ATT_1_Proposed_Resolution_to_Adopt_EIR.pdf — City Council Meeting Agenda, August 26, 2024 (part 4 of 6)

State agencies and local
agencies
Would Not Conflict. The state must continue to support low-carbon liquid fuels during this period of transition and for much harder sectors for ZEV technology such as aviation, locomotives, and marine applications.

Biomethane currently displaces fossil fuels in transportation and will largely be needed for hard-to-decarbonize sectors but will likely continue to play a targeted role in some fleets while the transportation sector transitions to ZEVs.

Private investment in alternative fuels will play a key role in diversifying the transportation fuel supply away from fossil fuels. EO N-79-20 calls on state agencies to support the transition of existing fuel production facilities away from fossil fuels and directs that this transition also protect and support workers, public health, safety, and the environment. In line with this direction, existing refineries could be repurposed to produce sustainable aviation fuel, renewable diesel, and hydrogen.

While these actions and strategies apply to state and local agencies, 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, and mobile source emissions generated by future development under the General Plan Update would be reduced with implementation of the wider use of zero-carbon fuels consistent with reduction of GHG emissions under AB 1279. Additionally, the General Plan Update has a goal of decarbonizing the transportation sector by transitioning existing fleet vehicles and construction and maintenance equipment to ZE fuels. Thus, the General Plan Update would not conflict with actions in the transportation fuels sector.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-55 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Vehicles Miles Traveled Sector
• Achieve a per capita VMT reduction of at least 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045. • Reimagine new roadway projects that decrease VMT in a way that meets community needs and reduces the need to drive.
• Invest in making public transit a viable alternative to driving by increasing affordability, reliability, coverage, service frequency, and consumer experience.
• Implement equitable roadway pricing strategies based on local context and need, reallocating revenues to improve transit, bicycling, and other sustainable transportation choices
• Expand and complete planned networks of high-quality active transportation infrastructure.
• Channel the deployment of autonomous vehicles, ride-hailing services, and other new mobility options toward high passenger- occupancy and low VMT-impact service models that complement transit and ensure equitable access for priority populations. • Streamline access to public transportation through programs such as the California Integrated Travel Project.
• Ensure alignment of land use, housing, transportation, and conservation planning in adopted regional plans, such as regional transportation plans (RTP)/ sustainable communities strategies (SCS), regional housing needs assessments (RHNA), and local plans (e.g., general plans, zoning, and local transportation plans), and develop tools to support implementation of these plans. • Accelerate infill development and housing production at all affordability levels in transportation-efficient places, with a focus on housing for lower income residents.

State agencies and local
agencies
Would Not Conflict. Managing total demand for transportation energy by reducing the miles people need to drive on a daily basis is also critical as the state aims for a sustainable transportation sector in a carbon neutral economy.

VMT reductions will play an indispensable role in reducing overall transportation energy demand and achieving the state’s climate, air quality, and equity goals.

CARB did not set regulatory limits on VMT in the 2022 Scoping Plan because the authority to reduce VMT largely lies with state, regional, and local transportation, land use, and housing agencies, along with the Legislature and its budgeting choices.

While these actions and strategies apply to state and local agencies, SB 375 requires SCAG to direct the development of the RTP/SCS for the region. The General Plan Update would not conflict with the RTP/SCS goal to adapt to a changing climate and to support an integrated regional development pattern.

Further, the location, design, and land use from future growth anticipated by the General Plan Update would implement land use and transportation strategies related to reducing vehicle trips for residents and employees of the City by increasing future mixed-use, commercial, and residential developments around major transit areas. Several transit agencies provide local and regional transit service within 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 in Section 4.16, Transportation, of this Draft PEIR, for a summary of transit service in Culver City.

The General Plan Update focuses on thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The 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 would 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 transit-oriented communities (TOC), the land use plan for the City promotes the retention and expansion of creative economy businesses and other emerging technologies in these industrial mixed-use areas and mixed- use corridors; supports the needs of neighborhood-serving retail by encouraging commercial and experiential opportunities, particularly in the Downtown area; and advances strategies that ensure a safe and effective phase out of the Inglewood Oil Field (IOF). The 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 contains policies to reduce VMT such as prioritizing

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-56 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis multimodal projects and integrated public transportation services, providing a cohesive active travel network, providing high-quality transit services, reducing first/last mile barriers, providing secure and covered bicycle parking at key destinations, providing equitable transit access, and providing accessible pedestrian facilities, Therefore, the General Plan Update would not conflict with the VMT reduction standards of the RTP/SCS and the General Plan Update would not conflict with applicable RTP/SCS actions and strategies to reduce GHG emissions.

Clean Electricity Grid Sector
• Use long-term planning processes (Integrated Energy Policy Report, IRP, CAISO Transmission Planning Process, AB 32 Climate Change Scoping Plan) to support grid reliability and expansion of renewable and zero-carbon resource and infrastructure deployment. • Complete systemwide and local reliability assessments across CAISO and other balancing authority areas, using realistic assumptions for land use, build rates, statewide and distribution system level constraints, and energy needs. Such assessments should be completed before state agencies update their electricity sector GHG targets.
• Prioritize actions to mitigate impacts to electricity reliability and affordability and provide sufficient flexibility in the state’s decarbonization roadmap for adjustments as may be needed. • Facilitate long lead-time resource development through the IRP and the SB 100 interagency process and through technology
development and demonstration funding376 that includes resources such as long-duration energy storage and hydrogen production. • Continue coordination between energy agencies and energy proceedings to maximize opportunities for demand response. • Continue to explore the benefits of regional markets to enhance decarbonization, reliability, and affordability.
• Address resource build-out challenges, including permitting, interconnection, and transmission network upgrades.
• Explore new financing mechanisms and rate designs to address affordability.
• Per SB 350, double statewide energy efficiency savings in electricity and fossil gas end uses by 2030, through a combination of energy efficiency and fuel substitution actions.
• Per SB 100 and SB 1020, achieve 90 percent, 95 percent, and 100 percent renewable and zero-carbon retail sales by 2035, 2040, and 2045, respectively.
• Evaluate and propose, as needed, changes to strengthen the Cap- and-Trade Program.

