significant fossils is considered “sensitive” to adverse impacts if there is a high probability that earth-moving or ground-disturbing activities in that rock unit will either directly or indirectly disturb or destroy fossil remains. Paleontological sites indicate that the containing sedimentary rock unit or formation is fossiliferous. The limits of the entire rock formation, both areal and stratigraphic, therefore define the scope of the paleontological potential in each case.
26 Fossils are contained within surficial sediments or bedrock and are therefore not observable or detectable unless exposed by erosion or human activity. In summary, paleontologists cannot know either the quality or quantity of fossils prior to natural erosion or human-caused exposure.

As a result, even in the absence of surface fossils, it is necessary to assess the sensitivity of rock units based on their known potential to produce significant fossils elsewhere within the same geologic unit (both within and outside of the study area), a similar geologic unit, or based on whether the unit in question was deposited in a type of environment that is known to be favorable for fossil preservation. Monitoring by experienced paleontologists greatly increases the probability that fossils will be discovered during ground-disturbing activities and that, if

24 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp- content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed March 2023. 25 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp- content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed March 2023. 26 Society of Vertebrate Paleontology. 2010. Standard Procedures for the Assessment and Mitigation of Adverse Impacts to Paleontological Resources. https://vertpaleo.org/wp- content/uploads/2021/01/SVP_Impact_Mitigation_Guidelines-1.pdf. Accessed March 2023.

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these remains are significant, successful mitigation and salvage efforts may be undertaken in order to prevent adverse impacts on these resources.

Regional
Los Angeles County General Plan
The Los Angeles County (County) General Plan governs the area within the SOI as it is within unincorporated Los Angels County. The County’s General Plan includes goals and policies to ensure future development is designed and constructed in accordance with the applicable building codes and engineering requirements that address geologic hazards.

Los Angeles County All-Hazard Mitigation Plan
The County’s All-Hazard Mitigation Plan was prepared to assess risks posed by natural hazards and to develop a mitigation action plan for reducing the risks in unincorporated Los Angeles County. This plan provides the following policies to address seismic and geologic hazards, which would apply to unincorporated lands in the Planning Area:

Seismic Hazard
Policy S 1.3: Require developments to mitigate geologic hazards, such as soil instability and landslides, in hillside management areas through siting and development standards.

Policy S 1.4: Support the retrofitting of unreinforced masonry structures to help reduce the risk of structural and human loss due to seismic or geological hazards.

Los Angeles County Municipal Code
Title 26, Building Code, of the Los Angeles County Municipal Code (LACMC) contains the County’s Building Code, which incorporates by reference the CBC, with County amendments for additional requirements. The County’s Building and Safety Department is responsible for the enforcement of the County’s Building Code. In regard to geologic hazards, the LACMC requires appropriate geotechnical investigation and reporting to determine and minimize site-specific risks of landslide, settlement, or slippage. In addition, the LACMC also enforces the setback and building requirements established in the Alquist-Priolo Act for new or redeveloped properties.

The LACMC would apply to areas within the SOI.

Local
City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan
The City and CCUSD’s MJHMP was approved by CalOES and FEMA on June 1, 2017 and was prepared to meet the requirements of these agencies and to allow the City and CCUSD to be eligible for funding and technical assistance from state and federal hazard mitigation programs in accordance with DMA2K (described under Federal Regulations). The MJHMP identifies resources, information, and strategies for risk reduction and provides a tool to measure the success of mitigation implementation on a continual basis. The strategies identified in the MJHMP are developed to reduce risks from natural hazards through a set of defined mitigation actions; to establish a basis for coordination and collaboration among resource agencies and the

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public; and to assist in meeting the requirements of federal assistance programs. The MJHMP does not supersede current City and CCUSD plans and strategies, but rather it enhances the ability to identify, inform, and mitigate natural hazard risk. The MJHMP purpose is to help guide and coordinate mitigation activities and serve as a tool for decisionmakers to direct mitigation activities and resources within the Planning Area.

Culver City Municipal Code
Chapter 15.02, Buildings, Structures, and Equipment, of the Culver City Municipal Code (CCMC) contains the City’s Building Code, which incorporates by reference the CBC, with City amendments for additional requirements. The Building Safety Division (BSD) is responsible for implementing the provisions of the City’s Building Code. To that end, BSD issues building and grading permits for construction projects. Building permits are required for any building or structure that is erected, constructed, enlarged, altered, repaired, moved, improved, removed, converted, or demolished. Grading permits are required for all grading projects other than those specifically exempted by the City’s Building Code. BSD has the authority to withhold building permit issuance if a project cannot mitigate potential hazards to the project or which are associated with the project. Throughout the permitting, design, and construction phases of a building project, BSD engineers and inspectors confirm that the requirements of the City’s Building Code pertaining specifically to geoseismic and soils conditions are being implemented by project architects, engineers, and contractors.

In addition, the City amended Chapter 15.02 of the CCMC on September 27, 2021, with the adoption of the Seismic Retrofit Ordinance. The purpose of the Seismic Retrofit Ordinance is to reduce the risk of death or injury that may result from seismic activity on existing wood-framed multi-story buildings with soft, weak, or open-front walls by requiring structure-specific measures to improve structural integrity to withstand seismic activity. The City has established Priority Designations, which categorizes eligible structures based on size, height, and/or number of units to be retrofitted, as well as a timeline for compliance with the ordinance.

Redevelopment within the City would be required to comply with the Seismic Retrofit Ordinance.

By adoption of the CBC into the CCMC, the City requires a detailed Final Geotechnical Report with final design recommendations prepared by a California-registered geotechnical engineer and submitted to the BSD for review prior to issuance of a grading permit. 27 Final foundation
design recommendations must be developed during final project design, and other deep foundation systems that may be suitable would be addressed in the detailed Final Geotechnical Report. All earthwork (e.g., excavation, site preparation, any fill backfill placement) must be conducted with engineering control under observation and testing by the geotechnical engineer and in accordance with CBC.

27 California Building Code. 2019. Part 2, Volume 1, Chapter 18, Soils and Foundations, Section 1803, Geotechnical Investigations.

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4.6.4 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 geology and soils if the project would:

Threshold GEO-1: Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury or death involving:
i. R upture of a known earthquake fault, as delineated on the most recent Alquist-Priolo Earthquake Fault Zoning Map
issued by the State Geologist for the area or based on other substantial evidence of a known fault;
ii. Strong seismic ground shaking;
iii. Seismic-related ground failure, including liquefaction ; iv. L andslides.

Threshold GEO-2: Result in substantial soil erosion or the loss of topsoil.

Threshold GEO-3: Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the project, and
potentially result in on- or off-site landslide, lateral spreading, subsidence, liquefaction or collapse.

Threshold GEO-4: Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property.

Threshold GEO-5: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Threshold GEO-6: Have soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems where sewers are not available for the disposal of wastewater.

The Initial Study (Appendix A) found no potentially significant impacts related to soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems (Threshold GEO-6); therefore, this issue is not studied further in this PEIR.

Methodology
Geologic and Seismic Hazards
This evaluation of geologic and seismic hazard conditions within the Planning Area that would apply to the Project was completed using published geologic, soils, and seismic maps and studies from USGS, CGS, and Los Angeles County, as well as information from the MJHMP and the Inglewood Oil Field Specific Plan Project Environmental Impact Report (SCH No. 2015101030).

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Paleontological Resources
The analysis of paleontological resources is based on a review of the results from the LACM paleontological records search conducted for the Culver City General Plan Update Environmental Background Report Existing Conditions Report. The purpose of the records search is to determine whether there are previously recorded fossil localities or paleontologically sensitive formations within the Planning Area that require inclusion in the current analysis. The results also provide a basis for assessing the sensitivity of the Planning Area in regard to the potential for surface and subsurface paleontological resources to exist.

Project Impact Analysis
Risk of Geologic Hazards
Threshold GEO-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving: (i) rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault; (ii) strong seismic ground shaking; (iii) seismic -related ground failure, including liquefaction; or (iv) landslides.

Impact Statement 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.

General Plan Update
Fault Rupture
As discussed above in Section 4.6.2, Environmental Setting, and mapped in Figure 4.6-3, the Newport-Inglewood Fault and the corresponding Alquist-Priolo Earthquake Fault Zones run through the northeastern part of the Planning Area, including the Hayden Tract. There are no other known faults that traverse the Planning Area that have the potential to result in surface fault rupture. As shown in Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description, of this Draft PEIR, the majority of the potential growth under the Project would occur outside of the designated Alquist-Priolo Earthquake Fault Zones within the Planning Area.

Existing land uses within the Alquist-Priolo Earthquake Fault Zones are developed with urban uses, including low- and medium-density residential, commercial, industrial, and open space uses. While the Project would change some of the land use designations in the Alquist-Priolo Earthquake Fault Zones, the uses would still be urban in nature and therefore, the Project would have the potential to expose people, structures, and infrastructure within these zones to the effects of surface fault rupture in the event of a large earthquake.

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In accordance with the Alquist-Priolo Act, future development proposed within the identified Alquist-Priolo earthquake fault zones would be required to conduct site-specific geological investigations to demonstrate the development would not be threatened by surface displacement from future faulting prior to issuance of building permits and/or approval of the project. For proposed structures intended for human occupancy within the Alquist-Priolo earthquake fault zones, in addition to the site-specific geological investigations, must also be located at least 50 feet from the trace of an active fault, unless proven otherwise by the geotechnical investigation and report that the development site is not underlain by active branches of the active fault. Compliance with the requirements of the Alquist-Priolo Act, including appropriate siting, and implementation of industry design and construction standards, would ensure that the risks of fault rupture would be minimized for future development within the Alquist-Priolo earthquake fault zones.

In addition to compliance with the Alquist-Priolo Act, compliance with the CBC, LACMC, and CCMC’s engineering design and construction requirements and standards would reduce the risk of potential structural damage and exposure of people to risk of injury or death from structural failure. In accordance with the CBC, LACMC, and CMCC, foundations and other structural support features would be designed to resist or absorb damaging forces from strong ground shaking and surface fault rupture. Chapter 15.02 of the CMCC incorporates the most recent CBC.

The Culver City Building and Safety Division reviews plans and applications for site clearance, grading, and building permits to ensure compliance with Chapter 15.08 (California Building Standards Code) and imposes requirements for revisions where needed to ensure that new or significantly remodeled structures are constructed in compliance with the CBC, and reflect any additional measures deemed appropriate. Building permit issuance would be based upon satisfactory completion of any identified applicable measures at the time of issuance.

Furthermore, the General Plan Update includes goals and policies to minimize structural damage and to promote public safety by reducing exposure of people to risk of injury or death from structural failure during a large seismic event. The Safety Element includes proposed Goal S-4 and Policies S-4.1 through S-4.11 that focus on addressing seismic hazards by focusing on strengthening the City’s project permit and review process and promoting the retrofitting and rehabilitation of utilities, infrastructure, and structures to increase public safety in the event of a seismic event. Specific to fault rupture, the Safety Element would establish policies for future development within the Newport-Inglewood Fault Zone and within Alquist-Priolo Zones, require earthquake-safe design and construction standards and measures, and ensure enforcement of the City’s seismic code within the City and the SOI once annexed Furthermore, the General Plan Update’s goals and policies require compliance with federal, state, and local regulations and design standards to address seismic hazards, including surface fault rupture.

With the implementation of the goals and policies in the General Plan Update as well as compliance with the CBC, CCMC, and LACMC, potential impacts associated with surface fault rupture within the Planning Area, including the Alquist-Priolo Earthquake Fault Zones, would be considered less than significant.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-27 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Ground Shaking
Earthquakes in and near the Planning Area have the potential to cause ground shaking of significant magnitude. The Project would allow for additional development within the Planning Area, which could expose people and property to strong seismic ground shaking. However, as discussed in greater detail under Fault Rupture above, all future development under the Project would be required to be designed and constructed in compliance with the requirements and standards of the CBC and CCMC to resist the effects of accelerated ground motions due to an earthquake event. Compliance with the engineering design and construction requirements and standards of the CBC, CMCC, and LACMC would reduce the risks of structural failure due to strong ground shaking. Furthermore, the Culver City Building and Safety Division would review future development projects on an individual basis to ensure compliance with all applicable engineering and environmental requirements prior to issuance of a building permit, which would further minimize the risk of structural failure due to strong ground shaking.

Additionally, Goal S-4 and Policies S-4.1 through S-4.11 in the General Plan Update address any potential impacts associated with strong seismic ground shaking. As indicated above, the Safety Element includes various goals and policies that address seismic hazards by focusing on strengthening the City’s project permit and review process and promoting the retrofitting and rehabilitation of utilities, infrastructure, and structures to increase public safety in the event of a seismic event. Specific to strong ground shaking, the Safety Element would establish policies to improve the enforcement of the City’s seismic code, conduct a seismic vulnerability inventory across the Planning Area, and to monitor future development and redevelopment within the Newport-Inglewood Fault Zone and Alquist-Priolo Zones. Furthermore, the General Plan Update’s goals and policies require compliance with federal, state, and local regulations and design standards to address seismic hazards, including strong ground shaking. Therefore, impacts related to strong seismic ground shaking would be considered less than significant.

Seismic-Related Ground Failure, including Liquefaction
Secondary effects of earthquake shaking may include landslides, slope instability, liquefaction, subsidence, and lateral spreading. Seismic-induced landslides and slope instability are discussed below under Seismically Induced Landslides. As shown on Figure 4.6-5, the majority of the Planning Area is located within a liquefaction hazard area, with the exception of the northwestern and southeastern areas. As such, future development under the Project could potentially be exposed to the effects of liquefaction, subsidence, and lateral spreading from local and regional earthquakes.

As discussed above in Fault Rupture and Strong Ground Shaking above, compliance with the CBC and CCMC as well as with the goals and policies of the General Plan Update, which aim to protect residents, employees, structures, and infrastructure within the City and the SOI once annexed from the effects of surface fault rupture and strong seismic ground shaking, would also protect against the secondary effects of earthquake shaking. All future development would be required to be designed, engineered, and constructed in accordance with the requirements and standards of the CBC, CMCC, and LACMC, which require that foundations and other structural support features be designed to resist or absorb damaging forces from strong ground shaking, liquefaction, and subsidence. Moreover, in accordance with the CBC, LACMC, and CCMC, for all

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-28 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
proposed future development within an identified liquefaction area, a site-specific geotechnical investigation and report that includes design and engineering requirements to reduce the risks of liquefaction would be required. The geotechnical investigation and report would be required to be submitted as part of the environmental and building permit process for future development projects.

In addition, General Plan Update includes goals and policies to address any potential impacts associated with strong seismic ground shaking (Goal S-4, Policies S-4.1 through S-4.12). The Safety Element includes various goals and policies that address seismic hazards by focusing on strengthening the City’s project permit and review process and promoting the retrofitting and rehabilitation of utilities, infrastructure, and structures to increase public safety in the event of a seismic event. Specific to ground failure, including liquefaction, the Safety Element includes policies for the following to occur for new development in the liquefaction vulnerability zone:
conduct liquefaction vulnerability studies with site-specific recommendations that address liquefaction, when warranted (Policy S-4.12); prepare site-specific geotechnical site investigations before permitting reuse or rebuilding of a failed area, adjacent unstable slopes, or debris flow path (Policies S-5.2 and S-5.4); and ensure enforcement of the City’s seismic and building codes to minimize risks of ground failure, including liquefaction (Policy S-5.3).

Furthermore, the General Plan Update’s goals and policies require compliance with federal, state, and local regulations and design standards to address seismic hazards, including seismic- related ground failure, including liquefaction.

Lastly, future development projects located within areas susceptible to seismic-related ground failure would be required by the CCMC to conduct an environmental analysis at the time a specific project is defined, including preparation of site-specific soils and geologic reports for review and approval by the City Engineer, and incorporation of the recommended actions during construction. Thus, compliance with the CBC and CMCC, the goal and policies of the General Plan Update, and site-specific recommendations identified during review, as necessary, would ensure impacts related to seismic-related ground failure, including liquefaction, would be considered less than significant.

Seismically Induced Landslides
Rapid erosion and landslides are most likely to occur on sloped areas. As described above in Section 4.6.2, Environmental Setting, the Planning Area is relatively flat with areas of rolling hills that vary in elevation from approximately 40 to 100 feet amsl, with the highest area being Baldwin Hills at 400 amsl. As shown in Figure 4.6-4, the eastern portion of the Planning Area around Baldwin Hills is designated as a potential landslide zone. As such, future development under the Project within the designated landslide area could potentially expose people, structures, and infrastructure within these areas to the effects of landslides and/or slope instability in the event of a large earthquake.

The General Plan Update includes Goal S-5 and Policies S-5.1 through S-5.6 to minimize slope instability and to promote public safety by reducing exposure of people to risk of injury or death from landslides during a large seismic event. The Safety Element includes various goals and policies, as listed below, that address seismic hazards by focusing on strengthening the City’s

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-29 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
project permit and review process and promoting the retrofitting and rehabilitation of utilities, infrastructure, and structures to increase public safety in the event of a seismic event. Specific to seismically induced landslides, the Safety Element includes policies that require the City to monitor development in areas with high landslide potential; require site stability measures through enforcement of the City’s Hillside Grading and Permitting Ordinance and other regulations; require site-specific geotechnical site investigations before permitting reuse or rebuilding of a failed area, adjacent unstable slopes, or debris flow path; and vegetation management to reduce the potential for landslides. Furthermore, the General Plan Update’s goals and policies require compliance with federal, state, and local regulations and design standards to address seismic hazards, including landslides and slope instability.

In addition to the General Plan Update’s goals and policies, compliance with the CBC, CCMC and LACMC engineering design and construction requirements and standards would reduce the risk of potential structural damage and exposure of people to risk of injury or death from landslides and slope instability. The potential impacts from landslides on future development associated with the Project would be addressed through site-specific geotechnical studies prepared in accordance with CBC an CMCC requirements and standard industry practices, as needed, which would specifically address landslide hazards. In addition, the CMCC includes various requirements for properties that contain slopes of 15 percent or more, including but not limited to preparation of a site-specific Slope Protection and Fire Prevention Landscape Plan and geotechnical and geologic report with detailed topographic survey, incorporation of slope stabilization measures approved by the Culver City Building and Safety Division, and submittal of a hillside grading plan to obtain a grading permit for sloped areas reviewed and issued by the Culver City Building and Safety Division. Furthermore, Chapter 1613.6 of the CMCC contains the seismic design provisions for hillside buildings to ensure slope stability. Therefore, compliance with the CBC and CMCC, the goal and policies of the General Plan Update, and site-specific recommendations identified prior to permit approval would ensure impacts related to seismically-induced landslides and slope instability would be considered less than significant.

Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan within the city. Future development under the Zoning Code Update would be required to comply with all appliable design, engineering, and construction standards and requirements of the CBC within the CMC, Zoning Code, and General Plan Update. Therefore, future development under the Project would not cause risk of loss, injury, or death associated with seismic hazards, including fault rupture, strong ground shaking, seismic-related ground failure, including liquefaction, or seismic-related landslides and slope instability. As such, implementation of the Project would result in a less than significant impact related to risk of seismic-related geologic hazards.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-30 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-4 Seismic hazards. Culver City residents and businesses are prepared for earthquake hazards, minimizing the economic impact of strong ground shaking, liquefaction, and fault rupture on public and private property.

S-4.1: Retrofitting and rehabilitation. Promote strengthening planned utilities (where feasible) and retrofitting and rehabilitating existing potentially hazardous structures and aging lifeline utilities to increase public safety and minimize potential damage from seismic and geologic hazards and inadequate maintenance.

S-4.2: Project permit and review process. Strengthen the project permit and review process to ensure that proper actions are taken to mitigate potential adverse effects of seismic hazards. Consider structural and nonstructural seismic design and construction practices that minimize earthquake damage to critical facilities and structures designed for human occupancy.

S-4.3: Geological and geotechnical investigations. Continue to require geological and geotechnical investigations in areas of potential seismic or geologic hazards as part of the environmental and development review process.

S-4.4: Development or redevelopment within the Newport-Inglewood Fault Zone.

Monitor development or redevelopment within the Newport-Inglewood Fault Zone in accordance with State law.

S-4.5: Newport-Inglewood Fault Zone cooperation. Cooperate with State and federal agencies in investigating the Newport-Inglewood Fault Zone geology. The City shall consider partnering with the U.S. Geological Survey’s Earthquake Hazards Program to better identify the active traces of the Newport-Inglewood Fault.

S-4.6: Alquist-Priolo hazard zone collaboration. Collaborate with the U.S. Geological Survey regarding compliance with regulations applicable to areas within the Alquist- Priolo hazard zone.

S-4.7: Earthquake-safe design. Ensure that new structures are designed to, and existing structures perform such that they, minimize risk associated with earthquake hazards.

S-4.8: Seismic code enforcement. Continue enforcing the California Building Standards Code’s Seismic Design Category provisions, including those related to near-source seismic conditions.

S-4.9: Seismic vulnerability inventory. Continue maintaining an inventory of private buildings vulnerable to seismic activity, including unreinforced masonry and soft story structures. Prioritize retrofitting more vulnerable structures.

S-4.10: Seismic retrofit funding. Continue to identify potential funding sources to assist with seismic retrofits.

S-4.11: Agency cooperation. Cooperate with other agencies, like the California Earthquake Authority Earthquake Brace + Bolt program, and private interests to implement incentive programs and educate private landowners on foundation bolting and bracing.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
S-4.12: Liquefaction vulnerability. Require new development in the liquefaction vulnerability zone to conduct liquefaction vulnerability studies with mitigation measures that addresses liquefaction, when warranted, for geological reports that the City requires emphasis on lower-income families.

Goal S-5 Geologic hazards. The Blair Hills and Culver Crest neighborhoods are protected from the social and economic effects of geologic hazards associated with unstable slopes.

S-5.1: Development in areas with high landslide potential. Continue ensuring required compliance with State regulations during development and redevelopment within areas with high landslide potential during environmental and development review processes.

S-5.2: Site stability. Continue to require the following, when determined necessary, through standard City requirements, the Hillside Grading and Permitting Ordinance, the California Environmental Quality Act (CEQA), and other regulations:
• Preliminary geotechnical and geologic investigations in areas with high landslide potential;
• Evaluation of site stability and possible impact on adjacent properties, before final project design is approved; and
• Preparation of reports, investigations, and design recommendations for grading permits, building permits, and subdivision applications by a State-geotechnical engineer and State-certified engineering geologist.

S-5.3: Building safety. Continue to require the following, when determined necessary through City requirements, CEQA, and other regulations:
• Meeting the California Building Standards Code and Hillside Grading and Permitting Ordinance adopted by Culver City, coordinating between the project civil engineer, engineering geologist, and geotechnical engineer during grading and construction operations; and
• Certifying that building sites are stable to potential adverse effects of rain, earthquakes, and differential settlement before issuing building permits.

S-5.4: Geotechnical site investigations. Require geotechnical site investigations before permitting reuse or rebuilding of a failed area, adjacent unstable slopes, or debris flow path. Establish standards to improve setbacks or surface/subsurface drainage, construct buttresses or other retaining structures, or reconstruct slopes, that will minimize future risk to persons and property or public liability.

S-5.5: Geologic hazard management. Whenever possible, mitigate geologic hazards in a manner that preserves the aesthetic or natural conditions of hillside areas through minimal grading, or corrective landform grading and revegetation with appropriate plant materials. When these goals conflict, protecting life and property shall take precedence.

S-5.6: Vegetation management. Reduce the potential for landslides by sufficiently removing dead, woody vegetation after a catastrophic fire.

4. Environmental Impact Analysis

4.6. Geology and Soils
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Preliminary − Subject to Revision
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 seismic- related geologic hazards.

Soil Erosion or Loss of Topsoil
Threshold GEO-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would result in substantial soil erosion or the loss of topsoil.

Impact Statement 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.

General Plan Update
Development anticipated as a result of implementation of the General Plan Update would likely include earthwork activities, such as grading, excavation, stockpiling, and paving, that could expose soils to the effects of erosion or loss of topsoil. Once disturbed, either through removal of vegetation, asphalt, or an entire structure, stockpiled soils can be exposed to the effects of wind and water if not managed properly. Construction activities that disturb one or more acre of land surface are subject to the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022-0057-DWQ) adopted by the SWRCB. Compliance with the permit requires each qualifying development project to file a Notice of Intent with the SWRCB. Permit compliance includes implementation of a storm water pollution prevention plan (SWPPP) through the local jurisdiction. A SWPPP must also describe the site, facility, erosion and sediment controls, runoff water quality monitoring, means of waste disposal, implementation of approved local plans, control of construction sediment and erosion BMPs, maintenance responsibilities, and non-stormwater management controls. Inspection of construction sites before and after a storm is also required to identify stormwater discharge from construction activity and to identify and implement erosion controls, where necessary. The BMPs implemented by a site-specific SWPPP include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. Generally, once construction is complete and exposed areas are revegetated or covered by buildings, asphalt, or concrete, the erosion hazard is substantially eliminated or reduced.

Additionally, the General Plan Update includes goals and policies, listed below, that require the use of best management practices (BMPs) to control soil erosion during and after ground- disturbing activities and geotechnical reports for projects requiring grading permits (Policies S-

4.3, S-5.5, S-5.6, S-7.10, and LU-12.2). Therefore, impacts related to soil erosion and topsoil loss would be considered less than significant with implementation of the Project.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan Update within the city. Future development under the Zoning Code Update would be required to comply with all appliable design, engineering, and construction standards and requirements of the CBC within the CMC, Zoning Ordinance, and General Plan Update. In addition, future projects would also comply with requirements related to erosion and loss of topsoil of the NPDES General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities, City’s Grading Ordinance, CCMC, and the General Plan Update.

Therefore, future development under the Project would not cause soil erosion or loss of topsoil.

As such, implementation of the Project would result in a less than significant impact related to soil erosion or loss of topsoil.

Applicable Proposed General Plan Goals and Policies
Safety Element
S-4.3: Geological and geotechnical investigations. Continue to require geological and geotechnical investigations in areas of potential seismic or geologic hazards as part of the environmental and development review process.

S-5.6: Vegetation management. Reduce the potential for landslides by sufficiently removing dead, woody vegetation after a catastrophic fire.

S-7.10: Fire-safe landscapes. Encourage residents to plant and maintain drought- resistant, fire-retardant landscape species on slopes to reduce the risk of brush fire and soil erosion in areas adjacent to canyons. Develop stringent site design and maintenance standards for areas with high fire hazard or soil erosion potential.

Land Use and Community Design Element
LU-12.2: Hillside safety measures. Incorporate additional safety measures for grading design into the Municipal Code/ Building Code, including • Adopting a cumulative grading maximum;
• Incorporating additional safety measures for grading design into the Municipal Code/ Building Code; and
• Establishing criterion for appropriate and adequate protective devices; and • Employing the use of landscaping as a method of erosion control.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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 soil erosion or loss of topsoil.

Unstable Soils
Threshold GEO-3: The Project would have a significant impact implementation of the General Plan Update and Zoning Code Update resulted in geologic units or soils that are unstable as a result of development, and potentially result s in on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse.

Impact Statement 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.

General Plan Update
As discussed above under Thresholds GEO-1 and GEO-2, certain geologic units present in the Planning Area have the potential for landslides, slope instability, liquefaction, and liquefaction- induced lateral spreading. Development allowed under the Project could be located on geologic units or soils that are unstable, or that could become unstable, and result in geologic hazards if not addressed appropriately. Areas with underlying materials that include undocumented fills, soft compressible deposits, or loose debris could be inadequate to support development, especially multi-story buildings. Soils that exhibit expansive properties when exposed to varying moisture content over time could result in damage to foundations, walls, or other improvements. Future structures developed under the Project could be damaged as a result of settlement or differential settlement where structures are underlain by materials of varying engineering characteristics. In addition, construction of new structures in the vicinity of relatively steep slopes could provide additional loading causing landslides or slope failure from unstable soils or geologic units. Slope failure can occur naturally through rainfall or seismic activity, or through earthwork and grading related activities. However, the risk of landslides and slope instability would be limited to the western portion of the Planning Area around Baldwin Hills, as shown in Figure 4.6-4.

The potential hazards of unstable soil or geologic units would be addressed largely through the integration of geotechnical information in the planning and design process for future development to determine the local soil suitability for specific projects in accordance with standard industry practices and state-provided requirements, such as CBC requirements that are used to minimize the risk associated with these hazards. Geotechnical investigations would be required for compliance with the CBC to thoroughly evaluate site-specific geotechnical characteristics of subsurface soils and bedrock to assess potential hazards and recommend site

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
preparation and design measures to address any hazards which may be present. These measures are enforced through compliance with the CBC to address hazards relating to unstable soils and slope failure. In addition, CCMC and LACMC also include local design, engineering, and construction requirements specific to unstable geologic units and soils as well as for properties with slopes of 15 percent or greater. Compliance with these standards and requirements would reduce risks of landslides, lateral spreading, subsidence, liquefaction, or collapse associated with unstable geologic units or soils.

In addition, the General Plan Update includes goals and policies that address the risk of landslides, lateral spreading, subsidence, liquefaction, or collapse associated with unstable geologic units or soils. Goal S-4 and the related policies of the Safety Element would address seismic hazards by focusing on strengthening the City’s project permit and review process and promoting the retrofitting and rehabilitation of utilities, infrastructure, and structures to increase public safety in the event of a seismic event. Specific to unstable soils, Goal S-5 and Policies S-5.1 through S-5.6 of the Safety Element require the City to monitor development in areas with high landslide potential; require site stability through the City’s Hillside Grading and Permitting Ordinance and other regulations; require site-specific geotechnical site investigations before permitting reuse or rebuilding of a failed area, adjacent unstable slopes, or debris flow path; vegetation management to reduce the potential for landslides; and requires the preparation of liquefaction vulnerability studies for new development proposed in the liquefaction vulnerability zone to address liquefaction, when warranted. For these reasons, impacts related to hazards associated with unstable soils, such as landslide, lateral spreading, subsidence, liquefaction, or collapse, would be considered less than significant.

Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan Land Use Designations within the city. Future development under the Zoning Code Update would be required to comply with all appliable design, engineering, and construction standards and requirements of the CBC within the CMC, Zoning Ordinance, and General Plan Update. In addition, future projects would also comply with requirements related to unstable geologic units or soils of the LACMC, City’s Grading Ordinance, CCMC, and the General Plan Update. Therefore, future development under the Project would not result in landslides, lateral spreading, subsidence, liquefaction, or collapse due to unstable geologic units or soils. As such, implementation of the Project would result in a less than significant impact related to unstable geologic units or soils.

Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-4 Seismic hazards. Culver City residents and businesses are prepared for earthquake hazards, minimizing the economic impact of strong ground shaking, liquefaction, and fault rupture on public and private property.

S-4.1: Retrofitting and rehabilitation. Promote strengthening planned utilities (where feasible) and retrofitting and rehabilitating existing potentially hazardous structures and

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
aging lifeline utilities to increase public safety and minimize potential damage from seismic and geologic hazards and inadequate maintenance.

S-4.4: Development or redevelopment within the Newport-Inglewood Fault Zone.

Monitor development or redevelopment within the Newport-Inglewood Fault Zone in accordance with State law.

S-4.7: Earthquake-safe design. Ensure that new structures are designed to, and existing structures perform such that they, minimize risk associated with earthquake hazards.

S-4.8: Seismic code enforcement. Continue enforcing the California Building Standards Code’s Seismic Design Category provisions, including those related to near-source seismic conditions.

S-4.10: Seismic retrofit funding. Continue to identify potential funding sources to assist with seismic retrofits.

S-4.12: Liquefaction vulnerability. Require new development in the liquefaction vulnerability zone to conduct liquefaction vulnerability studies with mitigation measures that addresses liquefaction, when warranted, for geological reports that the City requires emphasis on lower-income families.

Goal S-5 Geologic hazards. The Blair Hills and Culver Crest neighborhoods are protected from the social and economic effects of geologic hazards associated with unstable slopes.

4. Environmental Impact Analysis

4.6. Geology and Soils
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• Preparation of reports, investigations, and design recommendations for grading permits, building permits, and subdivision applications by a State-geotechnical engineer and State-certified engineering geologist.

S-5.6: Vegetation management. Reduce the potential for landslides by sufficiently removing dead, woody vegetation after a catastrophic fire.

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 unstable geologic units or soils.

Expansive Soils
Threshold GEO-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update resulted in development located on expansive soils , as defined in Table 1-B of the Uniform Building Code, creating substantial direct or indirect risks to life or property.

Impact Statement 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.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-38 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
General Plan Update
Soils that exhibit expansive properties when exposed to varying moisture content over time could result in damage to foundations, walls, or other improvements. As discussed above in Section 4.6.2, Environmental Setting, expansive soils within the Planning Area are generally located around Baldwin Hills due to their high clay content. Thus, future development facilitated under the Project in the Baldwin Hills area could potentially occur on expansive soils.

As discussed above, all future development would be required to be designed, engineered, and constructed in accordance with the requirements and standards of the CBC, LACMC, and CMCC, which requires that foundations and other structural support features be designed to resist or absorb damaging forces from expansive soils. The potential hazards of expansive soils would be addressed largely through the integration of geotechnical information in the planning and design process for projects to determine the local soil suitability for specific projects in accordance with standard industry practices and state and local requirements, such as CBC, CCMC, and LACMC requirements that regulate the analysis of expansive soils within the City and SOI. Geotechnical investigations would be required to thoroughly evaluate site-specific geotechnical characteristics of subsurface soils to assess potential hazards and recommend site preparation and design measures to address any hazards which may be present.

In addition, Policies S-4.1, S-4.3, and S-5.3 of the Safety Element address the risk of expansive soils, such as requiring site-specific geotechnical investigations and mitigation measures, as necessary, and enforcement of the City’s seismic and building codes. For these reasons, the impact related to hazards associated with expansive soils would be less than significant.

Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan within the city. Future development under the Zoning Code Update would be required to comply with all appliable design, engineering, and construction standards and requirements of the CBC within the CMC, including the Grading Ordinance, and Zoning Ordinance. Therefore, future development under the Project would not result in geologic hazards associated with expansive soils. As such, implementation of the Project would result in a less than significant impact related to unstable expansive soils.

Applicable Proposed General Plan Goals and Policies
Safety Element
S-4.1: Retrofitting and rehabilitation. Promote strengthening planned utilities (where feasible) and retrofitting and rehabilitating existing potentially hazardous structures and aging lifeline utilities to increase public safety and minimize potential damage from seismic and geologic hazards and inadequate maintenance.

4. Environmental Impact Analysis

4.6. Geology and Soils
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S-5.3: Building safety. Continue to require the following, when determined necessary through City requirements, CEQA, and other regulations:
• Meeting the California Building Standards Code and Hillside Grading and Permitting Ordinance adopted by Culver City, coordinating between the project civil engineer, engineering geologist, and geotechnical engineer during grading and construction operations; and
• Certifying that building sites are stable to potential adverse effects of rain, earthquakes, and differential settlement before issuing building permits.

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 expansive soils.

Paleontological Resources
Threshold GEO-5: The Project would have a potentially significant impact if implementation of the General Plan Update and Zoning Code Update would directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.

Impact Statement 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.

General Plan Update
As previously discussed, the records search from the LACM has indicated that four fossil localities have been recorded within the boundaries of the city and that eight other localities are located outside the city (either immediately adjacent or within several miles) but from the same sedimentary deposits (older Quaternary alluvium deposits and the San Pedro Sand) that occur within and throughout the city. Additional fossil localities have been identified recently within the city that were discovered at depth during construction of private redevelopment projects.

The fossil localities have yielded multiple specimens of plants and animals including mammoth, mastodon, camel, human, horses, saber-toothed cat, duck, and multiple invertebrates (e.g., clam shells, gastropods, etc.) that have been recovered in previously undisturbed sediments between 6 and 55 feet bgs and unknown depths.

Moreover, it is possible that additional paleontological resources are present within the Planning Area that have yet to be discovered; therefore, the current or prior existence of development throughout the Planning Area does not preclude the presence of paleontological resources located underneath this development. As mentioned in this section, several paleontological

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-40 SCH No. 2022030144 City of Culver City March 2024
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resources have been identified within the city at depth during paleontological monitoring of construction project sites that have undergone extensive development over many years.

Examples of paleontological resource recovered in the Planning Area that would be scientifically important include those that represent a new or rare species, geologic (temporal) and/or geographic range extension, an age-diagnostic or environmentally sensitive species, and/or a more complete specimen than those now available for their respective species.

Future development implemented under the General Plan Update that includes construction- related ground disturbance (e.g., grubbing/clearing, grading, excavation, trenching, and boring/drilling) into previously undisturbed sediments are activities that have potential to directly or indirectly destroy paleontological resources. Future development that does not require ground-disturbing activities into undisturbed sediments or ground-disturbing activities into artificial fill would cause no impacts on paleontological resources. However, intact paleontological resources may be encountered beneath the depth of previous disturbances or in pockets of undisturbed sediments within existing developments.

Anticipated development in the Planning Area would occur through activities such as infill development on vacant property, and through redevelopment, some of which could result in damage to paleontological resources. In addition, certain infrastructure and other improvements requiring ground disturbance into undisturbed sediments could result in damage to or destruction of paleontological resources buried below the ground surface. Therefore, impacts to paleontological resources are considered potentially significant.

However, as part of the entitlement process, the City would require and specify steps to be taken to avoid damage and promote preservation if unknown paleontological resources were to be uncovered during construction. In addition, Conservation Element Policies C-1.15 and C-1.21 would promote public knowledge and protection of paleontological resources. Furthermore, mitigation measure MM GEO-1 would serve to reduce the impacts to paleontological resources to a less-than-significant level.

Mitigation Measure MM-GEO-1 is required for some future projects to ensure that paleontological resources are properly identified during the CEQA planning process and that the impact on any identified significant resources is reduced. These future projects within the city would be subject to project-specific paleontological studies, which would include a site-specific database search through the LACM and/or other appropriate facilities; geologic map and scientific literature review; a pedestrian field survey (if deemed appropriate by the qualified professional paleontologist); assessment of the project area’s potential to have undisturbed sediments that are conducive to retaining resources, paleontological construction monitoring requirements (if necessary); and preparation of a technical report that documents the methods and results of the study. These paleontological studies would be prepared during the CEQA planning process (i.e., prior to construction).

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-41 SCH No. 2022030144 City of Culver City March 2024
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Zoning Code Update
The Zoning Code Update that is a part of the Project would establish new zoning districts and associated development standards to correspond with and implement the proposed General Plan within the city. Future development under the Zoning Code Update would be required to comply with all applicable requirements of the Zoning Ordinance, applicable mitigation measures such as MM-GEO-1, and implementing standard conditions of approval to avoid damage and promote preservation of paleontological resources. Therefore, potentially significant impacts to paleontological resources from some future Projects would be reduced to a less than significant level with mitigation incorporated.

Applicable Proposed General Plan Goals and Policies
Conservation Element
C-1.15: Public knowledge promotion. Promote public knowledge and understanding of cultural resources (including archaeological, tribal cultural resources, historic resources, and paleontological resources) present within the city.

C-1.21: Protect Archaeological, Paleontological, and Tribal Cultural Resources.

Promote programs and policies to protect known archaeological and paleontological sites and Tribal Cultural Resources.

Mitigation Measures
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.

Level of Significance After Mitigation
With implementation of the mitigation measures MM-GEO-1 and standard conditions of approval to avoid damage and promote preservation of paleontological resources, potential significant impacts related to paleontological resources would be reduced to a less-than- significant level.

4. Environmental Impact Analysis

4.6. Geology and Soils
General Plan 2045 and Zoning Code Update Project 4.6-42 SCH No. 2022030144 City of Culver City March 2024
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4.6.5 Cumulative Impacts Analysis
The geographic context for the analysis of impacts related to geology and soils is generally site- specific, rather than cumulative in nature, because each development site has unique geologic considerations that would be subject to site development and construction standards. In this way, potential cumulative impacts relating to geology and soils would be minimized on a site-by- site basis to the extent that appropriate construction methods and applicable code requirements are followed. Therefore, future development in the western Los Angeles County, including growth anticipated under the General Plan Update, would not result in a significant cumulative impact with respect to geology and soils.

The cumulative context for paleontological resources is the Planning Area and the larger Los Angeles County region. Development in Los Angeles County has resulted in the disturbance of land across almost of the entire region, thus resulting in the disturbance of unknown paleontological resources. It is reasonable to assume that present and future development activities in the region would continue to uncover unknown paleontological resources, and thus the cumulative impact of future development in the region on this resource would be potentially significant. The Planning Area has the potential to yield paleontological resources, and significant fossil discoveries have occurred within the Planning Area in the past. Future development projects anticipated within the Planning Area may involve grading, excavation, or other ground-disturbing activities into undisturbed sediments, which could destroy unknown paleontological resources. However, with the implementation of applicable local, State, and federal laws, the City’s standard conditions of development approval related to avoidance and preservation of paleontological resources, and mitigation measure MM-GEO-1, the contribution of the Project to this cumulative impact would not be cumulatively considerable.

4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.7-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.7 Greenhouse Gas Emissions

4.7.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on greenhouse gas emissions from future development allowed under the Project, including potential impacts related to generating greenhouse gas (GHG) emissions and conflicting with GHG reduction plans, policies, or regulations. The section provides context regarding the Planning Area’s existing conditions, as well as relevant federal, State, and local regulations and programs.

4.7.2 Environmental Setting
Regional Context
Global climate change refers to changes in average climatic conditions on Earth as a whole, including changes in temperature, wind patterns, precipitation, and severe weather events.

Global warming, a related concept, is the observed increase in average temperature of Earth’s surface and atmosphere. One identified cause of global warming is an increase of GHGs in the atmosphere. GHGs are those compounds in Earth’s atmosphere that play a critical role in determining Earth’s surface temperature.

Earth’s natural warming process is known as the “greenhouse effect.” It is called the greenhouse effect because Earth and the atmosphere surrounding it are similar to a greenhouse with glass panes in that the glass allows solar radiation (sunlight) into Earth’s atmosphere but prevents radiative heat from escaping, thus warming Earth’s atmosphere. Some levels of GHGs keep the average surface temperature of Earth close to a hospitable 60 degrees Fahrenheit. However, as GHG from human activities increase, they build up in the atmosphere and warm the climate, leading to many other changes around the world - in the atmosphere, on land, and in the oceans, with associated adverse climatic and ecological consequences. 1 Scientists studying the particularly rapid rise in global temperatures have determined that human activity has resulted in increased emissions of GHGs, primarily from the burning of fossil fuels (from motor vehicle travel, electricity generation, consumption of natural gas, industrial activity, manufacturing, etc.), deforestation, agricultural activity, and the decomposition of solid waste. Scientists refer to the global warming context of the past century as the “enhanced greenhouse effect” to distinguish it from the natural greenhouse effect. 2 Global GHG emissions due to human activities have grown since pre-industrial times. As reported by the USEPA, global carbon emissions from fossil fuels increased by over 16 times between 1900 and 2008 and by about 43 percent between 1990 and 2015. In addition, in the

1 United States Environmental Protection Agency (USEPA), 2023b. Climate Change Indicators: Greenhouse Gases, last updated on December 13, 2023. https://www.epa.gov/climate-indicators/greenhouse-gases. Accessed January 2024.
2 Pew Center on Global Climate Change, 2006. Climate Change 101: Understanding and Responding to Global Climate Change, October 12. https://www.pewtrusts.org/- /media/legacy/uploadedfiles/wwwpewtrustsorg/reports/global_warming/climate101full121406065519pdf.pdf.

Accessed January 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Global Carbon Budget 2022 report, published in November 2022, atmospheric CO2 concentrations in 2022 were found to be more than 50 percent above the concentration at the start of the Industrial Revolution, and the present concentration is the highest during at least the last 800,000 years.
3 Global increases in CO2 concentrations are due primarily to fossil fuel use, with land use change providing another significant but smaller contribution. Regarding emissions of non-CO
2 GHGs, these have also increased significantly since 1990.4 In particular, studies have concluded that it is very likely that the observed increase in methane (CH4) concentration is predominantly due to agriculture and fossil fuel use.5 GHGs are those compounds in the Earth’s atmosphere that play a critical role in determining temperature near the Earth’s surface. GHGs include CO
2, CH4, nitrous oxide (N2O),
hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF6), and nitrogen trifluoride (NF3).6 More specifically, these gases allow high-frequency shortwave solar radiation to enter the Earth’s atmosphere, but retain some of the low frequency infrared energy, which is radiated back from the Earth towards space, resulting in a warming of the atmosphere. Compounds that are regulated as GHGs are discussed in Table 4.7-1, Description of Identified GHGs. 7,8
Not all GHGs possess the same ability to induce climate change. CO2 is the most abundant GHG in Earth's atmosphere. Other GHGs are less abundant but have higher global warming potential (GWP) than CO

2. Thus, emissions of other GHGs are commonly quantified in the units of equivalent mass of carbon dioxide (CO2e). Mass emissions are calculated by converting pollutant specific emissions to CO2e emissions by applying the proper global warming potential (GWP) value.