State agencies and local
agencies
Would Not Conflict. Decarbonizing the electricity sector depends on both using energy more efficiently and replacing fossil-fueled generation with renewable and zero carbon resources, including solar, wind, energy storage, geothermal, biomass, and hydroelectric power. The RPS Program and the Cap-and-Trade Program continue to incentivize dispatch of renewables over fossil generation to serve state demand.

SB 100 increased RPS stringency to require 60 percent renewables by 2030 and for California to provide 100 percent of its retail sales of electricity from renewable and zero-carbon resources by 2045. Furthermore, SB 1020 has added interim targets to SB 100’s policy framework to require renewable and zero-carbon resources to supply 90 percent of all retail electricity sales by 2035 and 95 percent of all electricity retail sales by 2040; establish a planning goal of at least 20 GW of offshore wind by 2045; and that state agencies plan for an energy transition that avoids the need for new fossil gas capacity to meet California’s long-term energy goals.

California also continues to advance its appliance and building energy efficiency standards to reduce growth in electricity consumption and meet the SB 350 goal to double statewide energy efficiency savings in electricity and fossil gas end uses by 2030. Increased transportation and building electrification and continued policy commitment to behind-the-meter solar and storage will continue to drive growth of microgrids and other distributed energy resources (DER).

Continued transition to renewable and zero-carbon electricity resources will enable electricity to become a zero-carbon substitute for fossil fuels. To reach the 2045 target, the state will need to quadruple its current level of wind and solar capacity. This transformation will drive investments in a large fleet of generation and storage resources but will also require significant transmission to accommodate these new capacity additions. Resources such as storage and demand-side management are essential to maintain reliability with high concentrations of renewables. Hydrogen produced from renewable resources and renewable feedstocks can serve a dual role as a low-carbon fuel for existing combustion turbines or fuel cells, and as energy storage for later use.

While these actions and strategies apply to state and local agencies, the General Plan Update would support SB 100’s goals since future development facilitated by adoption of the General Plan Update would utilize the renewable energy provided by the regulated entity, SCE. SCE is required to generate

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-57 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis • Target programs and incentives to support and improve access to renewable and zero-carbon energy projects (e.g., rooftop solar, community owned or controlled solar or wind, battery storage, and microgrids) for communities most at need, including frontline, low- income, rural, and indigenous communities.
• Prioritize public investments in zero-carbon energy projects to first benefit the most overly burdened communities affected by pollution, climate impacts, and poverty.
electricity that would increase renewable energy resources to 50 percent by 2030. Further, Culver City is supplied with electricity by the CPA, which 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. The CPA automatically defaults to supplying 100 percent renewable energy to Culver City, although 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. As the CPA or SCE would provide electricity service to future development facilitated by the General Plan Update would use electricity consistent with the requirements of SB 100. In 2020, SCE provided 43 percent from renewable sources, exceeding the required target 33 percent by 2020 established under previous legislation.

The General Plan Update would comply with this action/strategy as the City is located within the SCE service area and future development facilitated by the General Plan Update would be required to comply with CALGreen and Title 24 energy efficiency standards. Additionally, the General Plan Update includes a goal for fossil fuel free energy which includes giving residents and businesses affordable access to carbon free and renewable energy resources, enhancing local energy generation and storage, aligning energy conversion and enhancement projects with public open space and trails provisioning, and ensuring compliance with adopted building reach codes to mandate building electrification. As such, the General Plan Update would not conflict with SB 100.

As required under SB 350, doubling of the energy efficiency savings from final end uses of retail customers by 2030 would primarily rely on the existing suite of building energy efficiency standards under California Code of Regulations Title 24, Part 6 and utility-sponsored programs such as rebates for high- efficiency appliances, HVAC systems, and insulation. Future development facilitated by the General Plan Update would meet or exceed the applicable requirements of Title 24, Part 6, as well as the California Green Building Standards Code in Title 24, Part 11 as adopted and amended in the CCMC.

The General Plan Update would further support this action and strategy by incorporating energy efficiency measures as outlined in the General Plan Update policies. As such, the General Plan Update would not conflict with SB 350.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-58 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Sustainable Manufacturing and Buildings Industry Sector • Maximize air quality benefits using the best available control technologies for stationary sources in communities most in need, including frontline, low-income, disadvantaged, rural, and tribal communities.
• Prioritize alternative fuel transitions first in communities most in need, including frontline, low-income, disadvantaged, rural, and tribal communities.
• Invest in research and development and pilot projects to identify options to reduce materials and process emissions along with energy emissions in California’s industrial manufacturing facilities, leveraging programs like the CEC’s Electric Program Investment Charge (EPIC). • Evaluate and propose, as needed, changes to strengthen the Cap- and-Trade Program.
• Support electrification with changes to industrial rate structures. • Develop infrastructure for CCS and hydrogen production to reduce GHG emissions where cost-effective and technologically feasible non-combustion alternatives are not available.
• Implement SB 905.
• Establish markets for low-carbon products and recycled materials using Buy Clean California Act and other mechanisms relying on robust data
• Develop a net-zero cement strategy to meet SB 596 targets for the GHG intensity of cement use in California.
• Continue to leverage energy-efficiency programs, including the U.S.