The larger the GWP, the more that a given gas warms the Earth compared to CO2 over that time.9 These GWP ratios are available from the Intergovernmental Panel on Climate Change (IPCC). Historically, GHG emission inventories have been calculated using the GWPs from the IPCC’s Second Assessment Report (SAR). GWP is based on several factors, including the radiative efficiency (heat-absorbing ability) of each gas relative to that of CO 2, as well as the decay rate of
each gas (the amount removed from the atmosphere over a given number of years otherwise referred to as atmospheric lifetime) relative to that of CO

2. 3 P. Friedlingstein et al., 2020. Global Carbon Budget 2020. https://essd.copernicus.org/articles/12/3269/2020/.

Accessed January 2024.
4 USEPA, 2023c. Global Greenhouse Gas Emissions Data, last updated on February 15, 2023. www.epa.gov/ghgemissions/global-greenhouse-gas-emissions-data. Accessed January 2024. 5 USEPA, 2023a. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gas, last updated on November 1, 2023. https://www.epa.gov/climate-indicators/climate-change-indicators-atmospheric- concentrations-greenhouse-gases. Accessed January 2024. 6 As defined by California Assembly Bill (AB) 32 and Senate Bill (SB) 104. 7 Intergovernmental Panel on Climate Change (IPCC), 1995. Second Assessment Report, Working Group I: The Science of Climate Change.
8 IPCC, Fourth Assessment Report, 2007. Working Group I Report: The Physical Science Basis, Table 2.14. 9 GWPs and associated CO2e values were developed by IPCC and published in its Second Assessment Report (SAR) in 1996. Historically, GHG emission inventories have been calculated using the GWPs from the IPCC’s SAR. The IPCC updated the GWP values based on the latest science in its Fourth Assessment Report (AR4). CARB has begun reporting GHG emission inventories for California using the GWP values from the IPCC AR4.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.7-1

DESCRIPTION OF IDENTIFIED GHGS
GHG General Description
Carbon Dioxide (CO2) An odorless, colorless GHG, which has both natural and anthropocentric sources. Natural sources include the following: decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing.

Anthropogenic (human-caused) sources of CO
2 are burning coal, oil, natural gas, and wood.

Methane (CH4) A flammable gas and the main component of natural gas. When one molecule of CH4 is burned in the presence of oxygen, one molecule of CO2 and two molecules of water are released. A natural source of CH4 is the anaerobic decay of organic matter. Geological deposits, known as natural gas fields, also contain CH4, which is extracted for fuel. Other sources are from landfills, fermentation of manure, and cattle.

Nitrous Oxide (N2O) A colorless GHG. High concentrations can cause dizziness, euphoria, and sometimes slight hallucinations. N2O is produced by microbial processes in soil and water, including those reactions which occur in fertilizer containing nitrogen. In addition to agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid production, and vehicle emissions) also contribute to its atmospheric load. It is used in rocket engines, race cars, and as an aerosol spray propellant.

Hydrofluorocarbons
(HFCs)
Chlorofluorocarbons (CFCs) are gases formed synthetically by replacing all hydrogen atoms in CH
4 or ethane (C2H6) with chlorine and/or fluorine atoms. CFCs are non-toxic, non-flammable, insoluble, and chemically unreactive in the troposphere (the level of air at Earth’s surface).

CFCs were first synthesized in 1928 for use as refrigerants, aerosol propellants, and cleaning solvents. Because they destroy stratospheric ozone, the production of CFCs was stopped as required by the Montreal Protocol in 1987. HFCs are synthetic man-made chemicals that are used as a substitute for CFCs as refrigerants. HFCs deplete stratospheric ozone, but to a much lesser extent than CFCs.

Perfluorocarbons
(PFCs)
PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere. High-energy ultraviolet rays about 60 kilometers above Earth’s surface are able to destroy the compounds. PFCs have very long lifetimes, between 10,000 and 50,000 years. Two common PFCs are tetrafluoromethane and hexafluoroethane.

The two main sources of PFCs are primary aluminum production and semi-conductor manufacturing.

Sulfur Hexafluoride
(SF
6)
An inorganic, odorless, colorless, non-toxic, and non-flammable gas. SF6 is used for insulation in electric power transmission and distribution equipment, in the magnesium industry, in semi- conductor manufacturing, and as a tracer gas for leak detection.

Nitrogen Trifluoride
(NF3)
An inorganic, non-toxic, odorless, non-flammable gas. NF3 is used in the manufacture of semi- conductors, as an oxidizer of high energy fuels, for the preparation of tetrafluorohydrazine, as an etchant gas in the electronic industry, and as a fluorine source in high power chemical lasers.

NOTE: GHGs identified in this table are ones identified in the Kyoto Protocol and other synthetic gases recently added to the IPCC’s Fifth Assessment Report.

SOURCES: Association of Environmental Professionals, Alternative Approaches to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007; U.S. Environmental Protection Agency, Acute Exposure Guideline Levels (AEGLs) for Nitrogen Trifluoride; January 2009.

The IPCC updated the GWP values based on the science in its Fourth Assessment Report (AR4).10,11 The California Air Resources Board (CARB) reports GHG emission inventories for California using the GWP values from the IPCC AR4, which is consistent with international reporting standards. By applying the GWP ratios, Project-related CO 2e emissions can be

10 IPCC, Fourth Assessment Report, 2007. Working Group I Report: The Physical Science Basis. 11 IPCC, 1995. Second Assessment Report, Working Group I: The Science of Climate Change.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
tabulated in metric tons per year. Typically, the GWP ratio corresponding to the warming potential of CO2 over a 100-year period is used as a baseline.

The IPCC has issued an updated Fifth Assessment Report (AR5), which has reduced down the majority of the GWP for key regulated pollutants. As CARB still uses AR4 values and the modeling software California Emissions Estimator Model (CalEEMod) is built on these assumptions, AR4 GWP values are used for the Project. Generally, the changes from AR4 to AR5 are reductions in warming potential for the GHG most associated with construction and operation of typical development projects. The GWP from AR4 and AR5 and atmospheric lifetimes for key regulated GHGs are provided in Table 4.7-2, Atmospheric Lifetimes and GWPs.

TABLE 4.7-2

ATMOSPHERIC LIFETIMES AND GWPS
Gas
Atmospheric
Lifetime
(Years)
GWP
(100-Year
Time Horizon)
(AR4 Assessment)
GWP
(100-Year
Time Horizon)
(AR5 Assessment)
Carbon Dioxide (CO2) 50-200 1 1
Methane (CH4) 12 (+/-3) 25 28
Nitrous Oxide (N2O) 114 298 265
HFC-23: Fluoroform (CHF3) 270 14,800 12,400
HFC-134a: 1,1,1,2-Tetrafluoroethane (CH2FCF3) 14 1,430 1,300 HFC-152a: 1,1-Difluoroethane (C2H4F2) 1.4 124 138
PFC-14: Tetrafluoromethane (CF4) 50,000 7,390 6,630
PFC-116: Hexafluoroethane (C2F6) 10,000 12,200 11,100
Sulfur Hexafluoride (SF6) 3,200 22,800 23,500
Nitrogen Trifluoride (NF3) 740 17,200 16,100
SOURCE: IPCC, Climate Change 2007: Working Group I: The Physical Science Basis, Direct Global Warming Potentials.

Existing Statewide Greenhouse Gas Emissions
CARB compiles GHG inventories for California. Based on the year 2021 GHG inventory data (the latest year for which data are available), California emitted 381.3 million metric tons of CO 2e
(MMTCO2e) which includes emissions resulting from imported electrical power.12 Between 1990 and 2023, the population of California grew by approximately 32 percent (from 29.8 to 38.9 million).
13,14 In addition, the California economy, measured as gross state product, grew from approximately $773 billion in 1990 to $3.6 trillion in 2022, representing an increase of

12 California Air Resources Board, 2024b. Current California GHG Emission Inventory Data – 2000–2021 GHG Inventory (2023 Edition). https://ww2.arb.ca.gov/ghg-inventory-data. Accessed January 2024. 13 United States Census Bureau, 1995. National and State Population Estimates: 1990–1994, 1995. 14 California Department of Finance, 2024. E-5 Population and Housing Estimates for Cities, Counties, and the State, 2020–2023. https://dof.ca.gov/wp-content/uploads/sites/352/Forecasting/Demographics/Documents/E- 5_2023_InternetVersion.xlsx. Accessed January 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
approximately five times the 1990 gross state product.15 Despite the population and economic growth, California’s net GHG emissions were reduced to below 1990 levels in 2016 and has continued to decline. According to CARB, the declining trend coupled with the State’s GHG reduction programs (such as the Renewables Portfolio Standard [RPS], Low Carbon Fuel Standard [LCFS], vehicle efficiency standards, and declining caps under the Cap-and-Trade Program) demonstrate that California is on track to meet the 2030 GHG reduction target of 40 percent below 1990 levels codified in Executive Order B-30-15. Table 4.7 3, State of California Greenhouse Gas Emissions, identifies and quantifies statewide anthropogenic GHG emissions and sinks (e.g., carbon sequestration due to forest growth) in 1990 and 2021 (i.e., the most recent year in which data are available from CARB). As shown in Table 4.7-3, the transportation sector is the largest contributor to statewide GHG emissions at approximately 39 percent in 2021.

TABLE 4.7-3

STATE OF CALIFORNIA GREENHOUSE GAS EMISSIONS
Category
Total 1990 Emissions
using IPCC SAR
(MMTCO2e)
Percent of
Total 1990
Emissions
Total 2021 Emissions
using IPCC AR4
(MMTCO2e)
Percent of Total
2021 Emissions
Transportation 150.7 35% 145.6 38%
Electric Power 110.6 26% 62.4 16%
Commercial 14.4 3% 13.3 4%
Residential 29.7 7% 25.5 7%
Industrial 103.0 24% 73.9 19%
Recycling and Wastea — — 8.4 2%
High GWP/Non-Specifiedb 1.3 <1% 21.3 6%
Agriculture/Forestry 23.6 6% 30.9 8%
Forestry Sinks -6.7 — — c —
Net Total (IPCC SAR) 426.6 100% — —
Net Total (IPCC AR4)d 431 100% 381.3 100%
NOTES: IPCC = Intergovernmental Panel on Climate Change; SAR = Second Assessment Report; AR4 = Fourth Assessment Report; MMTCO2e = million metric tons of carbon dioxide equivalent; GWP = global warming potential Totals may not add up exactly due to rounding.
a Included in other categories for the 1990 emissions inventory. b High GWP gases are not specifically called out in the 1990 emissions inventory. c Revised methodology under development (not reported for 2021). d CARB revised the state’s 1990 level GHG emissions using GWPs from the IPCC AR4.

SOURCE: California Air Resources Board, 2023e, California Greenhouse Gas Inventory for 2000 to 2021. by Category as Defined in the 2008 Scoping Plan, December 13, 2023. https://ww2.arb.ca.gov/sites/default/files/2023-12/ghg_inventory_scopingplan_sum_2000-21.pdf. Accessed January 2024

Urban Heat Island
According to the California Environmental Protection Agency (CalEPA), the urban heat island effect refers to large, urbanized areas that experience higher temperatures, greater pollution and more negative health impacts during hot summer months when compared to more rural

15 California Department of Finance, 2023. Gross State Product in California. https://dof.ca.gov/wp- content/uploads/sites/352/2023/06/CA-GDP.xlsx. Accessed January 2024. Amounts are based on current dollars as of the date of the report (June 2023).

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
communities.16 Heat islands are created by a combination of heat-absorptive surfaces (such as dark pavement and roofing), heat-generating activities (such as engines and generators) and the absence of vegetation (which provides evaporative cooling). Daytime temperatures in urban areas are on average 1 to 6 degrees Fahrenheit (F) higher than in rural areas, while nighttime temperatures can be as much as 22 degrees F higher as the heat is gradually released from buildings and pavement.
17 Assembly Bill (AB) 296 (Chapter 667, Statutes of 2012) required that CalEPA develop an Urban Heat Island Index (UHII) to quantify the extent and severity of an urban heat island for individual cities to map where and how intensely they manifest at a local scale.
18 In 2015, CalEPA released maps that show the scientifically assigned UHII scores based on atmospheric modeling for each census tract in and around most urban areas throughout the state. The urban area in which the city of Culver City is located has an approximate UHII range of 2001 to 4000 degree-hours per 182 days or 11 to 22 degree-hours per day (Celsius scale). 19 The
UHII range is equivalent to an average temperature difference between rural and urban areas of approximately 0.8 to 3.3 degrees F.
20 It is important to note that the UHII does not measure the temperatures of an area, but rather it measures the average temperature difference between rural and urban areas within a region.

Effects of Global Climate Change
The scientific community’s understanding of the fundamental processes responsible for global climate change has improved over the past decade, and its predictive capabilities are advancing.

However, there remain significant scientific uncertainties, for example, in predictions of local effects of climate change, occurrence, frequency, and magnitude of extreme weather events, effects of aerosols, changes in clouds, shifts in the intensity and distribution of precipitation, and changes in oceanic circulation. Due to the complexity of the Earth’s climate system and inability to accurately model it, the uncertainty surrounding climate change may never be completely eliminated. Nonetheless, the IPCC’s Fifth Assessment Report: Summary for Policy Makers (dated 2013) states that, “it is extremely likely that more than half of the observed increase in global average surface temperature from 1951 to 2010 was caused by the anthropogenic increase in GHG concentrations and other anthropogenic forces [sic] together.” 21 In addition, a report from
the National Academy of Sciences published in 2010 concluded that 97 to 98 percent of the

16 California Environmental Protection Agency, 2023b. Understanding the Urban Heat Island Index. https://calepa.ca.gov/climate/urban-heat-island-index-for-california/understanding-the-urban-heat-island-index/.

Accessed January 2024.
17 California Environmental Protection Agency, 2023b. Understanding the Urban Heat Island Index. https://calepa.ca.gov/climate/urban-heat-island-index-for-california/understanding-the-urban-heat-island-index/.

Accessed January 2024.
18 California Environmental Protection Agency, 2023b. Understanding the Urban Heat Island Index. https://calepa.ca.gov/climate/urban-heat-island-index-for-california/understanding-the-urban-heat-island-index/.

Accessed January 2024.
19 California Environmental Protection Agency, 2023c. Understanding the Urban Heat Island Index, Appendix C, Figure C41. https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/UrbanHeat-Report-AppendixC.pdf.

Accessed January 2024. According to CalEPA, the degree-hour combines both the intensity of the heat and the duration of the heat into a single numerical measure.
20 According to CalEPA, to perform an approximate conversion to a total number of degrees Fahrenheit per day, divide the Index by 24 hours and multiply the result by 1.8 degrees. For example, if the Index is 44 degree-hours per day, then the approximate average temperature difference between rural and urban in that area is 3.3 degrees F (i.e., 44 / 24 * 1.8 = 3.3).
21 IPCC, 2013. Fifth Assessment Report, Summary for Policy Makers, page 17.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
climate researchers most actively publishing in the field support the tenets of the IPCC in that climate change is very likely caused by human (i.e., anthropogenic) activity.22 According to CalEPA, the potential impacts in California due to global climate change may include: loss in snow pack; sea level rise; more extreme heat days per year; more high ozone days; more frequent and a greater spatial extent of forest fires; more drought years; increased erosion of California’s coastlines and sea water intrusion into the Sacramento and San Joaquin Deltas and associated levee systems; and increased pest infestation. 23 The California Energy
Commission (CEC) has a geospatial data tool (Cal-Adapt) that provides a view of how the state could be impacted by climate change. Below is a summary of some of the potential climate change effects and relevant Cal-Adapt data, reported by an array of studies that could be experienced in California as a result of global warming and climate change.

Air Quality
Higher temperatures have been determined to be conducive to air pollution formation and, therefore, could worsen air quality in California. Climate change may increase the concentration of ground- level ozone; however, the magnitude of the effect is uncertain. If higher temperatures resulting from climate change are accompanied by drier conditions, the potential for large wildfires could increase within the Los Angeles region, which, in turn, would further worsen air quality. However, if higher temperatures resulting from climate change are accompanied by wetter, rather than drier conditions, the rains would tend to temporarily clear the air of particulate pollution and reduce the incidence of large wildfires, thus ameliorating some of the pollution associated with wildfires, although it would not eliminate all effects of increased temperatures. Additionally, severe heat accompanied by drier conditions and poor air quality could increase the number of heat -related deaths, illnesses, and asthma attacks throughout the state.
24 According to the Cal-Adapt website’s “Local Climate Change Snapshot” database, Culver City could see an average annual increase in maximum temperature to 73.8 to 74.6°F in the mid- century (2035–2064) and 74.8 to 77.7°F at the end of the century (2070–2099) compared to

70.8°F for the baseline period (1961–1990). The average annual number of extreme heat days also could increase to 5 to 6 days in the mid-century (2035–2064) and 7 to 16 days at the end of the century (2070–2099) compared to 2 days for the baseline period (1961– 1990). 25 Water Supply
Uncertainty remains with respect to the overall impact of global climate change on future water supplies in California. Studies have found that, “Considerable uncertainty about precise impacts

22 Anderegg, William R. L., J.W. Prall, J. Harold, S.H. Schneider, 2010. Expert Credibility in Climate Change, Proceedings of the National Academy of Sciences of the United States of America. 107:12107–12109. 23 California Environmental Protection Agency, 2006. Climate Action Team, Climate Action Team Report to Governor Schwarzenegger and the Legislature.
https://efiling.energy.ca.gov/GetDocument.aspx?tn=204014&DocumentContentId=2726. Accessed January 2024. 24 California Environmental Protection Agency, 2006. Climate Action Team, Climate Action Team Report to Governor Schwarzenegger and the Legislature.
https://efiling.energy.ca.gov/GetDocument.aspx?tn=204014&DocumentContentId=2726. Accessed January 2024. 25 CalAdapt, 2024. Local Climate Change Snapshot Culver City, California. https://cal-adapt.org/tools/local-climate- change-snapshot/. Accessed January 2024.

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of climate change on California hydrology and water resources will remain until we have more precise and consistent information about how precipitation patterns, timing, and intensity will change.”
26 For example, some studies identify little change in total annual precipitation in projections for California while others show significantly more precipitation. 27 Warmer, wetter winters would increase the amount of runoff available for groundwater recharge; however, this additional runoff would occur at a time when some basins are either being recharged at their maximum capacity or are already full.
28 Conversely, reductions in spring runoff and higher
evapotranspiration because of higher temperatures could reduce the amount of water available for recharge.
29 According to the Cal-Adapt website’s “Local Climate Change Snapshot” database, Culver City could see an average annual length of dry spells of 168 to 169 days in the mid-century (2035–2064) and 169 to 177 days at the end of the century (2070–2099), compared to 161 days for the baseline period (1961–1990). The average annual precipitation could decrease to 14.5 to 14.6 inches in the mid-century (2035–2064) and potentially increase or decrease to 14.9 to 14.7 inches at the end of the century (2070–2099), compared to 14.8 inches for the baseline period (1961–1990).30 The California Department of Water Resources (CDWR) report dated 2006 on climate change and effects on the State Water Project (SWP), the Central Valley Project, and the Sacramento- San Joaquin Delta, concluded that “climate change will likely have a significant effect on California’s future water resources…[and] future water demand.” It also reported that “much uncertainty about future water demand [remains], especially [for] those aspects of future demand that will be directly affected by climate change and warming. While climate change is expected to continue through at least the end of this century, the magnitude and, in some cases, the nature of future changes is uncertain.” It also reported that the relationship between climate change and its potential effect on water demand is not well understood, but “[i]t is unlikely that this level of uncertainty will diminish significantly in the foreseeable future.” Still, changes in water supply are expected to occur, and many regional studies have shown that large changes in the reliability of water yields from reservoirs could result from only small changes in inflows.
31 In its Fifth Assessment Report, the IPCC states “Changes in the global water cycle in response to the warming over the 21st century will not be uniform. The contrast in precipitation

26 Pacific Institute for Studies in Development, Environment and Security, 2003. Climate Change and California Water Resources: A Survey and Summary of the Literature. July. https://pacinst.org/wp- content/uploads/2003/07/climate_change_and_california_water_resources.pdf. Accessed January 2024. 27 Pacific Institute for Studies in Development, Environment and Security, 2003. Climate Change and California Water Resources: A Survey and Summary of the Literature. July. https://pacinst.org/wp- content/uploads/2003/07/climate_change_and_california_water_resources.pdf. Accessed January 2024. 28 Pacific Institute for Studies in Development, Environment and Security, 2003. Climate Change and California Water Resources: A Survey and Summary of the Literature. July. https://pacinst.org/wp- content/uploads/2003/07/climate_change_and_california_water_resources.pdf. Accessed January 2024. 29 Pacific Institute for Studies in Development, Environment and Security, 2003. Climate Change and California Water Resources: A Survey and Summary of the Literature. July. https://pacinst.org/wp- content/uploads/2003/07/climate_change_and_california_water_resources.pdf. Accessed January 2024. 30 CalAdapt, 2024. Local Climate Change Snapshot Culver City, California. https://cal-adapt.org/tools/local-climate- change-snapshot/. Accessed January 2024.
31 California Department of Water Resources, 2006. Climate Change Report, Progress on Incorporating Climate Change into Planning and Management of California’s Water Resources, page 2-75.

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between wet and dry regions and between wet and dry seasons will increase, although there may be regional exceptions.”32
Hydrology and Sea Level Rise
As discussed above, climate changes could potentially affect the amount of snowfall, rainfall and snow pack; the intensity and frequency of storms; flood hydrographs (flash floods, rain or snow events, coincidental high tide and high runoff events); sea level rise and coastal flooding; coastal erosion; and the potential for salt water intrusion. Sea level rise can be a product of global warming through two main processes: expansion of seawater as the oceans warm and melting of ice over land. A rise in sea levels could result in coastal flooding and erosion and could jeopardize California’s water supply, and increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events. Models estimate that under mid to high sea-level rise scenarios (3 to 6.6 feet [0.9 to 2 meters]), 31 to 67 percent of Southern California beaches may completely erode by 2100 without large-scale human interventions.
33 Agriculture
California has a $30 billion agricultural industry that produces one half of the country’s fruits and vegetables. Higher CO
2 levels can stimulate plant production and increase plant water-use efficiency. However, if temperatures rise and drier conditions prevail, water demand could increase without planning and preparations. Under changing climate conditions, agriculture is projected to experience lower crop yields due to extreme heat waves, heat stress and increased water needs of crops and livestock (particularly during dry and warm years), and new and changing pest and disease threats.
34 Ecosystems and Wildlife
Increases in global temperatures and the potential resulting changes in weather patterns could have ecological effects on a global and local scale. Increasing concentrations of GHGs are likely to accelerate the rate of climate change. Scientists expect that the average global surface temperature could rise by 1.1 to 10.2°F (0.6 to 5.7°C) by 2100, with significant regional variation.
35 With increases in global temperatures, soil moisture is likely to decline in many regions, and intense rainstorms are likely to become more frequent. Sea level could rise as much as 3 to 6.6 feet (0.9 to 2 m) along most of the U.S. coastline. 36 Rising temperatures and
precipitation change could impact ecosystems and wildlife by causing population declines,

32 IPCC, 2013. Fifth Assessment Report, Summary for Policy Makers . 33 California Climate Change Assessment, 2018. California’s Fourth Climate Change Assessment Statewide Summary Report, November. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4- 2018-013_Statewide_Summary_Report_ADA.pdf. Accessed January 2024. 34 California Climate Change Assessment, 2018. California’s Fourth Climate Change Assessment Statewide Summary Report, November. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4- 2018-013_Statewide_Summary_Report_ADA.pdf. Accessed January 2024. 35 U.S. Global Change Research Program, 2018. Climate Science Special Report: Fourth National Climate Assessment, Volume 1, Executive Summary. https://science2017.globalchange.gov/chapter/executive-summary/. Accessed January 2024.
36 U.S. Global Change Research Program, 2018. Climate Science Special Report: Fourth National Climate Assessment, Volume 1, Executive Summary. https://science2017.globalchange.gov/chapter/executive-summary/. Accessed January 2024.

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shifting in their geographic distributions or ranges to track suitable climates, and facilitating the spread of invasive species, pest, pathogens, and diseases. 37 Wildfire
Wildfires in California over the past two decades are shown to be increasing in size, severity, and adverse impacts.
38 Warming temperature as a result of climate change influences the length of both the fire and growing seasons and consequently affects the amount of time and intensity fires burn at and the amount of available fuels. Higher temperatures lead to drought, which decreases the fuel moisture and increases the likelihood of ignitions. 39 According to the Cal-Adapt website’s “Local Climate Change Snapshot” database, Culver City could see an average annual area burned of approximately 0 acres in the mid-century (2035– 2064) and end of the century (2070–2099), compared to 0 acres for the baseline period (1961 – 1990).40 Increased wildfire activity leads to more GHG emissions from sources that would otherwise be carbon sinks.41 Between 2000 and 2019, emissions from wildfires ranged from a low of 1.2 MMTCO2e in 2010 to a high of 39 MMTCO2e in 2018, with an annual average of 14 MMTCO2e. Further, CARB estimates that wildfire emissions increased dramatically in 2020, totaling 112 MMTCO2e.42
Humans
Humans are better able to adapt to a changing climate than plants and animals in natural ecosystems. Nevertheless, climate change poses direct and indirect risks to public health, as people will experience earlier death and worsening illnesses. Temperature increases cause heat- related deaths and illnesses. In 2006, reported heat-related deaths and illness were much higher than in any other year because of a prolonged heat wave. 43 Nineteen heat-related events that
had significant impacts on human health occurred from 1999 to 2009, resulting in about 11,000

37 U.S. Global Change Research Program, 2018. Climate Science Special Report: Fourth National Climate Assessment, Volume 1, Executive Summary. https://science2017.globalchange.gov/chapter/executive-summary/. Accessed January 2024.
38 CARB, 2020a. Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities. December.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/pubs/ca_ghg_wildfire_forestmanagement.pdf?ut m_medium=email&utm_source=govdelivery. Accessed January 2024. 39 CARB, 2020a. Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities. December.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/pubs/ca_ghg_wildfire_forestmanagement.pdf?ut m_medium=email&utm_source=govdelivery. Accessed January 2024. 40 CalAdapt, 2024. Local Climate Change Snapshot Culver City, California. https://cal-adapt.org/tools/local-climate- change-snapshot/. Accessed January 2024.
41 CARB, 2020a. Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities. December.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/pubs/ca_ghg_wildfire_forestmanagement.pdf?ut m_medium=email&utm_source=govdelivery. Accessed January 2024. 42 CARB, 2020a. Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities. December.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/pubs/ca_ghg_wildfire_forestmanagement.pdf?ut m_medium=email&utm_source=govdelivery. Accessed January 2024. 43 Office of Environmental Health Hazard Assessment (OEHHA), 2018. Indicators of Climate Change in California.

May. https://oehha.ca.gov/media/downloads/climate-change/report/2018caindicatorsreportmay2018.pdf.

Accessed January 2024.

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excess hospitalizations.44 Additionally, indicators of the impacts of climate change on human health show that warming temperatures and changes in precipitation can affect vector-borne pathogen transmission and disease patterns in California.

Existing Conditions
Culver City is a mix of residential, commercial, retail, office, industrial, school, recreational, and open space land uses. A Culver City community wide GHG inventory was conducted in 2019 (2019 Community GHG Inventory Report), with the purpose of showing source types, distribution, and amount of GHG emissions within Culver City.45 Specifically, the 2019 Community GHG Inventory Report includes emissions for the calendar year 2019 from electricity, natural gas, transportation, solid waste, off-road equipment, industrial sources, water supply, and wastewater treatment activities occurring within the city limits and the sphere of influence.
46 The 2019 Community GHG Inventory Report factors in emissions from energy used by buildings, traffic signals, streetlights, water conveyance (both within the jurisdictional boundary and upstream of the city), and wastewater treatment.

The emission sources and activities included in the 2019 Community GHG Inventory Report are based on the U.S. Community Protocol for Accounting and Reporting of Greenhouse Gas Emissions (U.S. Community Protocol). Local Governments for Sustainability (ICLEI) created the U.S. Community Protocol, which sets guidelines and methods that help local governments quantify and report GHG emissions from community-wide activities. 47 The 2019 Community
GHG Inventory Report reviews emissions from sources that local government can influence. This generally includes activities within the City’s jurisdictional boundary where the local government has jurisdictional influence and community activities outside City limits, e.g., automobile use by residents. Table 4.7-4, Estimated Existing Culver City Operational GHG Emissions (2019), presents the community GHG emissions from the existing development in Culver City in 2019.

44 California Climate Change Assessment, 2018. California’s Fourth Climate Change Assessment Statewide Summary Report, November. https://www.energy.ca.gov/sites/default/files/2019-11/Statewide_Reports-SUM-CCCA4- 2018-013_Statewide_Summary_Report_ADA.pdf. Accessed January 2024. 45 Culver City, 2021. 2019 Community Greenhouse Gas Inventory Report. April. https://9021zeroemissions.rinconconsultants.com/wp-content/uploads/2021/11/2.- CulverCity_2019_Community_GHG_Inventory_Clean.pdf. Accessed January 2024. 46 Mobile and bus emissions associated with the sphere of influence are reflected in the on-road vehicular transportation calculations. All other calculations reflect sources within the city limits. 47 Local Governments for Sustainability (ICLEI) was formerly the International Council for Local Environmental Initiatives.

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TABLE 4.7-4
ESTIMATED EXISTING CULVER CITY OPERATIONAL GHG EMISSIONS (2019) Source MTCO2e Percent
On-road Transportation 164,246 56.3
Natural Gas 59,678 20.4
Electricity 33,740 11.6
Solid Waste 16,529 5.7
Off-road Equipment 14,469 5.0
Water Supply 2,497 0.9
Industrial Sources 383 0.1
Wastewater Treatment 380 0.1
Total 291,922 100
NOTES: MTCO2e = metric tons of carbon dioxide equivalent SOURCE: Culver City, 2021. 2019 Community Greenhouse Gas Inventory Report. April.

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

Federal
Federal Clean Air Act
The United States Environmental Protection Agency (USEPA) is responsible for implementing federal policy to address GHGs. The United States Supreme Court (Supreme Court) ruled in Massachusetts v. Environmental Protection Agency, 127 S.Ct. 1438 (2007), that carbon dioxide (CO
2) and other GHGs are pollutants under the Federal Clean Air Act (CAA), which the USEPA must regulate if it determines they pose an endangerment to public health or welfare. In December 2009, USEPA issued an endangerment finding for GHGs under the CAA, setting the stage for future regulation.

The Federal Government administers a wide array of public-private partnerships to reduce the GHG intensity generated in the United States. These programs focus on energy efficiency, renewable energy, CH
4 and other non-CO2 gases, agricultural practices, and implementation of technologies to achieve GHG reductions. USEPA implements numerous voluntary programs that contribute to the reduction of GHG emissions. These programs (e.g., the ENERGY STAR labeling system for energy-efficient products) play a significant role in encouraging voluntary reductions from large corporations, consumers, industrial and commercial buildings, and many major industrial sectors.

Corporate Average Fuel Economy Standards
In response to the Massachusetts v. Environmental Protection Agency ruling, President George W. Bush issued Executive Order 13432 in 2007, directing the USEPA, the U.S. Department of Transportation (USDOT), and the U.S. Department of Energy (USDOE) to establish regulations

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that reduce GHG emissions from motor vehicles, non-road vehicles, and non-road engines by 2008. The National Highway Traffic Safety Administration (NHTSA) subsequently issued multiple final rules regulating fuel efficiency for, and GHG emissions from, cars and light-duty trucks for model year 2011 and later for model years 2012–2016 and 2017– 2021. In April 2020, the USDOT and the USEPA issued the final Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, which amends existing CAFE standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establishes new standards covering model years 2021 through 2026. 48 These standards set a combined fleet wide average of 33.2 to 37.1 for the model years affected.
49 In February 2022, the USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.50 This final rule revises current GHG standards beginning for vehicles in model year 2023 and through model year 2026 and establishes the most stringent GHG standards ever set for the light-duty vehicle sector that are expected to result in average fuel economy label values of 40 mpg, while the standards they replace (the SAFE rule standards) would achieve only 32 mpg in model year 2026 vehicles.
51 In addition to the regulations applicable to cars and light-duty trucks described above, in 2011 the USEPA and NHTSA announced fuel economy and GHG standards for medium- and heavy- duty trucks for model years 2014–2018. The standards for CO 2 emissions and fuel consumption
are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the USEPA, this regulatory program would reduce GHG emissions and fuel consumption for the affected vehicles by 6 to 23 percent over the 2010 baselines. Building on the first phase of standards, in August 2016, the USEPA and NHTSA finalized Phase 2 standards for medium and heavy-duty vehicles through model year 2027 that will improve fuel efficiency and cut carbon pollution. The Phase 2 standards are expected to lower CO
2 emissions by approximately 1.1 billion metric tons.52 On July 28, 2023, the NHTSA proposed new CAFE standards for passenger cars and light trucks for model years 2027 through 2032, and new fuel efficiency standards for heavy-duty pickup trucks and vans for model years 2030 through 2035. The proposed rule would require an industry fleet-wide average of approximately 58 mpg for passenger cars and light trucks in model year 2032, by increasing fuel economy by two percent year over year for passenger cars

48 USEPA, 2020. Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30. https://www.govinfo.gov/content/pkg/FR-2020- 04-30/pdf/2020-06967.pdf. Accessed January 2024.
49 USEPA, 2020. Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30. https://www.govinfo.gov/content/pkg/FR-2020- 04-30/pdf/2020-06967.pdf. Accessed January 2024.
50 USEPA, 2021. Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 51 USEPA, 2021. Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 52 USEPA and NHTSA, 2016. Adopt Standards to Reduce GHG and Improve Fuel Efficiency of Medium- and Heavy- Duty Vehicles for Model Year 2018 and Beyond, August. https://www.govinfo.gov/content/pkg/FR-2016-10- 25/pdf/2016-21203.pdf . Accessed January 2024.

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and four percent year over year for light trucks.53 For heavy-duty pickup trucks and vans, the proposed rule would increase fuel efficiency by 10 percent year over year.54 Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national GHG emissions by requiring the following:
• Increasing the supply of alternative fuel sources by setting mandatory Renewable Fuel Standards (RFS) that requires fuel producers to use at least 36 billion gallons of biofuel in 2022;
• Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances;
• Requiring approximately 25 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020; and • While superseded by the USEPA and the NHTSA actions described above (refer to United States Department of Transportation, United States Department of Energy, and United States Environmental Protection Agency, above) (i) establishing miles per gallon targets for cars and light trucks and (ii) directing the NHTSA to establish a fuel economy program for medium- and heavy-duty trucks and create a separate fuel economy standard for trucks.

Additional provisions of EISA address energy savings in government and public institutions, promote research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”
55 State
California has promulgated a series of executive orders, laws, and regulations aimed at reducing both the level of GHGs in the atmosphere and emissions of GHGs from commercial and private activities within the state.

Executive Order S-1-07
EO S-1-0756 proclaims that the transportation sector is California’s main source of GHG emissions, generating more than 40 percent of statewide emissions. It established a goal to reduce the carbon intensity of transportation fuels sold in California by at least 10 percent by

53 National Highway Traffic Safety Administration, 2023. Corporate Average Fuel Economy. https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy#75896. Accessed January 2024. 54 National Highway Traffic Safety Administration, 2023. Corporate Average Fuel Economy. https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy#75896. Accessed January 2024. 55 A “green job,” as defined by the United States Department of Labor, is a job in business that produces goods or provides services that benefit the environment or conserve natural resources. 56 Office of the Governor of California, 2007. Executive Order S-01-07, January 18. https://climateactionnetwork.ca/wp-content/uploads/2011/06/eos0107.pdf. Accessed January 2024.

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2020. This order also directed CARB to determine whether the Low Carbon Fuel Standard could be adopted as a discrete early-action measure, as part of the effort to meet AB 32 mandates.

Executive Order S-3-05
EO S-3-05 set forth the following targets for progressively reducing statewide GHG emissions: 57 • By 2010, reduce GHG emissions to 2000 levels.
• By 2020, reduce GHG emissions to 1990 levels.
• By 2050, reduce GHG emissions to 80 percent below 1990 levels.

The executive order directed the Secretary of CalEPA to coordinate a multi-agency effort to reduce GHG emissions to the target levels. The Secretary is also mandating that biannual reports be submitted to the California Governor and Legislature describing the progress made toward the emissions targets, the impacts of global climate change on California’s resources, and mitigation and adaptation plans to combat these impacts. To comply with the executive order, the secretary of CalEPA created the California Climate Action Team (CAT), made up of members from various state agencies and commissions. The first CAT Report to the Governor and the Legislature in 2006 contained recommendations and strategies to help meet the targets in EO S- 3-05. The most recent 2022 State Agency Greenhouse Gas Reduction Report Card documents the effectiveness of measures to reduce GHG emissions in California and GHG emissions from state agencies’ operations. This report card documents reductions of 1.157 MMTCO 2e that
occurred in 2021. 58 In 2016, GHG emissions were 429 MMTCO2e, showing that California reached its 2020 emissions target (431 MMTCO2e) four years early, and emissions are continuing to decline.

Executive Order B-30-15
In 2015, EO B-30-15 promulgated the following targets and measures:59 • Established a new interim statewide reduction target to reduce GHG emissions to 40 percent below 1990 levels by 2030.
• Ordered all state agencies with jurisdiction over sources of GHG emissions to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 reduction targets.
• Directed CARB to update the Climate Change Scoping Plan to express the 2030 target in terms of million metric tons of carbon dioxide equivalent.

57 Office of the Governor of California, 2005. Executive Order S-3-05, June 2. https://www.library.ca.gov/wp- content/uploads/GovernmentPublications/executive-order-proclamation/5129-5130.pdf. Accessed January 2024. 58 CalEPA, 2023a. 2022 State Agency Greenhouse Gas Reduction Report Card. https://calepa.ca.gov/wp- content/uploads/sites/6/2023/05/CAT-Report-Card-2022.a.pdf. Accessed January 2024. 59 Office of the Governor of California, 2015. Executive Order B-30-15, April 29. https://www.library.ca.gov/wp- content/uploads/GovernmentPublications/executive-order-proclamation/39-B-30-15.pdf. Accessed January 2024.

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Executive Order B-55-18
EO B-55-18 was signed by Governor Edmund G. Brown Jr. on September 10, 2018.60 The order establishes an additional statewide policy to achieve carbon neutrality by 2045 and maintain net negative emissions thereafter. As per EO B-55-18, CARB is directed to work with relevant state agencies to develop a framework for implementation and accounting that tracks progress toward this goal and to ensure future Climate Change Scoping Plans identify and recommend measures to achieve the carbon neutrality goal. California is making progress towards the 2045 goal, however the pathway to carbon neutrality is still under development. According to CARB, there will be a strong reliance on energy efficiency, electrification, low carbon fuels (including low-carbon electricity), and CO
2 removal in future policies and strategies for reaching the ambitious goal. The path to carbon neutrality lies in striving for zero emissions from all new sources and maximum sequestration to offset existing sources.

Assembly Bill 32 – California Global Warming Solutions Act of 2006 In 2006, the California Legislature adopted Assembly Bill (AB) 32 (Health and Safety Code Division 25.5), also known as the California Global Warming Solutions Act of 2006, with a focus on reducing GHG emissions in California to 1990 levels by 2020. This act defines GHGs as CO 2,
methane, nitrous oxide, hydrofluorocarbons, perfluorocarbons, and sulfur hexafluoride and represents the first enforceable statewide program to limit emissions of these GHGs from all major industries with penalties for noncompliance. The law further requires that reduction measures be technologically feasible and cost effective. The California Global Warming Solutions Act assigned CARB the primary responsibility for reducing GHG emissions, by adopting rules and regulations directing state actions that would achieve GHG emissions reductions equivalent to 1990 statewide levels by 2020.

As required by the California Global Warming Solutions Act, CARB approved the 1990 GHG emissions inventory, thereby establishing the emissions limit for 2020, originally set at 427 MMTCO
2e, using the GWP values from the IPCC SAR. CARB established the GHG emissions reduction target based on GWP values from the IPCC AR4 and determined that the 1990 GHG emissions inventory and 2020 GHG emissions limit is 431 MMTCO 2e.

CARB approved the initial AB 32 Scoping Plan in 2008.61 It approved the First Update to the Climate Change Scoping Plan (2014 Scoping Plan) in May 2014 and built upon the 2008 Scoping Plan with new strategies and recommendations.
62 In 2014, CARB revised the target using the
GWP values from the IPCC AR4 and determined that the 1990 GHG emissions inventory and 2020 GHG emissions limit is 431 MMTCO
2e. CARB also updated the state’s 2020 business-as-
usual (BAU) emissions estimate to account for the impact of the 2007– 2009 economic recession, new estimates for future fuel and energy demand, and the reductions required by

60 Office of the Governor of California, 2018. Executive Order, September 10. https://www.ca.gov/archive/gov39/wp-content/uploads/2018/09/9.10.18-Executive-Order.pdf. Accessed January 2024.
61 CARB, 2009. Climate Change Scoping Plan a framework for change, December. 62 CARB, 2014. First Update to the Climate Change Scoping Plan Building on the Framework, May.

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regulation that were adopted for motor vehicles and renewable energy. CARB’s projected statewide 2020 emissions estimate using the GWP values from the IPCC AR4 is 509.4 MMTCO2e.

Therefore, under the 2014 Scoping Plan, the emission reductions necessary to achieve the 2020 emissions target of 431 MMTCO
2e would be 78.4 MMTCO2e, or a reduction of GHG emissions by approximately 15.4 percent.

Senate Bill 32 and Assembly Bill 197
In 2016, the California Legislature adopted Senate Bill (SB) 32 and its companion bill AB 197. SB 32 and AB 197 amended Health and Safety Code Division 25.5 and established a new climate pollution reduction target of 40 percent below 1990 levels by 2030, with provisions included to ensure that the benefits of state climate policies reach into vulnerable communities. In response to the 2030 GHG reduction target, CARB adopted the 2017 Scoping Plan. 63 The 2017 Scoping
Plan outlines the strategies the state will implement to achieve the 2030 GHG emissions reduction target, which build on the Cap-and-Trade Program; the Low Carbon Fuel Standard; improved vehicle, truck, and freight movement emissions standards; increasing renewable energy; and strategies to reduce methane emissions from agricultural and other wastes by using it to meet California’s energy needs. CARB’s projected statewide 2030 emissions take into account 2020 GHG reduction policies and programs. The 2017 Scoping Plan also comprehensively addresses GHG emissions from natural and working lands of California, including the agriculture and forestry sectors. The adopted 2017 Scoping Plan includes ongoing and statutorily required programs and the continuation of the Cap-and-Trade Program. This Scoping Plan Scenario was modified from the January 2017 Proposed Scoping Plan to reflect AB 398,
64 including removal of the 20 percent refinery measure.

The 2017 Scoping Plan outlines the strategies the State of California will implement to achieve the 2030 GHG emissions reduction target. The 2017 Scoping Plan includes the Scoping Plan Scenario, which CARB stated “is the best choice to achieve the state’s climate and clean air goals”.
65 Under the Scoping Plan Scenario, continuation of the Cap-and-Trade regulation (or carbon tax) is expected to cover approximately 34–79 MMTCO2e of the 2030 reduction obligation.66 The short-lived GHG strategy is expected to cover approximately 17–35 MMTCO2e.

The Renewables Portfolio Standard with 50 percent renewable electricity by 2030 is expected to cover approximately 3 MMTCO
2e. The mobile-source strategy and sustainable freight action plan includes maintaining the existing vehicle GHG emissions standards, increasing the number of ZEVs, and improving the efficiency of the freight system, and is expected to cover approximately 11–13 MMTCO
2e. Under the Scoping Plan Scenario, CARB expects that the doubling of the energy efficiency savings by 2030 would cover approximately 7–9 MMTCO2e of

63 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November. 64 AB 398 was enacted in 2017 to extend and clarify the role of the State’s Cap-and-Trade Program through December 31, 2030. As part of AB 398, refinements were made to the Cap-and-Trade program to establish updated protocols and allocation of proceeds to reduce GHG emissions. 65 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November. 66 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
the 2030 reduction obligation. The other strategies would be expected to cover the remaining 2030 reduction obligations.

The 2017 Scoping Plan also discusses the role of local governments in meeting the state’s GHG reductions goals because local governments have jurisdiction and land use authority related to community-scale planning and permitting processes, local codes and actions, outreach and education programs, and municipal operations. Furthermore, local governments may have the ability to incentivize renewable energy, energy efficiency, and water efficiency measures. 67 The
2017 Scoping Plan encourages local governments to adopt climate action plans (CAPs) to address local GHG emissions sources. For individual projects under the California Environmental Quality Act (CEQA), the 2017 Scoping Plan states that local governments can support climate action when considering discretionary approvals and entitlements. According to the 2017 Scoping Plan, lead agencies have the discretion to develop evidence-based numeric thresholds consistent with the 2017 Scoping Plan, the State’s long-term goals, and climate change science. 68 Assembly Bill 1279 and 2022 Scoping Plan
The Legislature enacted AB 1279, The California Climate Crisis Act, on September 16, 2022.69 AB 1279 establishes the policy of the State of California to achieve net zero GHG emissions as soon as possible but no later than 2045, and to achieve and maintain net negative GHG emissions thereafter. Additionally, AB 1279 mandates that by 2045, statewide anthropogenic GHG emissions are to be reduced at least 85 percent below 1990 levels. AB 1279 also requires CARB to ensure that the Scoping Plan identifies and recommends measures to achieve carbon neutrality, and to identify and implement policies and strategies for CO 2 removal solutions and
carbon capture, utilization, and storage technologies. It also requires CARB to submit an annual report on progress in achieving the Scoping Plan’s goals.