DOE’s ENERGY STAR program, U.S. DOE’s Superior Energy
Performance program, and ISO 50001.
• Evaluate and continue to offer incentives to install energy efficiency and renewable energy technologies through programs such as CPUC decisions as part of rulemaking R.19-09-009393 and the CEC’s Food Production Investment Program (FPIP) and EPIC programs.
• Leverage low-carbon hydrogen programs, including the Bipartisan Infrastructure Law, for regional hydrogen hubs, hydrogen electrolysis, and hydrogen manufacturing and recycling.
• Evaluate the role of hydrogen in meeting GHG emission reductions, including policy recommendations regarding the use of hydrogen in California as required by SB 1075.
• Address cost barriers to promote low-carbon fuels for hard-to-electrify industrial applications.

State agencies and local
agencies
Consistent. Fossil gas is the primary gaseous fossil fuel used to produce heat at industrial facilities, as well as in residential and commercial buildings.

Gaseous fossil fuel use can be displaced by four primary alternatives: zero- carbon electricity, solar thermal heat, hydrogen, and biogas/biomethane. The 2022 Scoping Plan reduces dependence on fossil gas in the industrial and building sectors by transitioning substantial energy demand to alternative fuels.

Combustion of fossil gas, other gaseous fossil fuels, and solid fossil fuels provide energy to meet three broad industry needs: electricity, steam, and process heat. Non-combustion emissions result from fugitive emissions and from the chemical transformations inherent to some manufacturing processes.

About 20 percent of the GHG emissions from the industrial sector are non- combustion emissions. Decarbonizing industrial facilities depends upon displacing fossil fuel use with a mix of electrification, solar thermal heat, biomethane, low- or zero-carbon hydrogen, and other low-carbon fuels to provide energy for heat and reduce combustion emissions. Emissions also can be reduced by implementing energy efficiency measures and using substitute raw materials that can reduce energy demand and some process emissions.

Some remaining combustion emissions and some non-combustion CO 2 emissions can be captured and sequestered. This sector has a continuing demand for fossil gas due to lack of non-combustion technologically feasible or cost-effective alternatives for certain industrial sectors. Microgrids powered by renewable resources and with battery storage are emerging as a key enabler of electrification and decarbonization at industrial facilities.

While these actions and strategies apply to state and local agencies, each future project developed under the General Plan Update would be required to comply with applicable USEPA, CARB and SCAQMD emissions standards, rules, and regulations regarding fossil fuel use. The General Plan Update would not conflict with actions in the sustainable manufacturing and buildings industry sector.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-59 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Sustainable Manufacturing and Buildings Building Sector • Prioritize California’s most vulnerable residents with the majority of funds in the new $922 million Equitable Building Decarbonization program, created through the 2022–2023 state budget. This would include residents in frontline, low-income, disadvantaged, rural, and tribal communities. This program is dedicated to a statewide direct- install building retrofit program for low-income households to replace fossil fuel appliances with electric appliances, energy-efficient lighting, and building insulation and sealing while also coordinating reductions in gas infrastructure in specific geographic areas. • Achieve three million all-electric and electric-ready homes by 2030 and seven million by 2035 with six million heat pumps installed statewide by 2030.
• Expand incentive programs to support the holistic retrofit of existing buildings, especially for vulnerable communities.
• Ensure that incentive programs prioritize energy affordability and tenant protections, promote affordable and low-income household retrofits that improve habitability and reduce expenses, protect and empower small landlords and homeowners, address overlooked consumer groups, and pair decarbonization with other critically needed renovation efforts to ensure that buildings support human health and are climate- and weather-resistant.
• End fossil gas infrastructure expansion for newly constructed buildings.
• Evaluate and propose, as needed, changes to strengthen the Cap- and-Trade Program.
• Strengthen California’s building standards to support zero-emission new construction.
• Develop building performance standards for existing buildings. • Adopt a zero-emission standard for new space and water heaters sold in California beginning in 2030, as specified in the 2022 State Strategy for the State Implementation Plan.
• Expand use of low-GWP refrigerants within buildings.
• Support electrification with changes to utility rate structures and by promoting load management programs.
• Increase funding for incentive programs and expand financing assistance programs focused on existing buildings and appliance replacements.
• Expand consumer education efforts to raise awareness and stimulate the adoption of decarbonized buildings and appliances, especially in vulnerable communities.

State agencies and local
agencies
Would Not Conflict. Achieving carbon neutrality must include transitioning away from fossil gas in residential and commercial buildings and will rely primarily on advancing energy efficiency while replacing gas appliances with non-combustion alternatives. This transition must include the goal of trimming back the existing gas infrastructure, so pockets of gas-fueled residential and commercial buildings do not require ongoing maintenance of the entire limb for gas delivery. Blending low-carbon fuels such as hydrogen and biomethane into the pipeline further displaces fossil gas. Pipeline safety and reliability must be evaluated to accommodate low-carbon fuels. This transition is achieved when all new buildings constructed include non-combustion appliances, and appliances in existing buildings are replaced at the end of their useful life with non-combustion alternatives.

While these actions and strategies apply to state and local agencies, as stated above, each future project developed under the General Plan Update would be required to comply with applicable USEPA, CARB and SCAQMD emissions standards, rules, and regulations regarding fossil fuel use. The General Plan Update would not conflict with actions in the sustainable manufacturing and buildings industry sector.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-60 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis • Implement biomethane procurement targets for investor-owned utilities as specified in SB 1440 (Hueso, Chapter 739, Statutes of 2018) to reduce GHG emissions in remaining pipeline gas and reduce methane emissions from organic waste.

Carbon Dioxide Removal and Capture Sector
• Implement SB 905
• Convene a multi-agency Carbon Capture and Sequestration Group comprised of federal, state, and local agencies to engage with environmental justice advocates, tribes, academics, researchers, and community representatives to identify the current status, concerns, and outstanding questions concerning CCS, and develop a process to engage with communities to understand specific concerns and consider guardrails to ensure safe and effective deployment of CCS. • Iteratively update the CARB CCS Protocol with the best available science and implementation experience.
• Incorporate CCS into other sectors and programs beyond transportation where cost-effective and technologically feasible options are not currently available and to achieve the 85 percent reduction in anthropogenic sources below 1990 levels as called for in AB 1279.
• Evaluate and propose, as appropriate, financing mechanisms and incentives to address market barriers for CCS and CDR.
• Evaluate and propose, as appropriate, the role for CCS in cement decarbonization (SB 596) and as part of hydrogen production pathways (SB 1075).
• Support carbon management infrastructure projects through core CEC research, development, and demonstration (RD&D) programs. • Continue to explore carbon capture applications for producing or leveraging zero-carbon power for reliability needs as part of SB 100. • Consider carbon capture infrastructure when developing hydrogen roadmaps and strategy, especially for non-electrolysis hydrogen production.
• Evaluate and streamline permitting barriers to project implementation while protecting public health and the environment.
• Explore options for how local air quality benefits can be achieved when CCS is deployed.
• Explore opportunities for CCS and CDR developers to leverage existing infrastructure, including subsurface infrastructure. • Explore permitting options to allow for scaling the number of sources at carbon sequestration hubs.

State agencies and local
agencies
Would Not Conflict. The deployment of CDR to counterbalance hard-to-abate residual emissions is unavoidable if net zero CO2 or GHG emissions are to be achieved. Modeling shows that emissions from the AB 32 GHG Inventory sources will continue to persist even if all fossil related combustion emissions are phased out. These residual emissions must be compensated for to achieve carbon neutrality wither with CDR, which includes both sequestration in natural and working lands and mechanical approaches like direct air capture, CCS, which is carbon capture from anthropogenic point sources involves capturing carbon from a smokestack of an emitting facility, or direct air capture, which captures carbon directly from the atmosphere.

While these actions and strategies apply to state and local agencies, the General Plan Update is a policy document that guides land use development that would not conflict with measures to increase carbon dioxide removal and capture.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-61 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Short-Lived Climate Pollutants (Non-Combustion Gases) Dairy and Livestock Methane Sector • Install state of the art anaerobic digesters that maximize air and water quality protection, maximize biomethane capture, and direct biomethane to sectors that are hard to decarbonize or as a feedstock for energy.
• Increase alternative manure management projects, including but not limited to conversion to “solid,” “dry,” or “scrape” manure management; installation of a compost-bedded pack barn; an increase in the time animals spend on pasture; and implementation of solid-liquid separation technology into flush manure management systems. • Implement enteric fermentation strategies that are cost-effective, scientifically proven, safe for animal and human health, and acceptable to consumers, and that do not impact animal productivity.

Provide financial incentives for these strategies as needed. • Accelerate demand for dairy and livestock product substitutes such as plant-based or cell-cultured dairy and livestock products to achieve reductions in animal populations.
• In consideration of pace of deployment of methane mitigation strategies and the scale of complimentary incentives, consider regulation development to ensure that the 2030 target is achieved, assuming the conditions outlined in SB 1383 are met.

State agencies and local
agencies
Would Not Conflict. Short-Lived Climate Pollutants (SLCPs) include black carbon, methane, and fluorinated gases. HFCs are the fastest growing source of GHG emissions, primarily driven by their use to replace ozone-depleting substances and an increased demand for cooling and refrigeration. Dairy and livestock are the largest sources of methane emissions followed by landfills.

The General Plan Update would not conflict with SLCP dairy and livestock methane sector actions in the 2022 Scoping Plan. There are no dairy or livestock uses within the Planning Area. The General Plan Update, as a policy document that guides future land use development, does not include future dairy or livestock uses.

Short-Lived Climate Pollutants (Non-Combustion Gases) Landfill Methane Sector • Maximize existing infrastructure and expand it to reduce landfill disposal, with strategies including composting, anaerobic digestion, co-digestion at wastewater treatment plants, and other non- combustion conversion technologies.
• Expand markets for products made from organic waste, including through recognition of the co-benefits of compost, biochar, and other products.
• Recover edible food to combat food insecurity.
• Invest in the infrastructure needed to support growth in organic recycling capacity.
• Utilize existing digesters at wastewater treatment facilities to rapidly expand food waste digestion capacity.
• Direct biomethane captured from landfills and organic waste digesters to sectors that are hard to decarbonize.
• Implement improved technologies and best management practices at composting and digestion operations.
• Reduce emissions from landfills through improvements in operational practices, lower permeability covers, advanced collection systems, and technologies to utilize landfill gas.

State agencies and local
agencies
Would Not Conflict. SB 1383 has a 75 percent organic waste disposal reduction target below the 2013 baseline by 2030. The state did not achieve the 50 percent reduction in organic waste disposal below 2014 levels by 2020.

The CPUC approved a decision in February 2022 implementing the biomethane procurement program, which will require investor-owned utilities by 2025 to procure 17.6 billion cubic feet (BCF) of biomethane produced from organic wastes to support the landfill disposal reduction and SLCP target and reduce fossil gas reliance for residential and commercial customers. Organic waste will also be reduced by measures to remove edible food from the waste stream. Emissions can also be reduced by improvements in operational practices at landfills including lower permeability covers, advanced landfill gas collection systems, and increased monitoring to detect and repair leaks.

The General Plan Update would not conflict with SLCP landfill methane sector actions in the 2022 Scoping Plan.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-62 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis • Leverage advances in remote sensing capabilities to quickly pinpoint large methane sources and mitigate leaks, improve understanding of the factors that lead to better capture efficiency, and explore new technologies and practices that can reliably improve methane control at landfills.