The 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan), adopted by CARB in December 2022, expands on prior scoping plans. The 2022 Scoping Plan Update is the most comprehensive and far-reaching Scoping Plan developed to date. This plan responds to more recent legislation, outlining a technologically feasible, cost-effective, and equity-focused path to achieve the state’s climate target of reducing anthropogenic emissions to 85 percent below 1990 levels by 2045, while also assessing the progress California is making toward the 40 percent below 1990 levels by 2030, and achieving carbon neutrality 70 by 2045 or earlier.71 The 2030
target is an interim but important stepping stone along the critical path to the broader goal of deep decarbonization by 2045. The 2022 Scoping Plan outlines the strategies the state will implement to achieve carbon neutrality by reducing GHG emissions to meet the anthropogenic

67 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November. 68 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November. 69 California Legislative Information, 2022. AB-1279 The California Climate Crisis Act (2012-2022), September 16. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB1279. Accessed January 24. 70 Carbon neutrality means “net zero” emissions of GHGs. In other words, it means that GHG emissions generated by sources such as transportation, power plants, and industrial processes must be less than or equal to the amount of CO2 that is stored, both in natural sinks and through mechanical sequestration. AB 1279 uses the terminology “net zero” and the 2022 Scoping Plan uses the terminology “carbon neutrality” or “carbon neutral.” For purposes of this PEIR, these terms mean the same thing and are used interchangeably. 71 CARB, 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality, December.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
target, and by expanding actions to capture and store carbon through the state’s natural and working lands and using a variety of mechanical approaches. A summary of the GHG emissions reductions and targets set forth under the 2022 Scoping Plan Update is provided in Table 4.7-5, Estimated Statewide Greenhouse Gas Emissions Reductions in the 2022 Scoping Plan.

TABLE 4.7-5
ESTIMATED STATEWIDE GREENHOUSE GAS EMISSIONS REDUCTIONS IN THE 2022 SCOPING PLAN Emissions Scenario GHG Emissions (MMTCO2e)
2019
2019 State GHG Emissions 404
2030
2030 BAU Forecast 312
2030 GHG Emissions without Carbon Removal and Capture 233 2030 GHG Emissions with Carbon Removal and Capture 226
2030 Emissions Target Set by AB 32 (i.e., 1990 level by 2030) 260 Reduction below Business-As-Usual necessary to achieve 1990 levels by 2030 52 (16.7%) a 2045
2045 BAU Forecast 266
2045 GHG Emissions without Carbon Removal and Capture 72 2045 GHG Emissions with Carbon Removal and Capture (3)
MMTCO2e = million metric tons of carbon dioxide equivalents; parenthetical numbers represent negative values. a 312 – 260 = 52 /312 = 16.7%
SOURCE: CARB, 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality, December.

The 2022 Scoping Plan Update reflects existing and recent direction in the Governor’s Executive Orders and State Statutes, which identify policies, strategies, and regulations in support of and implementation of the Scoping Plan. Among these include Executive Order B-55-18 and AB 1279 (The California Climate Crisis Act), which identify the 2045 carbon neutrality and GHG reduction targets required for the Scoping Plan. Table 4.7-6, Major Climate Legislation and Executive Orders Enacted Since the 2017 Scoping Plan, provides a summary of major climate legislation and executive orders issued since the adoption of the 2017 Scoping Plan.

TABLE 4.7-6
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
Assembly Bill 1279 (AB 1279)
(Muratsuchi, Chapter 337,
Statutes of 2022)
The California Climate Crisis Act
AB 1279 establishes the policy of the state to achieve carbon neutrality as soon as possible, but no later than 2045; to maintain net negative GHG emissions thereafter; and to ensure that by 2045 statewide anthropogenic GHG emissions are reduced at least 85 percent below 1990 levels. The bill requires CARB to ensure that Scoping Plan updates identify and recommend measures to achieve carbon neutrality, and to identify and implement policies and strategies that enable CO 2 removal solutions and carbon capture, utilization, and storage (CCUS) technologies. This bill is reflected directly in 2022 Scoping Plan Update.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Bill/Executive Order Summary
Senate Bill 905 (SB 905)
(Caballero, Chapter 359,
Statutes of 2022)
Carbon Capture, Removal,
Utilization, and Storage Program
SB 905 requires CARB to create the Carbon Capture, Removal, Utilization, and Storage Program to evaluate, demonstrate, and regulate CCUS and carbon dioxide removal (CDR) projects and technology.

The bill requires CARB, on or before January 1, 2025, to adopt regulations creating a unified state permitting application for approval of CCUS and CDR projects. The bill also requires the Secretary of the Natural Resources Agency to publish a framework for governing agreements for two or more tracts of land overlying the same geologic storage reservoir for the purposes of a carbon sequestration project.

The 2022 Scoping Plan Update modeling reflects both CCUS and CDR contributions to achieve carbon neutrality.

Senate Bill 846 (SB 846) (Dodd,
Chapter 239, Statutes of 2022)
Diablo Canyon Powerplant:

Extension of Operations
SB 846 extends the Diablo Canyon Power Plant’s sunset date by up to five additional years for each of its two units and seeks to make the nuclear power plant eligible for federal loans. The bill requires that the CPUC not include and disallow a load-serving entity from including in their adopted resource plan, the energy, capacity, or any attribute from the Diablo Canyon power plant.

The 2022 Scoping Plan Update explains the emissions impact of this legislation.

Senate Bill (SB 1020) (Laird,
Chapter 361, Statutes of 2022)
Clean Energy, Jobs, and
Affordability Act of 2022
SB 1020 adds interim renewable energy and zero carbon energy retail sales of electricity targets to California end-use customers set at 90 percent in 2035 and 95 percent in 2040. It accelerates the timeline required to have 100 percent renewable energy and zero carbon energy procured to serve state agencies from the original target year of 2045 to 2035. This bill requires each state agency to individually achieve the 100 percent goal by 2035 with specified requirements. This bill requires the CPUC, CEC, and CARB, on or before December 1, 2023, and annually thereafter, to issue a joint reliability progress report that reviews system and local reliability.

The bill also modifies the requirement for CARB to hold a portion of its Scoping Plan workshops in regions of the state with the most significant exposure to air pollutants by further specifying that this includes communities with minority populations or low-income communities in areas designated as being in extreme federal non-attainment.

The 2022 Scoping Plan Update describes the implications of this legislation on emissions.

Senate Bill 1137 (SB 1137)
(Gonzales, Chapter 365,
Statutes of 2022)
Oil & Gas Operations: Location
Restrictions: Notice of Intention:

Health protection zone: Sensitive
receptors
SB 1137 prohibits the development of new oil and gas wells or infrastructure in health protection zones, as defined, except for purposes of public health and safety or other limited exceptions. The bill requires operators of existing oil and gas wells or infrastructure within health protection zones to undertake specified monitoring, public notice, and nuisance requirements. The bill requires CARB to consult and concur with the California Geologic Energy Management Division (CalGEM) on leak detection and repair plans for these facilities, adopt regulations as necessary to implement emission detection system standards, and collaborate with CalGEM on public access to emissions detection data.

Senate Bill 1075 (SB 1075)
(Skinner, Chapter 363, Statutes
of 2022)
Hydrogen: Green Hydrogen:

Emissions of Greenhouse Gases
SB 1075 requires CARB, by June 1, 2024, to prepare an evaluation that includes:
policy recommendations regarding the use of hydrogen, and specifically the use of green hydrogen, in California; a description of strategies supporting hydrogen infrastructure, including identifying policies that promote the reduction of GHGs and short-lived climate pollutants; a description of other forms of hydrogen to achieve emission reductions; an analysis of curtailed electricity; an estimate of GHG and emission reductions that could be achieved through deployment of green hydrogen through a variety of scenarios; an analysis of the potential for opportunities to integrate hydrogen production and applications with drinking water supply treatment needs; policy recommendations for regulatory and permitting processes associated with transmitting and distributing hydrogen from production sites to end uses; an analysis of the life-cycle GHG emissions from various forms of hydrogen

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Bill/Executive Order Summary
production; and an analysis of air pollution and other environmental impacts from hydrogen distribution and end uses.

This bill would inform the production of hydrogen at the scale called for in the 2022 Scoping Plan Update.

Assembly Bill 1757 (AB 1757)
(Garcia, Chapter 341, Statutes
of 2022)
California Global Warming
Solutions Act of 2006: Climate
Goal: Natural and Working Lands
AB 1757 requires the California Natural Resources Agency (CNRA), in collaboration with CARB, other state agencies, and an expert advisory committee, to determine a range of targets for natural carbon sequestration, and for nature- based climate solutions, that reduce GHG emissions in 2030, 2038, and 2045 by January 1, 2024. These targets must support state goals to achieve carbon neutrality and foster climate adaptation and resilience.

This bill also requires CARB to develop standard methods for state agencies to consistently track GHG emissions and reductions, carbon sequestration, and additional benefits from natural and working lands over time. These methods will account for GHG emissions reductions of CO
2, methane, and nitrous oxide related
to natural and working lands and the potential impacts of climate change on the ability to reduce GHG emissions and sequester carbon from natural and working lands, where feasible.

This 2022 Scoping Plan Update describes the next steps and implications of this legislation for the natural and working lands sector.

Senate Bill 1206 (SB 1206)
(Skinner, Chapter 884, Statutes
of 2022)
Hydrofluorocarbon gases: sale or
distribution
SB 1206 mandates a stepped sales prohibition on newly produced high- global warming potential (GWP) hydrofluorocarbons (HFCs) to transition California’s economy toward recycled and reclaimed HFCs for servicing existing HFC-based equipment. Additionally, SB 1206 also requires CARB to develop regulations to increase the adoption of very low-, i.e., GWP < 10, and no-GWP technologies in sectors that currently rely on higher-GWP HFCs.

Senate Bill 27 (SB 27) (Skinner,
Chapter 237, Statutes of 2021)
Carbon Sequestration: State
Goals: Natural and Working
Lands: Registry of Projects
SB 27 requires CNRA, in coordination with other state agencies, to establish the Natural and Working Lands Climate Smart Strategy by July 1, 2023. This bill also requires CARB to establish specified CO
2 removal targets for 2030 and beyond as
part of its Scoping Plan. Under SB 27, CNRA is to establish and maintain a registry to identify projects in the state that drive climate action on natural and working lands and are seeking funding.

CNRA also must track carbon removal and GHG emission reduction benefits derived from projects funded through the registry.

This bill is reflected directly in 2022 Scoping Plan Update as CO2 removal targets for 2030 and 2045 in support of carbon neutrality.

Senate Bill 596 (SB 596)
(Becker, Chapter 246, Statutes
of 2021)
Greenhouse Gases: Cement
Sector: Net-Zero Emissions
Strategy
SB 596 requires CARB, by July 1, 2023, to develop a comprehensive strategy for the state’s cement sector to achieve net-zero emissions of GHGs associated with cement used within the state as soon as possible, but no later than December 31, 2045. The bill establishes an interim target of 40 percent below the 2019 average GHG intensity of cement by December 31, 2035. Under SB 596, CARB must:

Define a metric for GHG intensity and establish a baseline from which to measure GHG intensity reductions.
• Evaluate the feasibility of the 2035 interim target (40 percent reduction in GHG intensity) by July 1, 2028.
• Coordinate and consult with other state agencies.
• Prioritize actions that leverage state and federal incentives. • Evaluate measures to support market demand and financial incentives to encourage the production and use of cement with low GHG intensity.

The 2022 Scoping Plan Update modeling is designed to achieve these outcomes.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Bill/Executive Order Summary
Executive Order N-82-20 Governor Newsom signed Executive Order N-82-20 in October 2020 to combat the climate and biodiversity crises by setting a statewide goal to conserve at least 30 percent of California’s land and coastal waters by 2030. The Executive Order also instructed the CNRA, in consultation with other state agencies, to develop a Natural and Working Lands Climate Smart Strategy that serves as a framework to advance the state’s carbon neutrality goal and build climate resilience. In addition to setting a statewide conservation goal, the Executive Order directed CARB to update the target for natural and working lands in support of carbon neutrality as part of this Scoping Plan, and to take into consideration the NWL Climate Smart Strategy.

CO
2 Executive Order N-82-20 also calls on the CNRA, in consultation with other state agencies, to establish the California Biodiversity Collaborative (Collaborative).

The Collaborative shall be made up of governmental partners, California Native American tribes, experts, business and community leaders, and other stakeholders from across the state. State agencies will consult the Collaborative on efforts to:
• Establish a baseline assessment of California’s biodiversity that builds upon existing data and can be updated over time.
• Analyze and project the impact of climate change and other stressors in California’s biodiversity.
• Inventory current biodiversity efforts across all sectors and highlight opportunities for additional action to preserve and enhance biodiversity.

CNRA also is tasked with advancing efforts to conserve biodiversity through various actions, such as streamlining the state’s process to approve and facilitate projects related to environmental restoration and land management. The California Department of Food and Agriculture (CDFA) is directed to advance efforts to conserve biodiversity through measures such as reinvigorating populations of pollinator insects, which restore biodiversity and improve agricultural production.

The Natural and Working Lands Climate Smart Strategy informs 2022 Scoping Plan Update.

Executive Order N-79-20 Governor Newsom signed Executive Order N-79-20 in September 2020 to establish targets for the transportation sector to support the state in its goal to achieve carbon neutrality by 2045. The targets established in this Executive Order are:
• 100 percent of in-state sales of new passenger cars and trucks will be zero- emission by 2035.
• 100 percent of medium- and heavy-duty vehicles will be zero-emission by 2045 for all operations where feasible, and by 2035 for drayage trucks. • 100 percent of off-road vehicles and equipment will be zero-emission by 2035 where feasible.

The Executive Order also tasked CARB to develop and propose regulations that require increasing volumes of zero- electric passenger vehicles, medium- and heavy-duty vehicles, drayage trucks, and off-road vehicles toward their corresponding targets of 100 percent zero-emission by 2035 or 2045, as listed above.

The 2022 Scoping Plan Update modeling reflects achieving these targets.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Bill/Executive Order Summary
Executive Order N-19-19 Governor Newsom signed Executive Order N-19-19 in September 2019 to direct state government to redouble its efforts to reduce GHG emissions and mitigate the impacts of climate change while building a sustainable, inclusive economy. This Executive Order instructs the Department of Finance to create a Climate Investment Framework that:
• Includes a proactive strategy for the state’s pension funds that reflects the increased risks to the economy and physical environment due to climate change.
• Provides a timeline and criteria to shift investments to companies and industry sectors with greater growth potential based on their focus of reducing carbon emissions and adapting to the impacts of climate change. • Aligns with the fiduciary responsibilities of the California Public Employees’ Retirement System, California State Teachers’ Retirement System, and the University of California Retirement Program.

Executive Order N-19-19 directs the State Transportation Agency to leverage more than $5 billion in annual state transportation spending to help reverse the trend of increased fuel consumption and reduce GHG emissions associated with the transportation sector. It also calls on the Department of General Services to leverage its management and ownership of the state’s 19 million square feet in managed buildings, 51,000 vehicles, and other physical assets and goods to minimize state government’s carbon footprint. Finally, it tasks CARB with accelerating progress toward California’s goal of five million ZEV sales by 2030 by:
• Developing new criteria for clean vehicle incentive programs to encourage manufacturers to produce clean, affordable cars.
• Proposing new strategies to increase demand in the primary and secondary markets for ZEVs.
• Considering strengthening existing regulations or adopting new ones to achieve the necessary GHG reductions from within the transportation sector.

The 2022 Scoping Plan Update modeling reflects efforts to accelerate ZEV deployment.

Senate Bill 576 (SB 576)
(Umberg, Chapter 374, Statutes
of 2019)
Coastal Resources: Climate
Ready Program and Coastal
Climate Change Adaptation,
Infrastructure and Readiness
Program
Sea level rise, combined with storm-driven waves, poses a direct risk to the state’s coastal resources, including public and private real property and infrastructure.

Rising marine waters threaten sensitive coastal areas, habitats, the survival of threatened and endangered species, beaches, other recreation areas, and urban waterfronts. SB 576 mandates that the Ocean Protection Council develop and implement a coastal climate adaptation, infrastructure, and readiness program to improve the climate change resiliency of California’s coastal communities, infrastructure, and habitat. This bill also instructs the State Coastal Conservancy to administer the Climate Ready Program, which addresses the impacts and potential impacts of climate change on resources within the conservancy’s jurisdiction.

Assembly Bill 65 (AB 65)
(Petrie- Norris, Chapter 347,
Statutes of 2019)
Coastal Protection: Climate
Adaption: Project Prioritization:

Natural Infrastructure: Local
General Plans
This bill requires the State Coastal Conservancy, when it allocates any funding appropriated pursuant to the California Drought, Water, Parks, Climate, Coastal Protection, and Outdoor Access For All Act of 2018, to prioritize projects that use natural infrastructure in coastal communities to help adapt to climate change. The bill requires the conservancy to provide information to the Office of Planning and Research on any projects funded pursuant to the above provision to be considered for inclusion into the clearinghouse for climate adaption information. The bill authorizes the conservancy to provide technical assistance to coastal communities to better assist them with their projects that use natural infrastructure.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Bill/Executive Order Summary
Executive Order B-55-18 Governor Brown signed Executive Order B-55-18 in September 2018 to establish a statewide goal to achieve carbon neutrality as soon as possible, and no later than 2045, and to achieve and maintain net negative emissions thereafter. Policies and programs undertaken to achieve this goal shall:
• Seek to improve air quality and support the health and economic resiliency of urban and rural communities, particularly low-income and disadvantaged communities.
• Be implemented in a manner that supports climate adaptation and biodiversity, including protection of the state’s water supply, water quality, and native plants and animals.

This Executive Order also calls for CARB to:
• Develop a framework for implementation and accounting that tracks progress toward this goal.
• Ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.

The 2022 Scoping Plan Update is designed to achieve carbon neutrality no later than 2045 and the modeling includes technology and fuel transitions to achieve that outcome.

Senate Bill 100 (SB 100)
(De León, Chapter 312, Statutes
of 2018)
California Renewables Portfolio
Standard Program: emissions of
greenhouse gases
Under SB 100, the CPUC, CEC, and CARB shall use programs under existing laws to achieve 100 percent clean electricity. The statute requires these agencies to issue a joint policy report on SB 100 every four years. The first of these reports was issued in 2021.

The 2022 Scoping Plan Update reflects the SB 100 Core Scenario resource mix with a few minor updates.

Assembly Bill 2127 (AB 2127)
(Ting, Chapter 365, Statutes of
2018)
Electric Vehicle Charging
Infrastructure: Assessment
This bill requires the CEC, working with CARB and the CPUC, to prepare and biennially update a statewide assessment of the electric vehicle charging infrastructure needed to support the levels of electric vehicle adoption required for the state to meet its goals of putting at least 5 million zero-emission vehicles on California roads by 2030 and of reducing emissions of GHGs to 40 percent below 1990 levels by 2030. The bill requires the CEC to regularly seek data and input from stakeholders relating to electric vehicle charging infrastructure.

This bill supports the deployment of ZEVs as modeled in 2022 Scoping Plan Update.

Senate Bill 30 (SB 30) (Lara,
Chapter 614, Statutes of 2018)
Insurance: Climate Change
This bill requires the Insurance Commissioner to convene a working group to identify, assess, and recommend risk transfer market mechanisms that, among other things, promote investment in natural infrastructure to reduce the risks of climate change related to catastrophic events, create incentives for investment in natural infrastructure to reduce risks to communities, and provide mitigation incentives for private investment in natural lands to lessen exposure and reduce climate risks to public safety, property, utilities, and infrastructure. The bill requires the policies recommended to address specified questions.

Assembly Bill 2061 (AB 2061)
(Frazier, Chapter 580, Statutes
of 2018)
Near-Zero-Emission and Zero-
Emission Vehicles
Existing state and federal law sets specified limits on the total gross weight imposed on the highway by a vehicle with any group of two or more consecutive axles. Under existing federal law, the maximum gross vehicle weight of that vehicle may not exceed 82,000 pounds. AB 2061 authorizes a near-zero- emission vehicle or a zero-emission vehicle to exceed the weight limits on the power unit by up to 2,000 pounds. This bill supports the deployment of cleaner trucks as modeled in this 2022 Scoping Plan Update.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-25 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The 2022 Scoping Plan Update identifies the need to accelerate AB32’s 2030 target, from 40 percent to 48 percent below 1990 levels. Cap-and-Trade regulation continues to play a large factor in the reduction of near-term emissions for meeting the 2030 reduction target. Every sector of the economy will need to begin to transition in this decade to meet these GHG reduction goals and achieve carbon neutrality no later than 2045. The 2022 Scoping Plan Update approaches decarbonization from two perspectives, managing a phasedown of existing energy sources and technologies, as well as increasing, developing, and deploying alternative clean energy sources and technology. The Scoping Plan Scenario is summarized in Table 2-1 starting on page 72 of the Scoping Plan. It includes references to relevant statutes and Executive Orders, although it is not comprehensive of all existing new authorities for directing or supporting the actions described. Table 2-1 identifies actions related to a variety of sectors such as: smart growth and reductions in Vehicle Miles Traveled (VMT); light-duty vehicles (LDV) and zero- emission vehicles (ZEV); truck ZEVs; reduce fossil energy, emissions, and GHGs for aviation ocean- going vessels, port operations, freight and passenger rail, oil and gas extraction; and petroleum refining; improvements in electricity generation; electrical appliances in new and existing residential and commercial buildings; electrification and emission reductions across industries such as the for food products, construction equipment, chemicals and allied products, pulp and paper, stone/clay/glass/cement, other industrial manufacturing, and agriculture; retiring of combined heat and power facilities; low carbon fuels for transportation, business, and industry; improvements in non-combustion methane emissions, and introduction of low GWP refrigerants.