Short-Lived Climate Pollutants (Non-Combustion Gases) Upstream Oil and Gas Methane Sector • Mitigate emissions from leaks by regular leak detection and repair (LDAR) surveys at all facilities.
• Replace high emitting equipment with zero emission alternatives wherever feasible.
• Have CARB and CalGEM lead a Task Force to identify and address methane leaks from oil infrastructure near communities. • Pursuant to SB 1137, develop leak detection and repair plans for facilities in health protection zones, implement emission detection system standards, and provide public access to emissions data. • Minimize emissions from equipment that must vent fossil gas by design (e.g., fossil gas powered compressors).
• Install vapor collection systems on high emitting equipment. • Phase out venting and routine flaring of associated gas (gas produced as a by-product during oil production).
• Continuous ambient monitoring at fossil gas underground storage facilities to quickly detect large methane sources.
• Reduce pipeline and compressor blowdown emissions.
• Leverage advances in remote sensing capabilities to quickly pinpoint large methane sources and mitigate leaks.

State agencies and local
agencies
Would Not Conflict. California is currently on track to achieve a 41 percent reduction in methane emission from oil and gas production by 2025 relative to 2013. To meet the 2030 target, regulatory requirements to further reduce intentional venting of fossil gas from equipment are needed.

While these actions and strategies apply to state and local agencies, the General Plan Update would not conflict with SLCP upstream oil and gas methane sector actions in the 2022 Scoping Plan.

Short-Lived Climate Pollutants (Non-Combustion Gases) Hydrofluorocarbons Sector • Expand the use of very low- or no -GWP technologies in all HFC end- use sectors, including emerging sectors, like heat pumps for applications other than space conditioning, to maximize the benefits of building decarbonization.
• Convert large HFC emitters such as existing refrigeration systems to the lowest practical GWP technologies.
• Prioritize small-scale and independent grocers serving priority populations in addressing existing “banks” of high-GWP refrigerants. • Improve recovery, reclamation, and reuse of refrigerants by limiting sales of new or virgin high-GWP refrigerants and requiring the use of reclaimed refrigerants where appropriate.

State agencies and local
agencies
Would Not Conflict. New targeted measures are needed to reduce HFCs, primarily from high-GWP refrigerants, to meet 2045 requirements. The adoption of low-GWP refrigerants must occur in parallel with building decarbonization efforts to maximize reductions. The sales prohibitions on newly produced refrigerants set forth in SB 1206 and the national/international HFC phasedown will help in reducing HFC emissions from existing equipment by restricting the supply of and increasing the value of existing high-GWP HFCs.

While these actions and strategies apply to state and local agencies, the General Plan Update would not conflict with SLCP hydrofluorocarbons sector actions in the 2022 Scoping Plan. These regulations would be applicable to future development facilitated by the General Plan Update to the extent that new development would use these regulated compounds in accordance with regulations. Any such future development would be required to comply with applicable regulations from this CARB Short-Lived Climate Pollutants reduction

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-63 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis • Assist low-income and disadvantaged communities in obtaining low- GWP space conditioning units to protect vulnerable communities from heat stress and wildfire smoke.
• Accelerate technology transitions in California and the U.S. overall by collaborating with international partners committed to taking action on HFCs under the Kigali Amendment to the Montreal Protocol; this includes addressing barriers to adoption of very low- or no-GWP refrigerant technologies such as high upfront costs, shortage of trained technicians, and lag in updating safety standards and building codes.
strategy, with respect to adopted limits on the use of regulated compounds for refrigeration uses. Therefore, the General Plan Update would not conflict with this strategy.

Short-Lived Climate Pollutants (Non-Combustion Gases) Anthropogenic Black Carbon Sector • Reduce fuel combustion commensurate with state’s climate and air quality programs, particularly from reductions in transportation emissions and agricultural equipment emissions.
• Invest in residential woodsmoke reduction.

State agencies and local
agencies
Would Not Conflict. Under current strategies, anthropogenic black carbon from transportation is expected to be reduced by over 60 percent in 2030.

Continued reductions in combustion emissions across all sectors from both the state’s climate and air quality programs will also reduce anthropogenic black carbon emissions.

While these actions and strategies apply to state and local agencies, the General Plan Update would not conflict with SLCP anthropogenic black carbon sector actions in the 2022 Scoping Plan. As discussed above, the location, design, and land uses of future growth facilitated by the General Plan Update would implement land use and transportation strategies related to reducing vehicle trips for residents and employees of the City by locating and increasing intensities of future mixed-use, commercial, and residential developments around major transit areas, which also results in a reduction of fuel combustion.

Natural and Working Lands: Strategies for all NWL
• Implement AB 1757 and SB 27.
• Implement the Climate Smart Strategy.
• Accelerate the pace and scale of climate smart action, consistent with the management levels identified above, as part of a collective effort between federal, state, private, nonprofit, and individual land managers.
• Prioritize and practice equity, including through meaningful community engagement and prioritizing implementation of nature- based solutions that benefit the communities most vulnerable to climate change.
• Advance multi-benefit, collaborative, landscape-level approaches that engage communities and landowners, and incorporate adaptive managements.
• Consult and partner with California Native American tribes to increase co-management and tribal management authority; restore, protect, and enhance natural cultural resources, traditional foods, and cultural landscapes; respect tribal sovereignty; and support tribes’ State agencies and local
agencies
Would Not Conflict. AB 1757 calls for the development of an ambitious range of targets for the NWL sector to be integrated into the Scoping Plan and other state policies. SB 27 directed CARB to establish CO2 removal targets for 2030 and beyond. In response to EO N-82-20 and AB 1757, the proposed target for NWL for 2045 is a -4 percent change in total carbon stock from 2014.