Achieving the targets described in the 2022 Scoping Plan Update will require continued commitment to and successful implementation of existing policies and programs, and identification of new policy tools and technical solutions to go further, faster. California’s Legislature and state agencies will continue to collaborate to achieve the state’s climate, clean air, equity, and broader economic and environmental protection goals. It will be necessary to maintain and strengthen this collaborative effort, and to draw upon the assistance of the federal government, regional and local governments, tribes, communities, academic institutions, and the private sector to achieve the state’s near-term and longer-term emission reduction goals and a more equitable future for all Californians. The Scoping Plan acknowledges that the path forward is not dependent on one agency, one state, or even one country. However, the State can lead by engaging Californians and demonstrating how actions at the state, regional, and local levels of governments, as well as action at community and individual levels, can contribute to addressing the challenge.

Appendix D, Local Actions, of the 2022 Scoping Plan Update includes “recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under the California Environmental Quality Act (CEQA).” Appendix D is intended to provide clarification on challenges local jurisdictions face when implementing GHG reduction strategies or approving much-needed housing projects.
72 72 CARB, 2022b. 2022 Scoping Plan for Achieving Carbon Neutrality – Appendix D: Local Actions, November.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-26 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Aligning local jurisdiction action with state-level priorities to tackle climate change and the outcomes called for in the 2022 Scoping Plan Update is critical to achieving the statutory targets for 2030 and 2045. The 2022 Scoping Plan Update discusses the role of local governments in meeting the State’s GHG reductions goals. Local governments have the primary authority to plan, zone, approve, and permit how and where land is developed to accommodate population growth, economic growth, and the changing needs of their jurisdictions. They also make critical decisions on how and when to deploy transportation infrastructure, and can choose to support transit, walking, bicycling, and neighborhoods that do not force people into cars. Local governments also have the option to adopt building ordinances that exceed statewide building code requirements and play a critical role in facilitating the rollout of ZEV infrastructure. As a result, local government decisions play a critical role in supporting state-level measures to contain the growth of GHG emissions associated with the transportation system and the built environment— the two largest GHG emissions sectors over which local governments have authority. The City has taken the initiative in combating climate change by addressing it in the Culver City General Plan and Zoning Code Update and 2019 Community Greenhouse Gas Inventory Report and developing programs and regulations such as the Culver City Green Building Ordinance, Culver City Bicycle & Pedestrian Action Plan, Culver City's Electric Vehicle (EV) Infrastructure Plan, and Culver City Clean Power Alliance. Each of these is discussed further below.

Cap-and-Trade Program
The Climate Change Scoping Plan identifies a Cap-and-Trade Program as one of the strategies California would employ to reduce GHG emissions. CARB asserts that this program will help put California on the path to meet its goal of ultimately achieving an 80 percent reduction from 1990 levels by 2050. Pursuant to its authority under AB 32, CARB has designed and adopted the California Cap-and-Trade Program to reduce GHG emissions from major sources (deemed “covered entities”) by setting a firm cap on statewide GHG emissions and employing market mechanisms to achieve AB 32’s emissions reduction mandate of returning to 1990 levels of emissions by 2020 (17 CCR Sections 95800–96023).

The Cap-and-Trade Program establishes an overall limit for GHG emissions from capped sectors (e.g., electricity generation, petroleum refining, cement production, and large industrial facilities that emit more than 25,000 MTCO
2e per year) and declines over time, and facilities subject to the cap may trade permits to emit GHGs. The statewide cap for GHG emissions from the capped sectors commenced in 2013 and declines over time, achieving GHG emissions reductions throughout the program’s duration (17 CCR Sections 95811 and 9512). On July 17, 2017, the California Legislature enacted AB 398, extending the Cap-and-Trade Program through 2030.

The Cap-and-Trade Regulation provides a firm cap, ensuring that the statewide emission limits will not be exceeded. An inherent feature of the Cap-and-Trade Program is that it does not guarantee GHG emissions reductions in any discrete location or by any particular source. Rather, GHG emissions reductions are only guaranteed on an accumulative basis. In other words, because climate change is a global occurrence and the impacts of GHG emissions are considered cumulative, a focus on aggregate GHG emissions reductions, rather than source-specific reductions, is warranted.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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California Environmental Quality Act Guidelines
In August 2007, the California State Legislature adopted SB 97 (Chapter 185, Statutes of 2007), requiring the Governor’s Office of Planning and Research (OPR) to prepare and transmit new CEQA Guidelines for the mitigation of GHG emissions or the effects of GHG emissions to the Resources Agency by July 1, 2009. In response to SB 97, OPR adopted the CEQA Guidelines that became effective on March 18, 2010.

However, neither a threshold of significance nor any specific mitigation measures are included or provided in the CEQA Guidelines.
73 The CEQA Guidelines require a lead agency to make a
good-faith effort, based on the extent possible on scientific and factual data, to describe, calculate, or estimate the amount of GHG emissions resulting from a project. Discretion is given to the lead agency whether to (1) use a model or methodology to quantify GHG emissions resulting from a project, and which model or methodology to use, or (2) rely on a qualitative analysis or performance-based standards. Furthermore, three factors are identified that should be considered in the evaluation of the significance of GHG emissions:

1. The extent to which a project may increase or reduce GHG emissions as compared to the existing environmental setting;

2. Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and

3. The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
74 On December 28, 2018, OPR adopted amendments to the CEQA Guidelines to clarify several points such as cumulative nature of GHG emissions, modeling methodology, and significance evaluation. The administrative record for the CEQA Guidelines amendments also clarifies “that the effects of GHG emissions are cumulative and should be analyzed in the context of California Environmental Quality Act’s requirements for cumulative impact analysis.” 75 California Air Resources Board
CARB, a part of CalEPA, is responsible for the coordination and administration of both federal and State air pollution control programs within California. In this capacity, CARB conducts research, sets state ambient air quality standards, compiles emission inventories, develops suggested control measures, and provides oversight of local programs. CARB establishes emissions standards for motor vehicles sold in California, consumer products (such as hairspray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. CARB also sets fuel specifications to further reduce vehicular emissions. CARB has primary responsibility for the development of California’s State Implementation Plan (SIP), for which it

73 See 14 California Code of Regulations Sections 15064.7 (generally giving discretion to lead agencies to develop and publish thresholds of significance for use in the determination of the significance of environmental effects), 15064.4 (giving discretion to lead agencies to determine the significance of impacts from GHGs). 74 14 California Code of Regulations Section 15064.4(b). 75 Letter from Cynthia Bryant, Director of the Governor’s Office of Planning and Research (OPR) to Mike Chrisman, California Secretary for Natural Resources, dated April 13, 2009.

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4.7. Greenhouse Gas Emissions
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works closely with the federal government and the local air districts. The SIP is required for the State to take over implementation of the CAA. CARB also has primary responsibility for adopting regulations to meet the state’s goal of reducing GHG emissions to 1990 levels by 2020.

Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling
In 2004, CARB adopted an Airborne Toxic Control Measure to limit heavy-duty diesel motor vehicle idling in order to reduce public exposure to diesel particulate matter and other toxic air contaminants (13 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 generally does not allow diesel- fueled commercial vehicles to idle for more than 5 minutes at any given location with certain exemptions for equipment in which idling is a necessary function such as concrete trucks. While this measure primarily targets diesel particulate matter emissions, it has co-benefits of minimizing GHG emissions from unnecessary truck idling.

Low Carbon Fuel Standard
In 2007, Executive Order S-01-07 mandated the following: establish a statewide goal to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020; and adopt a LCFS for transportation fuels in California. CARB identified the LCFS as one of the nine discrete early actions in the Climate Change Scoping Plan. In 2009, the LCFS regulations were approved by CARB and established a reduction in the carbon intensity of transportation fuels by 10 percent by 2020 beginning in 2011. In 2015, CARB approved the re-adoption of the LCFS, which became effective beginning January 2016, to address procedural deficiencies in the way the original regulation was adopted.

In -Use Off-Road Diesel-Fueled Fleets Regulation
In 2007, CARB promulgated emission standards for off-road diesel construction equipment of greater than 25 horsepower such as bulldozers, loaders, backhoes, and forklifts, as well as many other self-propelled off-road diesel vehicles. The regulation aims to reduce emissions by installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emission-controlled models.

CARB approved amendments to the In-Use Off-Road Diesel-Fueled Fleets Regulation in November of 2022.
76 The amendment will require fleets to phase-out use of the oldest and highest polluting off-road diesel vehicles, prohibit the addition of high-emitting vehicles to a fleet, and require the use of R99 or R100 renewable diesel in off-road diesel vehicles. The amendments phase-in starting in 2024 through the end of 2046 and include changes to enhance enforceability and encourage the adoption of zero-emission technologies. These amendments aim to further reduce emissions from the off-road sector.

76 CARB, 2022c. CARB approves amendments to Off-Road Regulation to further reduce emissions, November 17. https://ww2.arb.ca.gov/news/carb-approves-amendments-road-regulation-further-reduce-emissions. Accessed January 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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Truck and Bus Regulation
In 2008, CARB approved the Truck and Bus regulation to reduce particulate matter and nitrogen oxide emissions from existing diesel vehicles operating in California (13 CCR, Section 2025, subsection (h)). CARB has also promulgated emission standards for off-road diesel construction equipment of greater than 25 horsepower, such as, bulldozers, loaders, backhoes and forklifts, as well as many other self-propelled off-road diesel vehicles. The regulation aims to reduce emissions by installation of diesel soot filters, and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emission-controlled models. While these regulations primarily target reductions in criteria air pollutant emission, they have co-benefits of minimizing GHG emissions due to improved engine efficiencies.

Advanced Clean Cars Program
In 2012, CARB adopted the Advanced Clean Cars (ACC) emissions-control program, which is closely associated with the emissions standards for passenger vehicles and light-duty trucks discussed above.
77 The program requires an increase in the number of zero-emissions vehicle models for years 2015 through 2025 to control smog, soot and GHG emissions. By 2025, ZEVs must be 22 percent of large volume manufacturers overall production. 78 This program includes
the Low-Emissions Vehicle (LEV) regulations to reduce criteria pollutants and GHG emissions from light- and medium-duty vehicles; and ZEV regulations to require manufacturers to produce an increasing number of pure ZEVs (meaning battery and fuel cell electric vehicles) with the provision to produce plug-in hybrid electric vehicles (PHEV) between 2018 and 2025.

Governor Gavin Newsom signed an executive order (Executive Order No. N-79-20) on September 23, 2020, which would phase out sales of new gas-powered passenger cars by 2035 in California with an additional 10-year transition period for heavy vehicles. The State would not restrict used car sales, nor forbid residents from owning gas-powered vehicles. In accordance with the Executive Order, CARB is developing a 2020 Mobile Source Strategy, a comprehensive analysis that presents scenarios for possible strategies to reduce the carbon, toxic and unhealthy pollution from cars, trucks, equipment, and ships. The strategies will provide important information for numerous regulations and incentive programs going forward by conveying what is necessary to address the aggressive emission reduction requirements.

The primary mechanism for achieving the ZEV target for passenger cars and light trucks is CARB’s Advanced Clean Cars II (ACC II) Program

79. The ACC II regulations will rapidly scale down
light-duty passenger car, pickup truck and SUV emissions starting with the 2026 model year through 2035. The ACC II regulation amends the Zero-emission Vehicle Regulation to require an increasing number of zero-emission vehicles, and relies on currently available advanced vehicle technologies, including battery-electric, hydrogen fuel cell electric and plug-in hybrid electric- vehicles, to meet air quality and climate change emissions standards which supports Governor

77 CARB, 2023b. California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission-standards-under-assembly-bill-1493-2002- pavley. Accessed March 2023.
78 CARB, 2023c. Current Zero-Emissions Vehicle Regulation. https://ww2.arb.ca.gov/our-work/programs/advanced- clean-cars-program/zev-program/current-zero-emission-vehicle-regulation. Accessed March 2023. 79 CARB, 2024a. Advanced Clean Cars II. https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars- program/advanced-clean-cars-ii. Accessed January 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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Preliminary − Subject to Revision
Newsom’s 2020 Executive Order N-79-20 that requires all new passenger vehicles sold in California to be zero emissions by 2035. Additionally, the ACC II regulation amends the Low- emission Vehicle Regulations to include increasingly stringent standards for gasoline cars and heavier passenger trucks to continue to reduce smog-forming emissions.

Advanced Clean Trucks Program
The Advanced Clean Trucks regulations were approved on June 25, 2020, and require that manufacturers sell zero-emissions or near-zero-emissions trucks as an increasing percentage of their annual California sales beginning in 2024. The goal of this proposed strategy is to achieve nitrogen oxide (NOx) and GHG emission reductions through advanced clean technology, and to increase the penetration of the first wave of zero-emissions heavy-duty technology into applications that are well suited to its use. According to CARB, “Promoting the development and use of advanced clean trucks will help CARB achieve its emission reduction strategies as outlined in the SIP, Sustainable Freight Action Plan, SB 350, and AB 32.” 80 The percentage of zero-
emissions truck sales is required to increase every year until 2035 when sales would need to be 55 percent of Classes 2b–3 (light/medium- and medium-duty trucks) truck sales, 75 percent of Classes 4–8 (medium- to heavy-duty trucks) straight truck sales, and 40 percent of truck tractor (heavy-duty trucks weighing 33,001 pounds or greater) sales. Additionally, large fleet operators (of 50 or more trucks) would be required to report information about shipments and services and their existing fleet operations.

Land Use and Transportation Planning
In 2008, SB 375 (Chapter 728, Statutes of 2008) established mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions. Under SB 375, CARB is required, in consultation with the State’s metropolitan planning organizations (MPOs), to set regional GHG reduction targets for the passenger vehicle and light-duty truck sector for 2020 and 2035. 81 The proposed reduction targets explicitly exclude emission reductions expected from the AB 1493 and the LCFS regulations.

Under SB 375, the regional GHG reduction target must be incorporated within the applicable MPO’s Regional Transportation Plan (RTP), which is used for long-term transportation planning, in a Sustainable Communities Strategy (SCS).

In 2011, CARB adopted GHG emissions reduction targets for the Southern California Association of Governments (SCAG), the MPO for the region in which the city of Culver City is located. In 2018, CARB updated the SB 375 targets to require an 8 percent reduction by 2020 and a 19 percent reduction by 2035 in per capita passenger vehicle GHG emissions. 82,83

80 CARB, 2023a. Advanced Clean Trucks Program. https://ww2.arb.ca.gov/our-work/programs/advanced-clean- trucks/about. Accessed March 2023.
81 CARB, 2023d. Sustainable Communities and Climate Protection Program. https://ww2.arb.ca.gov/our- work/programs/sustainable-communities-climate-protection-program/about. Accessed March 2023. 82 CARB, 2017. California’s 2017 Climate Change Scoping Plan, November. 83 CARB, 2018. SB 375 Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets. https://ww2.arb.ca.gov/sites/default/files/2020-06/SB375_Updated_Final_Target_Staff_Report_2018.pdf.

Accessed March 2023.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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Preliminary − Subject to Revision
Energy Sector
The California Building Energy Efficiency Standards for Residential and Nonresidential Buildings (CCR, Title 24, Part 6) were adopted to ensure that building construction and system design and installation achieve energy efficiency and preserve outdoor and indoor environmental quality.

The CEC first adopted Energy Efficiency Standards for Residential and Nonresidential Buildings (CCR, Title 24, Part 6) in 1978 in response to a legislative mandate to reduce energy consumption in the state. Although not originally intended to reduce GHG emissions, increased energy efficiency and reduced consumption of electricity, natural gas, and other fuels would result in fewer GHG emissions from residential and nonresidential buildings subject to the standard. The standards are updated periodically (typically every three years) to allow for the consideration and inclusion of new energy efficiency technologies and methods.

The current California Building Energy Efficiency Standards (Title 24 standards) are the 2022 Title 24 standards, which became effective January 1, 2023. The 2022 Title 24 standards encourage efficient electric heat pumps, establish electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more.

Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 standards.
84 The California Green Building Standards Code (CCR, Title 24, Part 11), commonly referred to as the CALGreen Code, with the most current version being the 2022 version which became effective January 1, 2023. The purpose of the CALGreen Building Code is to “improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices in the following categories: (1) Planning and design; (2) Energy efficiency; (3) Water efficiency and conservation; (4) Material conservation and resource efficiency; and (5) Environmental air quality.”
85 The CALGreen Building Code is not intended to
substitute for or be identified as meeting the certification requirements of any green building program that is not established and adopted by the California Building Standards Commission.

The CALGreen Building Code establishes mandatory measures for new residential and non- residential buildings. The CALGreen Code includes mandatory measures for non-residential development related to site development, energy efficiency, water efficiency and conservation; material conservation and resource efficiency; and environmental quality. The 2022 CALGreen Code: revises standards for electric vehicle charging for new construction, primarily multi-family dwellings and hotels/motels, including increased requirements for EV parking spaces and EVSE Level 2 chargers, establishes heat pumps as a baseline technology, strengthens ventilation standards, establishes electric-ready requirements for new homes, and sets minimum solar photovoltaic and battery energy storage capacity for high-rise multifamily and commercial buildings, including office buildings, grocery stores, and schools, and more.

84 California Energy Commission, 2022. Building Energy Efficiency Standards. 85 California Building Standards Commission, 2010. California Green Building Standards Code.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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Preliminary − Subject to Revision
The 2012 Appliance Efficiency Regulations (CCR, Title 20, Sections 1601 through 1608) took effect February 13, 2013. The regulations include standards for both federally regulated appliances and non-federally regulated appliances.

The State has adopted regulations to increase the proportion of electricity from renewable sources. In 2008, Executive Order S-14-08 expanded the State’s RPS goal to 33 percent renewable power by 2020. In 2009, Executive Order S-21-09 directed CARB (under its AB 32 authority) to enact regulations to help the state meet the 2020 goal of 33 percent renewable energy. The 33 percent by 2020 RPS goal was codified with the passage of Senate Bill X1-2. This new RPS applied to all electricity retailers in the state, including publicly owned utilities (POUs), investor-owned utilities, electricity service providers, and community choice aggregators. SB 350 (Chapter 547, Statues of 2015) further increased the RPS to 50 percent by 2030, including interim targets of 40 percent by 2024 and 45 percent by 2027. In 2018, SB 100 further increased California’s RPS and requires retail sellers and local publicly-owned electric utilities to procure eligible renewable electricity for 44 percent of retail sales by the end of 2024, 52 percent by the end of 2027, and 60 percent by the end of 2030; and requires that CARB should plan for 100 percent eligible renewable energy resources and zero-carbon resources by the end of 2045.

Regional
Southern California Association of Governments
In 2020, SCAG adopted the SCAG 2020–2045 RTP/SCS, also known as “Connect SoCal,” which is an update to the previous 2012–2035 RTP/SCS and 2016–2040 RTP/SCS.86 Using growth forecasts and economic trends, the 2020–2045 RTP/SCS provides a vision for transportation throughout the region for the next several decades by considering the role of transportation in the broader context of economic, environmental, and quality-of-life goals for the future, identifying regional transportation strategies to address mobility needs. The 2020–2045 RTP/SCS describes how the region can attain the GHG emission-reduction targets set by CARB by achieving an 8 percent reduction in per capita transportation GHG emissions by 2020 and a 19 percent reduction in per capita transportation GHG emissions by 2035 compared to the 2005 level on a per capita basis.
87 Compliance with and implementation of the 2020–2045 RTP/SCS policies and strategies would have co-benefits of reducing per capita criteria air pollutant emissions (e.g., nitrogen dioxide, carbon monoxide, etc.) associated with reduced per capita

86 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.
87 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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VMT. CARB has accepted the SCAG GHG quantification determination in the 2020–2045 RTP/SCS for future GHG emission reduction targets.88
The 2020–2045 RTP/SCS states that the SCAG region was home to approximately 18.8 million people in 2016 and included approximately 6.0 million homes and 8.4 million jobs. 89 By 2045, the integrated growth forecast projects that these figures will increase by 3.7 million people, with approximately 1.6 million more homes and 1.7 million more jobs. The vision for the region incorporates a range of best practices for increasing transportation choices, reducing dependence on personal automobiles, further improving air quality, and encouraging growth in walkable, mixed-use communities with ready access to transit infrastructure and employment.

More and varied housing types and employment opportunities would be located in and near job centers, transit stations and walkable neighborhoods where goods and services are easily accessible via shorter trips. To support shorter trips, people would have the choice of using neighborhood bike networks, car share or micro-mobility services like shared bicycles or scooters. For longer commutes, people would have expanded regional transit services and more employer incentives to carpool or vanpool. Other longer trips would be supported by on- demand services such as microtransit, carshare, and citywide partnerships with ride hailing services. For those that choose to drive, hotspots of congestion would be less difficult to navigate due to cordon pricing and using an electric vehicle will be easier thanks to an expanded regional charging network.

High-quality transit areas (HQTAs), which are defined by the 2020–2045 RTP/SCS as generally walkable transit villages or corridors that are within 0.5 miles of a well-serviced transit stop or a transit corridor with 15-minute or less service frequency during peak commute hours, will account for 2.4 percent of regional total land, but are projected to accommodate 51 percent and 60 percent of future household growth respectively between 2016 and 2045. 90 The 2020–
2045 RTP/SCS overall land use pattern reinforces the trend of focusing new housing and employment in the region’s HQTAs. HQTAs are a cornerstone of land use planning best practice in the SCAG region because they concentrate roadway repair investments, leverage transit and active transportation investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potential to improve public health and housing affordability. Transit Priority Areas
91 (TPAs) will account for less than one percent of regional total land but are projected to accommodate 30 percent of future household growth between 2016 and 2045. The 2020–2045 RTP/SCS overall land use pattern reinforces the trend of focusing new housing and employment in the region’s TPAs. TPAs are a cornerstone of land use

88 CARB, 2020b. Southern California Association of Governments’ (SCAG) 2020 Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination, October 2020. https://ww2.arb.ca.gov/sites/default/files/2021-
02/SCAG%202020%20SCS%20CARB%20Acceptance%20of%20GHG%20Quantification%20Determination%20Execu tive%20Order.pdf. Accessed January 2024.
89 Southern California Association of Governments, 2020b. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Demographics and Growth Forecast Technical Report. September 2020. 90 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October, p 51.
91 Defined by the 2020–2045 RTP/SCS as generally walkable transit villages or corridors that are within 0.5 mile of a major transit stop (rail or bus rapid transit station) with 15-minute or less service frequency during peak commute hours.

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4.7. Greenhouse Gas Emissions
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planning best practice in the SCAG region because they concentrate roadway repair investments, leverage transit and active transportation investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potential to improve public health and housing affordability.

SCAG’s 2020–2045 RTP/SCS provides specific strategies for implementation. These strategies include supporting projects that encourage diverse job opportunities for a variety of skills and education, recreation and cultures and a full-range of shopping, entertainment and services all within a relatively short distance; encouraging employment development around current and planned transit stations and neighborhood commercial centers; encouraging the implementation of a “Complete Streets” policy that meets the needs of all users of the streets, roads and highways including bicyclists, children, persons with disabilities, motorists, electric vehicles, movers of commercial goods, pedestrians, users of public transportation, and seniors; and supporting alternative fueled vehicles.
92 In addition, the 2020–2045 RTP/SCS includes strategies to promote active transportation; support local planning and projects that serve short trips; promote transportation investments, investments in active transportation, more walkable and bikeable communities that will result in improved air quality and public health and reduced GHG emissions; and support building physical infrastructure such as local and regional bikeways, sidewalk and safe routes to schools pedestrian improvements, regional greenways and first-last mile connections to transit, including to light rail and bus stations. The 2020–2045 RTP/SCS aligns active transportation investments with land use and transportation strategies, increases competitiveness of local agencies for federal and state funding, and expands the potential for all people to use active transportation.

Although there are GHG emission reduction targets for passenger vehicles set by CARB for 2045, the 2020–2045 RTP/SCS GHG emission reduction trajectory shows that more aggressive GHG emission reductions are needed for 2045. By meeting and exceeding the SB 375 targets for 2035, as well as achieving an additional 4.1 percent reduction in GHG from transportation- related sources in the ten years between 2035 and 2045, the 2020–2045 RTP/SCS is expected to fulfill and exceed its portion of SB 375 compliance with respect to meeting the state’s future GHG emission reduction goals.
93 Refer to Section 4.10, Land Use and Planning, of this PEIR, for further discussion of the RTP/SCS.

South Coast Air Quality Management District
As discussed in Section 4.3, Air Quality, of this PEIR, SCAQMD is responsible for air quality planning in the South Coast Air Basin (where the Planning Area is located) and developing rules and regulations to bring the Air Basin into attainment of the ambient air quality standards. As part of its efforts to reduce local air pollution, SCAQMD has promoted a number of programs to combat climate change. For instance, SCAQMD has promoted energy conservation, low-carbon

92 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.
93 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.

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4.7. Greenhouse Gas Emissions
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Preliminary − Subject to Revision
fuel technologies (natural gas vehicles; electric-hybrids, hydraulic-hybrids, and battery-electric vehicles), renewable energy, VMT reduction programs, and market incentive programs.

A GHG Significance Threshold Working Group was formed by the SCAQMD to evaluate potential GHG significance thresholds.94 In 2008, the Working Group released draft guidance regarding interim CEQA GHG significance thresholds.95,96,97 Within its October 2008 document, the Working Group proposed the use of a percent emission reduction target compared to business as usual to determine significance for commercial/residential projects that emit greater than 3,000 MTCO
2e per year. Under this proposal, commercial/residential projects that emit fewer than 3,000 MTCO2e per year would be assumed to have a less-than-significant impact on climate change. In addition, on December 5, 2008, the SCAQMD Governing Board adopted the staff proposal for an interim GHG significance threshold of 10,000 MTCO2e for stationary source/industrial projects where the SCAQMD is the Lead Agency. However, the SCAQMD has not adopted a GHG significance threshold for land use development projects. The aforementioned Working Group has been inactive since 2011 and the SCAQMD has not formally adopted any GHG significance threshold for land use development projects.

Local
As discussed above in Section 4.7.2, Environmental Setting, Culver City prepared the 2019 Community GHG Inventory Report, which shows the types, distribution, and amount of GHG emissions from using electrical and natural gas, transportation, solid waste, off-road equipment, industrial sources, water supply, and wastewater treatment within Culver city by residents, businesses, and local government operations. In 2019, Culver City emitted 291,922 MTCO 2e
from all sources.98 The report does not include any GHG reduction measures or goals.

Culver City General Plan
The Circulation Element provides an overview of regulatory policies, transportation agencies, and local conditions; presents a vision for mobility in the Culver City area; presents a Street System Classification; discusses the Culver CityBus system; presents Bikeway Classifications; and provides goals, objectives, and policies to improve the local and regional transportation system.

Culver City has also adopted the concept of Complete Streets, which emphasizes a balanced transportation system that considers all users of the road (cyclists, pedestrians, transit riders,

94 South Coast Air Quality Management District, 2023. Greenhouse Gases CEQA Significance Thresholds. http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/ghg-significance-thresholds.

Accessed March 2023.
95 South Coast Air Quality Management District, 2008a. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, Attachment E. October 2008. 96 South Coast Air Quality Management District, 2008b. Board Meeting, December 5, 2008, Agenda No. 31. http://www3.aqmd.gov/hb/2008/December/0812ag.html. Accessed March 2023. 97 South Coast Air Quality Management District, 2008c. Greenhouse Gases, CEQA Significance Thresholds, Board Letter – Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. December 5, 2008. 98 Culver City, 2021. 2019 Community Greenhouse Gas Inventory Report, April. https://9021zeroemissions.rinconconsultants.com/wp-content/uploads/2021/11/2.- CulverCity_2019_Community_GHG_Inventory_Clean.pdf. Accessed January 2024.

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4.7. Greenhouse Gas Emissions
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and vehicles) while planning development and transportation projects.99 The goal of this concept is to transform Culver City into a place with an extensive bicycle and pedestrian network that allows travelers of all levels and abilities to feel comfortable walking and biking to their destinations.
100
Culver City Green Building Ordinance and Program
Culver City has adopted green building ordinances to reduce GHG emissions for new development. Culver City has adopted a Photovoltaic Requirement that requires 1 kilowatt (kw) of photovoltaic power installed per 10,000 square feet (sf) of new development or payment of an in-lieu fee.
101 Any new development projects under the General Plan and Zoning Code Update would comply with Culver City Municipal Code (CCMC) Chapter 15.02.105 by either installing a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code or paying an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code.

In 2009, Culver City adopted the Green Building Program that requires new developments totaling more than 50,000 sf to achieve Leadership in Energy and Environmental Design (LEED) equivalent certification.
102 An example of Culver City’s Green Building Program requirements is that all lighting has to be either fluorescent, LED or other type of high-efficiency lighting. Any new development projects under the General Plan and Zoning Code Update would have to meet or exceed the applicable requirements of Culver City’s Green Building Program.

Culver City's Electric Vehicle (EV) Infrastructure Plan The Culver City EV Infrastructure Plan was developed as a result of Culver City’s participation as one of 18 cities in the SCAG 2020 charging station study where SCAG assisted in developing a citywide EV infrastructure plan.
103 As noted in the City’s EV Infrastructure Plan, depending on the mix of EV charging station types, Culver City may need between 380 and 1,154 charging stations by 2030 to support statewide goals. The EV Infrastructure Plan aims to assist Culver City to expand its EV charging network as it determines the most suitable sites in Culver City to install EV charging stations and identifies hurdles to installing EV charging stations and develop solutions. Culver’s City’s EV Infrastructure Plan also highlights that while the City will increase EV charging stations at publicly owned locations, the majority of EV charging stations will be owned and operated by the private sector. The City with assistance from the City's EV Infrastructure Plan looks to foster private EV development by increasing education and awareness about EVs and EV charging stations; create policies and initiatives that encourage and streamline EV

99 Culver City, 2020. Bicycle and Pedestrian Master Plan. Adopted by City Council, June. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021-10-cc-bikepedplan- app2020-v10-final.pdf. Accessed January 2024.
100 Culver City, 2020. Bicycle and Pedestrian Master Plan. Adopted by City Council, June. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021-10-cc-bikepedplan- app2020-v10-final.pdf. Accessed January 2024.
101 Culver City Municipal Code. Section 15.02.105, Solar Photovoltaic Systems. 102 Culver City Municipal Code. Chapter 15.02.1100, Green Building Program and Requirements. 103 SCAG, 2023. SCAG EV Charging Station Study- Electric Vehicle (EV) Infrastructure Plan – Culver City, February 28. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/sustainability/2023-02-cc-scag-ev- studyplan-package-final.pdf. Accessed January 2024.

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charging stations development, installation, and use; and connect EV and EV charging stations stakeholders to funding resources to reduce upfront costs.104 Culver City Bicycle & Pedestrian Action Plan
The City of Culver City updated the Bicycle and Pedestrian Master Plan with the Bicycle and Pedestrian Action Plan (Action Plan), which received public input throughout 2017 through 2019. The Action Plan was adopted by Culver City Council in June 2020. 105 The Action Plan
establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network.

Culver City Clean Power Alliance
Clean Power Alliance (CPA) became the new electricity supplier for Culver City in February 2019 for residential customers and in May 2019 for non-residential customers. With this change, CPA purchases the renewable energy resources for electricity, and Southern California Edison (SCE) delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent, or opt out of the CPA and remain with SCE as their provider.

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

Threshold GHG-1: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Threshold GHG-2: Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

CEQA Guidelines Section 15064.4 assists lead agencies in determining the significance of the impacts of GHG emissions, and gives them discretion to determine whether to assess emissions quantitatively or qualitatively. If a qualitative and quantification-based approach is used, then Section 15064.4 recommends qualitative factors that may be used in the determination of significance. These factors include the extent to which the project may increase or reduce GHG

104 SCAG, 2023. SCAG EV Charging Station Study- Electric Vehicle (EV) Infrastructure Plan – Culver City, February 28. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/sustainability/2023-02-cc-scag-ev- studyplan-package-final.pdf. Accessed January 2024.
105 Culver City, 2020. Bicycle and Pedestrian Master Plan. Adopted by City Council, June. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021-10-cc-bikepedplan- app2020-v10-final.pdf. Accessed January 2024.

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emissions compared to the existing environment, whether the project exceeds an applicable significance threshold, and the extent to which the project complies with regulations or requirements adopted to implement a reduction or mitigation of GHGs. CEQA Guidelines Section 15064.4 does not establish a threshold of significance; rather, lead agencies are granted discretion to establish significance thresholds for their respective jurisdictions, including by looking to thresholds developed by other public agencies, or suggested by other experts, such as the California Air Pollution Control Officers Association, so long as any threshold chosen is supported by substantial evidence (CEQA Guidelines Section 15064.7[c]). The California Natural Resources Agency also has clarified that the CEQA Guidelines focus on the impacts of GHG emissions as cumulative impacts, and that they should be analyzed in the context of CEQA’s requirements for cumulative impact analysis (see also CEQA Guidelines Section 15064[h]). 106
Although GHG emissions can be quantified, CARB, SCAQMD, and Culver City have not adopted quantitative project-level significance thresholds for GHG emissions that apply to the Project. In 2008, OPR released a technical advisory on CEQA and climate change that provided some guidance on assessing the significance of GHG emissions, and states that “lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice,” and that while “climate change is ultimately a cumulative impact, not every individual project that emits GHGs must necessarily be found to contribute to a significant cumulative impact on the environment”.
107 Furthermore, the technical advisory states that “CEQA authorizes reliance on previously approved plans and mitigation programs that have adequately analyzed and mitigated GHG emissions to a less than significant level as a means to avoid or substantially reduce the cumulative impact of a project”. 108
To qualify, such a plan or program 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 (CCR, Title 14, Section 15064(h)(3)). Examples of such programs include a “water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, [and] plans or regulations for the reduction of greenhouse gas emissions” (CCR, Title 14, Section 15064(h)(3)).

Even in the absence of clearly defined thresholds for GHG emissions, the law requires that an agency makes a good faith effort to disclose the GHG emissions from a project and mitigate to the extent feasible whenever the lead agency determines that a project contributes to a significant, cumulative climate change impact. Regardless of which threshold(s) are used, the agency must support its analysis and significance determination with substantial evidence (CEQA Guidelines,Section15064.7).The CEQA Guidelines recommends considering certain

106 See generally CNRA, Final Statement of Reasons for Regulatory Action (December 2009), pp. 11-13, 14, 16; see also Letter from Cynthia Bryant, Director of the OPR to Mike Chrisman, Secretary for Natural Resources, April 13, 2009. 107 Governor’s OPR, 2008. Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, June 19. https://opr.ca.gov/ceqa/docs/20210720-june08- ceqa.pdf. Accessed January 2024.
108 Governor’s OPR, 2008. Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, June 19. https://opr.ca.gov/ceqa/docs/20210720-june08- ceqa.pdf. Accessed January 2024.

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factors, among others, when determining the significance of a project’s GHG emissions, including the extent to which a project may increase or reduce GHG emissions as compared to the existing environment; whether a project exceeds an applicable significance threshold; and extent to which a project complies with regulations or requirements adopted to implement a reduction or mitigation of GHGs.

According to CAPCOA, “GHG impacts are exclusively cumulative impacts; there are no non- cumulative GHG emission impacts from a climate change perspective.” 109 Due to the complex
physical, chemical and atmospheric mechanisms involved in global climate change, there is no basis for concluding that a single project’s increase in annual GHG emissions would cause a measurable change in global GHG emissions necessary to influence global climate change.

Section 15064.4(b) of the CEQA Guidelines states that “in determining the significance of a project’s greenhouse gas emissions, the lead agency should focus its analysis on the reasonable, foreseeable incremental contribution of a project’s emissions to the effects of climate change. A project’s incremental contribution may be cumulatively considerable even if it appears relatively small compared to statewide, national, or global emissions.” The Project consists of planning documents, the approval of which would not directly result in the development of land uses and would not directly result in GHG emissions. Future GHG emissions may result from new developments that could occur from adoption of the proposed General Plan and Zoning Code Updates. This assessment quantifies GHG emissions from such new development under buildout conditions of the proposed General Plan and Zoning Code Update. Although GHG emissions have been quantified as discussed under the Methodology and Assumptions subsection below, neither CARB, SCAQMD, nor Culver City has adopted quantitative significance thresholds. In the absence of any adopted quantitative threshold, the determination of whether or not new development that could occur from adoption of the Project would result in a cumulatively considerable contribution to the cumulative impacts of global climate change is based on the following:
• If the Project would conflict with (and thereby be inconsistent with) the applicable GHG emissions reduction plans, policies, and regulations, which include the emissions reduction measures included within CARB’s 2022 Scoping Plan; SCAG’s 2020–2045 RTP/SCS; and Culver City’s plans, programs, and policies including Culver City’s Green Building Program established for the purpose of increasing energy efficiency and reducing GHG emissions for new developments under the Project.

Greenhouse Gas Emissions
The Climate Action Registry General Reporting Protocol provides procedures and guidelines for calculating and reporting GHG emissions from general and industry-specific activities. Although no numerical thresholds of significance have been adopted, and no specific protocols are available for land use projects, the General Reporting Protocol provides a framework for calculating and reporting GHG emissions. The GHG emissions provided in this report are

109 California Air Pollution Control Officers Association (CAPCOA), 2008. CEQA & Climate Change: Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act..

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consistent with the General Reporting Protocol framework. For the purposes of this PEIR, estimated GHG emissions from the operation of new development that could occur with adoption of the proposed General Plan and Zoning Code Update are quantified to provide information to decision makers and the public regarding the level of the GHG emissions. GHG emissions are typically separated into three categories that reflect different aspects of ownership or control over emissions:
• Scope 1: Direct, on-site combustion of fossil fuels (e.g., natural gas, propane, gasoline, and diesel)
• Scope 2: Indirect, off-site emissions associated with purchased electricity or purchased steam.
• Scope 3: Indirect emissions associated with other emissions sources, such as third-party vehicles and embodied energy.
110
Direct GHG emissions from new development would result from natural gas combustion and landscaping equipment, and indirectly from electricity demand, water conveyance, wastewater generation, solid waste decomposition, and motor vehicles. Since potential impacts resulting from GHG emissions are long-term rather than acute, GHG emissions are calculated on an annual basis.

The quantification of GHGs from any project involves many uncertainties. For example, it is reasonable to assume that some portion of the residents, employees, and visitors that would occupy new development that would occur under the proposed General Plan and Zoning Code Update would engage in similar activities (working, recreating, and driving) that generate GHG emissions without adoption of the proposed General Plan and Zoning Code Update. However, adoption of the proposed General Plan and Zoning Code Update could result in changing travel behavior that reduces vehicle miles traveled. Additionally, newer construction materials and practices, future energy efficiency requirements, future mobile source emission standards, and advances in technology would likely reduce future levels of emissions. However, the net effect is difficult to quantify due to the difficulty in predicting future behaviors of residents, employees, and visitors and future standards and requirements. As such, the estimated net change in emissions that could result from new development under the Project is likely to be an overestimation. These same uncertainties and assumptions exist throughout the accepted analytical methodologies for quantifying GHG emissions. Additional details regarding emissions quantification are provided below.

Construction Emissions
Construction of new development that could occur as a result of the General Plan and Zoning Code Updates would have the potential to increase GHG 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. 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 GHG emissions associated

110 Embodied energy includes energy required for water pumping and treatment for end-uses.

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with future development under the Project cannot be specifically determined at this time.

Therefore, the analysis will be based on the potential for construction to conflict with applicable plans, policies, and regulations to reduce GHG emissions in the context of overall development GHG emissions.

Operational Emissions
Operation of new development that could occur as a result of the Project would generate GHG emissions from on-site operations such as natural gas combustion for heating/cooking, landscaping equipment and the use of consumer products. GHG emissions would also be generated by vehicle trips, electricity demand, water demand, wastewater generation, and solid waste decomposition. Operational impacts were assessed for the full Project buildout year of 2045.

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 region 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 General Plan Circulation 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.

Emissions of GHGs from buildout of new development that could occur under the Project are estimated using CalEEMod, which is a statewide land use emission computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions from a variety of land us projects. CalEEMod was developed in collaboration with the air districts of California and is recommended by the SCAQMD. Regional data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California air districts to account for local requirements and conditions. The model is considered to be an accurate and comprehensive tool for quantifying GHG emissions from land use development throughout California. For new development, CalEEMod default values were used for area source emissions except that wood stoves and wood fireplaces were removed from the emissions calculations as they are not permitted within SCAQMD’s jurisdiction for most new commercial and residential development per SCAQMD Rule 445 and no fireplaces are permitted in multi-family residential units. Future development is assumed to comply with the Title 24 (2022) building energy efficiency standards, 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.

Emissions of GHG from water and wastewater are due to the required energy to supply, distribute and treat. Wastewater also results in emissions of GHGs from wastewater treatment systems. For new development, CalEEMod default water and wastewater related GHG emissions

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are assumed in the analysis. A municipal solid waste diversion rate of 75 percent is assumed in compliance with AB341 (refer to Section 3.18, Utilities and Service Systems, of this PEIR, for additional information regarding AB 341). For solid waste, the default values, as provided in CalEEMod, for landfill gas capture (e.g., no capture, flaring, energy recovery) are statewide averages and are used in this assessment.

In 2019, Culver City automatically enrolled all residential and commercial users to receive electricity from the Clean Power Alliance (CPA). The CPA buys electricity from renewable sources and partners with Southern California Edison to distribute electricity to residential and commercial customers throughout the city. Culver City has chosen 100 percent Green Power as a step to reaching carbon neutrality and all customers are defaulted to receive electricity from 100 percent renewable resources. However, as customers have the ability to choose lower renewable energy percentages or to opt out of the CPA, the analysis conservatively assumes that the renewable usage is equal to that of SCE’s renewable production via compliance with the state’s Renewables Portfolio Standard (which requires local publicly owned electric utilities to procure eligible renewable electricity for 44 percent of retail sales by December 31, 2024, 52 percent by 2027, 60 percent by 2030, and 100 percent by 2045).

Other sources of GHG emissions from operation of developments that could occur under the General Plan and Zoning Code Update include equipment used to maintain landscaping, such as lawnmowers and trimmers. CalEEMod default emission rates were used in calculating GHG emissions from these additional sources. The emissions for landscaping equipment are based on the size of the open space based on the Project’s residential and retail land uses, the GHG emission factors for fuel combustion, and the GWP values for the GHGs emitted. Refrigerant emissions are based on Project land use type since different types of refrigeration equipment are used by different types of land uses. CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing of the refrigeration equipment lifetime, and then derives average annual emissions from the lifetime estimate.

Comparative Net Emissions
As discussed above in Section 4.7.2, Environmental Setting, Culver City prepared the 2019 Community GHG Inventory Report, which is a detailed analysis of year 2019 GHG emissions from the use of electrical and natural gas, transportation, solid waste, off-road equipment, industrial sources, water supply, and wastewater treatment within the city by residents, businesses, and local government operations. A similarly detailed analysis of year 2045 GHG emissions with future buildout of the Project is not possible because data with respect to the exact types of future uses that would be developed, future use activity levels (i.e., utility consumption, trip generation), and building energy standards for each residential or business use is not known at this time. Adoption of the General Plan and Zoning Code Update would not result in the approval of any specific development. Therefore, emissions estimates for future year 2045 GHG emissions with future buildout of the Project are based on default parameters in CalEEMod, version 2022.1, and modifications to default parameters as discussed above. Additionally, as described above, GHG reductions that would likely occur in the future, such as renewable energy from the CPA and increased EV vehicles pursuant to the ACC II Program or future EV programs, are not accounted for in the modeling. Thus, in order to compare the future year

4. Environmental Impact Analysis

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2045 GHG emissions with future buildout of the Project to existing GHG emissions and provide a like-for-like comparison using a similarly conservative and generalized methodology, the existing emissions have been reassessed also using default parameters in CalEEMod, version 2022.1 in 2019, with modifications to default parameters, such as assuming no wood stoves and CalEEMod default usage for fireplaces and assuming a municipal solid waste diversion rate of 50 percent in compliance with AB 939 and SB 1016. Thus, for the purposes of this comparative assessment, year 2045 GHG emissions with future buildout of the Project are conservatively overestimated, as are the reassessed year 2019 existing development GHG emissions.

Consistency with GHG Reduction Plan, Policies, and Actions The Project’s potential for GHG impacts is also evaluated by assessing the Project’s consistency with applicable GHG reduction strategies and local actions adopted by CARB, SCAG, and the City.

As there is no applicable adopted or accepted numerical threshold of significance for GHG emissions, the methodology for evaluating the Project’s impacts related to GHG emissions focuses on whether the Project is not in conflict with, and therefore is consistent with, Statewide, regional, and local plans adopted for the purpose of reducing and/or mitigating GHG emissions. This evaluation of consistency with such plans is the sole basis for determining the significance of the Project’s GHG-related impacts on the environment consistent with CEQA Guidelines Section 15064.4 and CEQA Guidelines Appendix G. Based on CEQA case law, when no guidance exists, the lead agency may look to and assess general compliance with comparable regulatory schemes.
111
A consistency analysis is provided and describes the Project’s compliance with performance- based standards included in the regulations outlined in the applicable portions of CARB’s 2022 Scoping Plan, the 2020-2045 RTP/SCS and the City’s Green Building Program.

For this Project, the City of Culver City serves as the lead agency. OPR encourages lead agencies to make use of programmatic mitigation plans and programs from which to tier when they perform individual project analyses. Culver City does not have a programmatic mitigation plan to tier from, such as a GHG Emissions Reduction Plan as recommended in the CEQA Guidelines.