While these actions and strategies apply to state and local agencies, there are no Natural and Working Lands in the City. Thus, this strategy is not directly related to future development facilitated by the General Plan Update and the Project would not interfere, impede, or conflict with NWL strategies for all NWL actions under the 2022 Scoping Plan.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-64 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis implementation of tribal expertise and Traditional Ecological Knowledge and cultural easements.
• Leverage existing innovative financial and market mechanisms, and explore new ones, between the public, private, and philanthropic sectors to secure funding of climate smart land management. • In partnership with communities, tribes, and the private sector, expand and develop new infrastructure for manufacturing and processing of climate smart agricultural and biomass products. • Leverage and support technical assistance providers: such as the UC Cooperative Extension and California’s 98 Resource Conservation Districts, that have track records of providing technical assistance to local landowners and implementing agriculture, forestry, natural resource management, and restoration projects across the state. • Establish and expand mechanisms that ensure NWL are protected from land conversion and parcelization (e.g., conservation easements or Williamson Act), in line with the strategies outlined in CNRA’s Pathways to 30x30 California. Pair land conservation projects with management plans that increase carbon sequestration, where feasible.
• Increase opportunities for private and philanthropic investments in nature-based climate solutions, utilizing existing voluntary and compliance carbon markets, existing state and local programs, and the California Carbon Sequestration and Climate Resiliency Project Registry established pursuant to SB 27.
• Expand monitoring and tracking of management actions and outcomes consistent with the tracking and monitoring
recommendations of the Climate Smart Strategy
Natural and Working Lands: Forest Shrublands and Chaparral • Accelerate the pace and scale of climate smart forest management to at least 2.3 million acres annually by 2025, in line with the climate smart management strategies identified in this Scoping Plan, the NWL Climate Smart Strategy, and the Wildfire and Forest Resilience Action Plan.
• Establish and expand mechanisms that ensure forests, shrublands, and grasslands are protected from land conversion and that support ongoing, rather than one-time, management actions.
• In collaboration with state and local agencies, accelerate the deployment of long-term carbon storage from waste woody biomass residues resulting from climate smart management, including storage in durable wood products, underground reservoirs, soil amendments, and other mediums.
• Expand infrastructure to facilitate processing of biomass resulting from climate smart management.

State agencies and local
agencies
Would Not Conflict. California is covered by 27 percent forests and 31 percent shrublands and chaparral. Climate smart management can help make forests more resilient to climate change and less prone to catastrophic wildfire.

Climate-smart management in shrublands and chaparral face can provide protection for threatened communities and natural resources.

While these actions and strategies apply to state and local agencies, there are some natural and working forest shrublands and chaparral lands within portions of the IOF and Kenneth Hahn State Recreational Area within the City limits and Sphere of Influence (SOI) (refer to Section 4.3, Biological Resources, for discussions of the vegetation communities within portions of the IOF and Kenneth Hahn State Recreational Area). The City is focused on the protection and enhancement of the biological resources within the City’s portion of the IOF as part of ongoing maintenance and use, with a long-term vision for decommissioning and a change in use. In October 2021, the City adopted an Oil Termination Ordinance (Zoning code amendment P2021-0036-ZCA) intended to implement an amortization program that would terminate and

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-65 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis • Expand permit streamlining in collaboration with state and local agencies to accelerate implementation of climate smart forest management while protecting natural resources.
phase out nonconforming oil and gas activities within the City’s portion of the IOF. The adopted Oil Termination Ordinance included a requirement for the remediation, restoration and revegetation of the areas of the Oil Use Premises affected by the plugging and removal activities to as near a natural state as practicable, free from all oil, rotary mud, oil-soaked earth, asphalt, concrete, litter, debris and other substances associated with oil operations. The General Plan Update also includes Goal C-2, Biological Resources, and specifically Policy C.2-6, which requires standards and guidelines to protect plant and wildlife species from new development, including in the IOF, Kenneth Hahn State Recreational Area and other open space areas. Thus, the Project would not interfere, impede, or conflict with strategies on any NWL where forests, shrublands, and chaparral occur under the 2022 Scoping Plan.

Natural and Working Lands: Grasslands
• Establish and expand mechanisms that ensure grasslands are protected from land conversion/parcelization and that support ongoing, rather than one-time, management actions that improve carbon sequestration.
• Deploy grassland management strategies, like prescribed grazing, compost application, and other regenerative practices, to support soil carbon sequestration, biodiversity, and other ecological improvements.
• Increase adoption of compost production on farms and application of compost in appropriate grassland settings for improved vegetation and carbon storage, and to deliver waste diversion goals through nature-based solutions.

State agencies and local
agencies
Would Not Conflict. California is covered by 9 percent grasslands. The protection of grasslands provides an opportunity to reduce sprawl and complement VMT reduction strategies. Climate smart strategies can increase grassland resilience to climate change by improving species diversity and maintaining or increasing soil carbon stocks.

While these actions and strategies apply to state and local agencies, there are some natural and working grasslands within portions of the IOF and Kenneth Hahn State Recreational Area within the City limits and SOI (refer to Section

4.3, Biological Resources, for discussions of the vegetation communities within portions of the IOF and Kenneth Hahn State Recreational Area). The City is focused on the protection and enhancement of the biological resources within the City’s portion of the IOF as part of ongoing maintenance and use, with a long-term vision for decommissioning and a change in use. The City has adopted an Oil Termination Ordinance (Zoning code amendment P2021-0036- ZCA) intended to implement an amortization program that would terminate and phase out nonconforming oil and gas activities within the City’s portion of the IOF and includes a requirement for the remediation, restoration and revegetation of the areas of the Oil Use Premises affected by the plugging and removal activities to as near a natural state as practicable, free from all oil, rotary mud, oil-soaked earth, asphalt, concrete, litter, debris and other substances associated with oil operations. the General Plan Update also includes Goal C-2, Biological Resources, and specifically Policy C.2-6, which requires standards and guidelines to protect plant and wildlife species from new development, including in the IOF, Kenneth Hahn State Recreational Area, and other open space areas. Thus, the General Plan Update and Project.