However, Culver City has adopted the Green Building Program that encourages and requires applicable projects to implement energy efficiency measures. In addition, the California CAT Report provided recommendations for specific emission reduction strategies for reducing GHG emissions and reaching the targets established in HSC Division 25.5. Thus, if the Project incorporates policies and regulations that would not conflict with the above emission reduction strategies for reducing GHG, it would result in a less than significant impact, because it would be consistent with the overarching State regulations on GHG reductions.

111 See Protect Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1107 [“‘[A] lead agency’s use of existing environmental standards in determining the significance of a project’s environmental impacts is an effective means of promoting consistency in significance determinations and integrating CEQA environmental review activities with other environmental program planning and resolution.”’”]. Lead agencies can, and often do, use regulatory agencies’ performance standards. A project’s compliance with these standards usually is presumed to provide an adequate level of protection for environmental resources. See, e.g., Cadiz Land Co. v. Rail Cycle (2000) 83 Cal.App.4th 74, 99 (upholding use of regulatory agency performance standard).

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Appendix D, Local Actions, of the 2022 Scoping Plan Update includes “recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under the California Environmental Quality Act (CEQA).” 112
The State encourages local governments to adopt a CEQA-qualified CAP addressing the three priority areas (transportation electrification, VMT reduction, and building decarbonization).

However, the State recognizes that almost 50% of jurisdictions do not have an adopted CAP, among other reasons because they are costly, requiring technical expertise, staffing, funding.

Additionally, CAPs need to be monitored and updated as State targets change and new data is available. Jurisdictions that wish to take meaningful climate action (such as preparing a non- CEQA-qualified CAP or as individual measures) aligned with the State’s climate goals in the absence of a CEQA-qualified CAP should also look to the three priority areas when developing local climate plans, measures, policies, and actions. “By prioritizing climate action in these three priority areas, local governments can address the largest sources of GHGs within their jurisdiction.”
113
The State also recognizes in Appendix D, Local Actions, of the Scoping Plan that each community or local area has distinctive situations and local jurisdictions must balance the need for housing while demonstrating that a Project is in alignment with the State’s Climate Goals. 114 The State
calls for the climate crisis and the housing crisis to be confronted simultaneously. Jurisdictions should avoid creating targets that are impossible to meet as a basis to determine significance.

Ultimately, targets that make it more difficult to achieve statewide goals by prohibiting or complicating projects that are needed to support the State’s climate goals, like infill development, low-income housing or solar arrays, is not consistent with the State’s goals. The State also recognizes the lead agencies’ discretion to develop evidence-based approaches for determining whether a project would have a potentially significant impact on GHG emissions.

Project Impact Analysis
Generate GHG Emissions
Threshold GHG-1: The Project would have a significant impact if future development allowed by the 2045 General Plan would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

112 CARB, 2022b. 2022 Scoping Plan for Achieving Carbon Neutrality – Appendix D: Local Actions, November. 113 CARB, 2022b. 2022 Scoping Plan for Achieving Carbon Neutrality – Appendix D: Local Actions, November. 114 The State recognizes the need for 2.5 million housing units over the next eight years, with one million being affordable units. See page 20, Appendix D, 2022 Scoping Plan Update, November 2022.

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Impact Statement GHG-1: The Project would result in a less than significant impact related to GHG emissions.

Construction
As stated above, the Project consists of planning documents, the approval of which would not directly result in the development of land uses and would not directly result in GHG emissions.

Future GHG emissions may result from new development that would occur from adoption of the General Plan and Zoning Code Updates. Construction of future new development has the potential to generate GHG emissions 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. Construction emissions can vary substantially from day to day, depending on the level of activity and the specific type and amount of equipment. However, as there are no specific projects currently proposed under the Project 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. Information regarding 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 at this time.

All future projects developed under the General Plan Update would be required to comply with applicable USEPA, CARB and SCAQMD emissions standards, rules, and regulations. In addition, applicable CEQA analysis, as required, would determine significance based on the individual project specifics. Furthermore, future construction activities under the General Plan 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 (13 CCR, Section 2485), CARB In-Use Off-Road Diesel Vehicle regulation, CARB Truck and Bus regulation, SAFE Vehicle Rule (or its successor rule), and CARB Advanced Clean Car and Advanced Clean Trucks regulations, all of which support the goals of the CARB Climate Change Scoping Plan by requiring 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 vehicle and truck technologies as they become developed and commercially available.

Mandatory compliance with these rules and regulations would reduce GHG emissions, including fuel combustion emissions of CO
2, CH4, and N2O, during future construction activities under the General Plan Update.

Operation
Operation of future development under the General Plan Update would generate emissions of GHG emissions from vehicle trips traveling within the city, energy sources such as electricity demand and natural gas combustion, area sources such as fireplaces and landscaping equipment, water conveyance and distribution, wastewater treatment, and solid waste decomposition. Projected emissions resulting from operational activities of both existing and future development resulting from the General Plan Update are presented in Table 4.7-7, Unmitigated Annual Greenhouse Gas Emissions.

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TABLE 4.7-7

UNMITIGATED ANNUAL GREENHOUSE GAS EMISSIONS
Emissions Sources CO2e (Metric Tons per Year) a,b
Existing Development plus New Development (2045)
Mobile (Based on 2045 with GPU VMT) 227,221
Area (Fireplaces, Landscaping) 5,562
Energy (Electricity)c 148,803
Solid Waste 17,291
Water and Wastewater 6,984
Refrigerants 162
Annual Emissions 406,023
Existing Development (2019)d 524,285
Comparative Net Change (118,262)
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix E.
b CO2e emissions are calculated using the global warming potential values from the Intergovernmental Panel on Climate Change Fourth Assessment Report.
c Consistent with Senate Bill 1020, the proposed General Plan buildout would use 100 percent renewable electricity by 2045. In addition, the General Plan buildout would not include any natural gas infrastructure. d These GHG emissions are different from those presented in the Culver City 2019 Community GHG Inventory Report. In order to compare the future year 2045 GHG emissions with future buildout of the Project to existing GHG emissions and provide a like-for-like comparison using a similarly conservative and generalized methodology, the existing emissions have been reassessed using default parameters in CalEEMod, version 2022.1 in 2019, with modifications to default parameters, such as assuming no wood stoves and CalEEMod default usage for fireplaces and assuming a municipal solid waste diversion rate of 50 percent in compliance with AB 939 and SB 1016. Thus, for the purposes of this comparative assessment, year 2045 GHG emissions with future buildout of the Project are conservatively overestimated, as are the reassessed year 2019 existing development GHG emissions.

SOURCE: ESA, 2024.

As shown in Table 4.7-7, applying consistent GHG emissions modeling methodologies, the net change in operational emissions from existing development (2019) compared to existing plus buildout under the General Plan Update at 2045 would be negative primarily due to the focus of the General Plan Update on infill development and development along transportation corridors to achieve an integrated land use mix that would accommodate growth while reducing VMT and associated emissions, improvements in vehicle emissions standards and, to a lesser extent, improvements in building energy efficiency standards. Development of future residential and nonresidential uses would be based on market demand and would be constructed over the buildout through 2045.

The proposed General Plan policies, listed below, would reduce potential emissions from future new, as well as existing, development. As required by SB 1000, the Community Health and Environmental Justice Element identifies SB 1000 Priority Neighborhoods (refer to Section 4.2, Air Quality, for additional information on SB 1000). The Community Health and Environmental Justice Element includes several policies relevant to reducing GHG emissions and sustainability.

In addition, as applicable, applicants for future development under the General Plan Update requiring discretionary approval would conduct CEQA analysis to determine significance based on the individual project specifics. Through each project’s environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual

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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 GHG emissions control strategies and regulations as discussed above. As shown in Table 4.7-7, applying consistent GHG emissions modeling methodologies, the net change in operational emissions from existing development (2019) to existing plus buildout at 2045 would be negative compared to existing (2019) development primarily due to the focus of the proposed General Plan Update on infill development and development along transportation corridors to 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. Since the Zoning Code Update would provide the development standards to implement the General Plan Update, and would be consistent with the General Plan Update, the Zoning Code Update would result in a less than significant 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-2.5: 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-2.9: Climate justice. Ensure SB 1000 Priority Neighborhoods are considered in all future programs related to sustainable development, greenhouse gas mitigation, and climate adaptation.

Greenhouse Gas Reduction Element
Goal GHG-1: Carbon Neutrality. A carbon neutral community by 2045 in line with or exceeding State targets.

GHG-1.1: GHG inventory. Update the community and municipal GHG inventories every five years to track progress toward achieving the City’s GHG reduction goal.

GHG-1.2: Reduction measures. Maintain and regularly update GHG reduction measures in the General Plan to reduce GHG emissions generated within the city. Formalize and make necessary changes to the City’s climate action strategy based on results of the five- year GHG inventory updates to achieve the City’s GHG reduction goals.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-48 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
GHG-1.3: New technologies. Regularly evaluate new and emerging technology changes that can help to reduce GHG emissions and encourage using technology that is demonstrated to be effective at reducing GHG emissions in a fiscally responsible manner.

GHG-1.4: Funding sources. Seek additional funding sources to support implementing GHG reduction projects for the City, residents, and businesses.

GHG-1.5: Support GHG reduction. Initiate or support legislation and regulations that are designed to establish achievable targets and to fund programs that ensure that all cities can achieve their GHG reduction goals.

Goal GHG-2: Green buildings. Green and decarbonized buildings are the standard for new construction, major renovations, and existing building retrofits.

GHG-2.2: All electric buildings. Foster a transition to all-electric buildings.

GHG-2.4: Energy and water efficiency. Improve the energy and water efficiency of new and existing buildings.

GHG-2.6: Passive heating and cooling. Encourage and ensure dissemination of resources for solar energy generation and passive heating and cooling strategies.

GHG-2.7: Efficiency outreach. Educate residents and businesses on available incentive and rebate opportunities to reduce energy and water use.

Goal GHG-3: Municipal buildings and facilities. The environmental efficiencies and performance of municipal buildings, facilities, landscaping, and parks in Culver City is improved.

GHG-3.2: Benchmarking. Regularly benchmark the environmental performance of municipal buildings, landscaping, parks, and facilities.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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Preliminary − Subject to Revision
GHG-3.4: Waste diversion. Encourage municipal construction projects to achieve 75 percent waste diversion from the landfill.

Goal GHG-4: Decarbonized transportation sector. GHG emissions from the transportation sector are eliminated.

GHG-4.1: Zero emission vehicles. Enable the shift to zero emission vehicles.

GHG-4.2: Public electric vehicle (EV) chargers. Install additional EV chargers at suitable public facilities and curbside, including Downtown parking structures, community parks, and mobility hubs.

GHG-4-4: Zero-emission vehicle fleet purchases. When buying new City vehicles, purchase zero emission vehicles when feasible.

GHG-4.5: Zero emission fuels. Transitioning existing vehicles and construction and maintenance equipment to zero emission fuels.

Goal GHG-5: Zero Waste. Increase resource capture and decrease waste sent to landfills.

GHG-5.1: Zero waste. Achieve zero waste through adoption of circular economy principles such as recovery, reuse, and sharing of resources.

GHG-5.3: Zero waste textile program. Explore establishing a zero-waste textile initiative and collection system.

Goal GHG-6: Sustainability. A city that is aware of its ecology and environmental past and present.

GHG-6.1: Sustainability in City decision-making. Integrate environmental and sustainability outcomes and issues into City decision-making processes, operations, and community activities.

GHG-6.2: Sustainability education. Coordinate with the Culver City Unified School District (CCUSD) to integrate environmental literacy into their student curriculum and in City-sponsored programs or events.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-50 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Conservation Element
Goal C-2: Biological resources. Habitats for sensitive, threatened, and endangered wildlife species are protected and enhanced to support healthy, diverse ecosystems, and carbon storage.

C-2.3: Vegetation at parks and open spaces. Manage vegetation at parks and open spaces in Culver City to support biodiversity by reducing pesticide use and reducing use of non-native species.

C-2.4: Tree planting. Plant and maintain trees to sequester carbon, reduce urban heat, provide habitat, and contribute to the city’s character.

Goal C-6: Ballona Creek. Ballona Creek is transformed such that it mitigates flooding, restores native ecologies, and becomes a scenic multi-purpose open space and recreational corridor.

C-6.5: Climate change and Ballona Creek. Account for climate change and apply current accepted models in planning for and assessing flood risk along the Ballona Creek corridor.

C-6.10: Trees and landscaping along Ballona Creek. Expand tree planting along Ballona Creek to sequester carbon, adapt to climate change, and provide habitat for wildlife.

C-6.12: Sustainable planting along Ballona Creek. Establish Ballona Creek as a sustainable scenic recreational and open space corridor by planting native trees and other compatible landscaping.

Safety Element
Goal S-1: Community resilience. The City proactively advances community resilience and is prepared for all hazards, including climate disruption.

S-1.8: Coordinate with regional and State agencies. Coordinate with regional and State agencies to monitor potential changes in severity, frequency, and affected areas from future emergency situations, especially due to climate change.

S-1.9: Municipal climate preparedness planning and assessment. Implement climate preparedness planning across City departments, programs, and operations.

Goal S-7: Fire hazards. Threats to public safety from wildland and urban fire hazards are reduced and property damage minimized.

S-7.6: Firefighting capability. Strengthen the City firefighting capability to respond to multiple fire incidents caused by an earthquake, Santa Ana winds, climate change, or other extraordinary circumstances.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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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-10.2: Heat island impacts. Reduce the heat island effect115 by implementing a variety of adaptation solutions.

S-10.3: Cooling and warming centers. Review, update, and maintain facilities that can be used for refuge during excessive heat and cold days.

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

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 GHG emissions, either directly or indirectly, that may have a significant impact on the environment.

Conflict with GHG Reduction Plan, Policy, or Regulation Threshold GHG-2: The Project would have a significant impact if future development allowed by the 2045 General Plan would conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

Impact Statement 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.

In the absence of any adopted quantitative threshold, the significance of the Project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b)(2) by considering whether the Project complies with applicable plans, policies, regulations, and requirements adopted for the purpose of reducing the emissions of GHGs.

The analyses below demonstrate that the Project is consistent with the applicable GHG emission reduction plans and policies included within the 2022 Scoping Plan, SCAG’s 2020–2045 RTP/SCS, and the City of Culver City’s Green Building Program.

115 The heat island effect refers to urban areas with higher temperatures compared to natural landscapes. These high temperatures result from the infrastructure and materials used in urban areas that absorb and re-emit the sun’s heat more than natural landscapes. Heat islands can impact human health, the environment, economy, and other issues.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
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2022 Scoping Plan
The 2022 Scoping Plan outlines a framework that relies on a broad array of GHG reduction actions, which include direct regulations, alternative compliance mechanisms, incentives, voluntary actions, and market-based mechanisms, such as the Cap-and-Trade program. The 2022 Scoping Plan builds off of a wide array of regulatory requirements that have been promulgated to reduce Statewide GHG emissions, particularly from energy demand and mobile sources. While these regulatory requirements are not targeted at specific land use development projects, they would indirectly reduce a development project’s GHG emissions.

Certain elements of these regulations must be complied with by all projects that develop urban land uses (e.g., commercial, residential, industrial). This category of regulations can be grouped in terms of the GHG sector that benefit from their implementation. As discussed below, with regard to the energy sector, implementation of the California RPS program and SB 100 and SB 350, would reduce GHG emissions generated by energy consumption. With regard to the mobile sector, implementation of the Advanced Clean Cars Program, LCFS, and SB 375 would reduce GHG emissions generated by motor vehicle travel. In addition, ongoing implementation of the Cap-and-Trade Program would reduce GHG emissions from both energy consumption and the fuels used for motor vehicle travel. With regard to the solid waste sector, implementation of the California Integrated Waste Management Act of 1989 and AB 341 would reduce GHG emissions generated by solid waste disposal in terms of reduced vehicle trips associated with the transport of solid waste materials as well as landfill emissions. Further, Project development would occur in accordance with these regulations and, therefore, would comply with their requirements and would not conflict with the implementation of these regulations.

In addition, as explained above, the CARB 2022 Scoping Plan expands on prior Scoping Plans and recent legislations, such as AB 1279, by outlining a technologically feasible, cost-effective, and equity-focused path to achieve the state’s climate target of reducing anthropogenic GHG emissions to 85 percent below 1990 levels and achieving carbon neutrality by 2045 or earlier. 116
To achieve carbon neutrality by 2045, the 2022 Scoping Plan contains GHG reductions, technology, and clean energy mandated by statutes, reduction of short-lived climate pollutants, and mechanical carbon dioxide capture and sequestration actions.

Table 4.7-8, Consistency with Applicable Scoping Plan Greenhouse Gas Reduction Strategies, contains a list of the GHG-reducing strategies from the 2022 Scoping Plan. The analysis describes the General Plan Update’s compliance and consistency with these strategies outlined in the State’s Scoping Plan to reduce GHG emissions. As discussed below, the General Plan Update would not conflict with applicable 2022 Scoping Plan strategies and regulations to reduce GHG emissions.

116 CARB, 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality, December.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-53 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.7-8

CONSISTENCY WITH APPLICABLE SCOPING PLAN

GREENHOUSE GAS REDUCTION STRATEGIES
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Transportation Technology Sector
• Achieve 100 percent ZEV sales of light duty vehicles by 2035 and medium heavy-duty vehicles by 2040.
• Achieve 20 percent zero-emission target for the aviation sector. • Develop a rapid and robust network of ZEV refueling infrastructure to support needed transition to ZEVs.
• Ensure that the transition of ZEV technology is affordable for low income households and communities of color, and meets the needs of communities and small business.
• Prioritize incentive funding for heavy-duty ZEV technology deployment in regions of the state with the highest concentrations of harmful criteria and toxic air contaminant emissions.
• Promote private investment in the transition to ZEV technology, undergirded by regulatory certainty such as infrastructure credits in the Low Carbon Fuel Standard for hydrogen and electricity and hydrogen station grants from the CEC’s Clean Transportation Program pursuant to Executive Order B-48-18.
• Evaluate and continue to offer incentives similar to those through FARMER, Carl Moyer, the Clean Fuel Reward Program, the
Community Air Protection Program, the Low Carbon Transportation, including CORE. Where feasible, prioritize and increase funding for clean transportation equity programs.
• Continue and accelerate funding support for zero emission vehicles and refueling infrastructure through 2030 to ensure the rapid transformation of the transportation sector.

State agencies and local
agencies
Would Not Conflict. Vehicles must transition to zero emission technology to decarbonize the transportation sector. Executive Order N-79-20 reflects the urgency of transitioning to zero emission vehicles (ZEVs) by establishing target dates for reaching 100 percent ZEV sales or fleet transitions to ZEV technology. EO N-79-20 calls for 100 percent ZEV sales of new light-duty vehicles by 2035. The Advanced Clean Cars II regulation fulfills this goal and serves as the primary mechanism to help deploy ZEVs. A number of existing incentive programs also support this transition, including the Clean Cars 4 All Program. EO N-79-20 also sets targets for transitioning the medium- and heavy-duty fleet to zero emissions by 2035 for drayage trucks and by 2045 for buses and heavy-duty long-haul trucks where feasible. Replacing heavy-duty vehicles with ZEV technology will significantly reduce GHG emissions and diesel PM emissions in low-income communities and communities of color adjacent to ports, distribution centers, and highways. The existing Advanced Clean Trucks regulation, paired with the Advanced Clean Fleets regulation, are designed to transition a significant amount of the Off-road vehicles rely heavily on ICE technology and EO N-79-20 sets an off-road equipment target of transitioning the entire fleet to ZEV technology by 2035, where feasible. There are a number of funding sources available to support this transition, including FARMER, Carl Moyer, and Community Air Protection Incentives; as well as Low Carbon Transportation Incentives, including the Clean Off-Road Equipment (CORE) program.

Refueling infrastructure is a crucial component of transforming transportation technology. Electric vehicle chargers and hydrogen refueling stations must become easily accessible for all drivers to support a wholesale transition to ZEV technology. Deployment of ZEV refueling infrastructure is currently supported by a number of existing local and state public funding mechanisms.

Intrastate aviation relies on ICE technology today, but battery-electric and hydrogen fuel cell aviation applications are in development, along with sustainable aviation fuel.

While these actions and strategies apply to state and local agencies and do not directly apply to land use development planning projects, the standards would apply to all vehicles purchased or used by occupants, vendors, and visitors of Culver City. Future development facilitated by adoption of the General Plan Update would be required to comply with the CCMC and CALGreen requirements regarding the number of electric vehicle-ready and electric vehicle-capable parking spaces to support ZEVs and PHEVs. As such, the General Plan Update would not conflict with implementation of this strategy.

As with the LDV sector, a number of incentive programs support this transition, such as the Hybrid and Zero-Emission Truck and Bus Voucher Incentive

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-54 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Project (HVIP) with implementation of standards under the Advanced Clean Cars II Program, Advanced Clean Fleet Regulation, and HVIP consistent with reduction of GHG emissions under AB 1279. GHG emissions generated by passenger, truck, and bus vehicular travel as a result of future development under the General Plan Update would benefit from the above regulations and programs, and mobile source emissions would be reduced with implementation. Additionally, the General Plan Update has a goal of decarbonizing the transportation sector by shifting to ZEV; providing EV chargers at public facilities; encouraging installation of EV chargers in multi-unit residential and mixed-use dwellings, single-family homes, workplaces, and shopping centers; purchasing only new EV vehicles for the City’s fleet; and transitioning existing fleet vehicles and construction and maintenance equipment to ZE fuels. Thus, the General Plan Update would not conflict with actions under the transportation technology sector.

Transportation Fuels Sector
• Accelerate the reduction and replacement of fossil fuel production and consumption in California.
• Incentivize private investment in new zero-carbon fuel production in California.
• Incentivize the transition of existing fuel production and distribution assets to support deployment of low- and zero-carbon fuels while protecting public health and the environment.
• Invest in the infrastructure to support reliable refueling for transportation such as electricity and hydrogen refueling. • Evaluate and propose, as needed, changes to strengthen the Cap- and-Trade Program.
o Initiate a public process focused on options to increase the stringency and scope of the LCFS:
o Evaluate and propose accelerated carbon intensity targets pre- 2030 for LCFS.
o Evaluate and propose further declines in LCFS post-2030 carbon intensity targets to align with this 2022 Scoping Plan. o Consider integrating opt-in sectors into the program. o Provide capacity credits for hydrogen and electricity for heavy- duty fueling.
• Monitor for and ensure that raw materials used to produce low- carbon fuels or technologies do not result in unintended consequences.

City Council Meeting AgendaAugust 26, 2024

City Council Meeting Agenda
August 26, 2024