Thus, the Project would not interfere, impede, or conflict with strategies on any NWL where grasslands occur under the 2022 Scoping Plan.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-66 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Natural and Working Lands: Croplands
• Accelerate the pace and scale of healthy soils practices to 80,000 acres annually by 2025, conserve at least 8,000 acres of annual crops annually, and increase organic agriculture to 20 percent of all cultivated acres by 2045.
• Utilize the recommendations included in CDFA’s Farmer and Rancher-Led Climate Change Solutions report to accelerate deployment of healthy soils practices, organic farming, and climate smart agriculture practices.
• Establish or expand financial mechanisms that support ongoing deployment of healthy soils practices and organic agriculture. • Support strategies that achieve co-benefits of safer, more sustainable pest management practices and the health and preservation of ecosystems, such as implementing the California Department of Pesticide Regulation’s (DPR’s) Sustainable Pest Management Work Group recommendations.
• Conduct research on the intersection of pesticides, soil health, GHGs, and pest resiliency via a multi-agency effort with DPR, CDFA, and CARB.
• Conduct outreach and education to develop and facilitate the increased adoption of safer, more sustainable pest management practices and tools; reduce the use of harmful pesticides; promote healthy soils; improve water and air quality; and reduce public health impacts.
• In collaboration with state and local agencies, accelerate the deployment of alternatives to agricultural burning that increase long- term carbon storage from waste agricultural biomass, including storage in durable wood products, underground reservoirs, soil amendments, and other mediums.
• Work across state agencies to reduce regulatory and permitting barriers around some healthy soils practices (e.g., composting), where appropriate.
• Utilize innovative agriculture energy use and carbon monitoring and planning tools to reduce on-farm GHG emissions from energy and fertilizer application or to increase carbon storage, as well as to promote on-farm energy production opportunities.

State agencies and local
agencies
Would Not Conflict. California is covered by 9 percent croplands. In addition to food, croplands provide considerable carbon storage in the soil and, in perennial croplands, in aboveground biomass. Climate smart practices can maintain or increase the climate resilience of cropland productivity through improved soil conditions and increased pollinator habitat.

While these actions and strategies apply to state and local agencies, there are no croplands in the City. Thus, this strategy is not directly related to future development facilitated by the Project; the Project would not interfere, impede, or conflict with strategies on any NWL where croplands occur under the 2022 Scoping Plan.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-67 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis Natural and Working Lands: Wetlands
• Restore 60,000 acres of Delta wetlands annually by 2045 to reduce methane emissions from wetlands and reverse the resulting subsidence.
• Identify and prioritize wetland restoration efforts around climate vulnerable communities.
• Leverage other funding and institutions to support wetland restoration projects, including land trusts, local funding, federal funding, and private and philanthropic funding to support wetlands restoration projects.
• Work across state agencies to reduce regulatory and permitting barriers around wetland restoration projects, where appropriate.

State agencies and local
agencies
Would Not Conflict. California is covered by 2 percent wetlands. Wetlands are hotspots for diversity, contain considerable carbon in the soil, are critical to the states’ water supply, and protect upland areas from flooding due to sea level rise and storms. Climate smart strategies to restore and protect wetlands can reduce emissions while simultaneously improving the climate resilience of surrounding areas and improving the water quality and yield for the state.

While these actions and strategies apply to state and local agencies, there are no wetlands in the City. Thus, this strategy is not directly related to future development facilitated by the General Plan Update and the Project would not interfere, impede, or conflict with strategies on any NWL where wetlands occur under the 2022 Scoping Plan.

Natural and Working Lands: Developed Lands
• Increase urban forestry investment annually by 200 percent, relative to business as usual.
• Increase public awareness of urban forest benefits and, where appropriate, prioritizing irrigation of trees over lawns. • Provide technical assistance and resources to disadvantaged communities to implement community urban greening projects to provide equitable access to the benefits of urban greening projects. • Work with state and local agencies to expand technical assistance for and enforcement of the defensible space requirements of PRC 4291 to reduce wildfire risk to homes and structures.

State agencies and local
agencies
Would Not Conflict. California is covered by 6 percent developed lands.

Developed lands include urban, suburban, and rural areas, as well as transportation and supporting infrastructure. The vegetation within cities and communities are all part of developed lands. This vegetation provides numerous benefits to surrounding areas, including carbon storage, air and water filtration, reduced urban heat island effect, and access to nature.

Climate smart strategies to protect and expand the urban forests, landscaping, green spaces, parks, and associated vegetation can increase their climate resilience and the benefits Californians derive from them. Urban forests have a significant potential to sequester carbon.

While these actions and strategies apply to state and local agencies, there are some natural and working developed lands within portions of the IOF and Kenneth Hahn State Recreational Area within the City limits and SOI, as well as various parks (refer to Section 4.3, Biological Resources, for discussions of the vegetation communities within portions of the IOF and Kenneth Hahn State Recreational Area). The City is focused on the protection and enhancement of the biological resources within the City’s portion of the IOF as part of ongoing maintenance and use, with a long-term vision for decommissioning and a change in use. The City has adopted an Oil Termination Ordinance (Zoning code amendment P2021-0036-ZCA) intended to implement an amortization program that would terminate and phase out nonconforming oil and gas activities within the City’s portion of the IOF and includes a requirement for the remediation, restoration and revegetation of the areas of the Oil Use Premises affected by the plugging and removal activities to as near a natural state as practicable, free from all oil, rotary mud, oil-soaked earth, asphalt, concrete, litter, debris and other substances associated with oil operations. The General Plan Update also includes Goal C-2, Biological Resources, and specifically Policy C.2-3, which requires management of vegetation at parks and open spaces in Culver City to support biodiversity by reducing pesticide use and reducing use of non-native species, and Policy C.2-6, which requires standards and guidelines to protect plant and wildlife species from new development,

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-68 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2022 Scoping Plan Actions and Strategies Responsible Party(ies) Consistency Analysis including in the IOF, Kenneth Hahn State Recreational Area, and other open space areas. Thus, the Project would not interfere, impede, or conflict with strategies on any NWL where developed lands occur under the 2022 Scoping Plan.

Natural and Working Lands: Vegetated Lands
• Establish and expand mechanisms that ensure sparsely vegetated lands are protected from land conversion, prioritizing those areas most vulnerable to climate change and loss.

State agencies and local
agencies
Would Not Conflict. California is covered by 10 percent sparsely vegetated lands. Vegetated lands include deserts, beaches, dunes, bare rock, and areas covered in ice and snow. Vegetated lands provide limited carbon storage, but nonetheless, are important for open space, unique habitats, and recreational opportunities.

While these actions and strategies apply to state and local agencies, the General Plan Update includes numerous goals and policies regarding protection and expansion of vegetated lands as appropriate (refer to Section

4.3, Biological Resources, for relevant goals and policies). Thus, the Project would not interfere, impede, or conflict with strategies on any NWL where vegetated lands occur under the 2022 Scoping Plan.

SOURCE: ESA 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-69 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
2020–2045 Regional Transportation Plan/Sustainable Communities Strategy The purpose of the 2020–2045 RTP/SCS is to achieve the regional per capita GHG reduction targets for the passenger vehicle and light-duty truck sector established by CARB pursuant to SB 375. SCAG’s Program EIR for the 2020–2045 RTP/SCS, certified on May 7, 2020, states that “[e]ach [metropolitan planning organization] is required to prepare an SCS as part of their RTP in order to meet these GHG emissions reduction targets by aligning transportation, land use, and housing strategies with respect to [Senate Bill] 375”.
117 The 2020–2045 RTP/SCS seeks
improved mobility and accessibility, which is defined as “the ability to reach desired destinations with relative ease and within a reasonable time, using reasonably available transportation choices”.
118 According to the 2020–2045 RTP/SCS, “[g]rowth within TPAs supports Connect SoCal’s strategies for preserving natural lands and farmlands and alleviates development pressure in sensitive resource areas by promoting compact, focused infill development in established communities with access to high-quality transportation”. 119
In order to assess the General Plan Update’s potential to conflict with the 2020–2045 RTP/SCS, this section analyzes the General Plan Update’s consistency with the strategies and policies set forth in the 2020–2045 RTP/SCS to meet GHG emission-reduction targets set by CARB.

Generally, projects are considered to not conflict with applicable City and regional land use plans and regulations, such as SCAG’s 2020–2045 RTP/SCS, if they are compatible with the general intent of the plans and would not preclude the attainment of their primary goals. The General Plan Update would not conflict with the 2020–2045 RTP/SCS goals as detailed in Table 4.7-9, Consistency with Applicable 2020–2045 SCAG RTP/SCS Actions and Strategies.

As presented in the table, the Project would not conflict with and would support the applicable goals and benefits of the 2020–2045 RTP/SCS to reduce GHG. Accordingly, the General Plan Update would encourage development in a manner that would not conflict with the 2020–2045 RTP/SCS to reduce VMT and expand multi-modal transportation options in order for the region to achieve the GHG reductions from the land use and transportation sectors required by SB 375, which, in turn, advances the State’s long-term climate policies. By furthering implementation of SB 375, the Project supports regional land use and transportation GHG reductions consistent with State regulatory requirements. As discussed in Section 4.16, Transportation, future development under the General Plan Update would result in significant and unavoidable transportation VMT impacts. Efforts to reduce VMT may include TDM strategies and the implementation of capital improvement projects that improve mobility and accessibility for active transportation and transit users. Nonetheless, while the Project would result in significant and unavoidable transportation VMT impacts, it is a separate impact determination and substantial evidence discussed above demonstrates the Project would not conflict with the 2020–2045 RTP/SCS for the purposes of GHG emissions.

117 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.
118 Southern California Association of Governments, 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October.
119 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
General Plan 2045 and Zoning Code Update Project 4.7-70 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.7-9
CONSISTENCY WITH APPLICABLE 2020–2045 SCAG RTP/SCS ACTIONS AND STRATEGIES Actions and Strategies Responsible Party(ies) Compliance/Consistency Analysis Focus on a regional jobs/housing balance to reduce commute times and distances and expand job opportunities near transit and along center-focused main streets
Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy.

The location, design, and land uses of future development facilitated by the General Plan Update would implement land use and transportation strategies related to reducing vehicle trips for residents and employees of the City by increasing future mixed-use, and residential density and locating mixed-use, commercial, and residential developments around major transit areas. Several transit agencies provide local and regional transit service within 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 in Section 4.16, Transportation, of this Draft PEIR, for a summary of transit service in Culver City.

The proposed General Plan Update focuses on thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The 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 would 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 transit-oriented communities (TOC), the land use plan for the City promotes the retention and expansion of creative economy businesses and other emerging technologies in these industrial mixed-use areas and mixed-use corridors; supports the needs of neighborhood-serving retail by encouraging commercial and experiential opportunities, particularly in the Downtown area; and advances strategies that ensure a safe and effective phase out of the 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. Therefore, the General Plan Update would not conflict with the VMT reduction strategies of the RTP/SCS and the General Plan Update would not conflict with applicable RTP/SCS actions and strategies to reduce GHG emissions.

Prioritize infill and redevelopment of underutilized land to accommodate new growth, increase amenities and
connectivity in existing neighborhoods
Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy.

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. The City is primarily built out and future development would constitute infill and would likely consist of redevelopment of properties. The General Plan Update would distribute growth along corridors, including in areas well served by transit, thereby incrementally adding housing in existing residential areas, providing access to opportunities, such as jobs, neighborhood amenities, and health care facilities.

In addition to incremental infill and TOCs, 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

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-71 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Actions and Strategies Responsible Party(ies) Compliance/Consistency Analysis needs of neighborhood-serving retail by encouraging commercial and experiential opportunities, particularly in the Downtown area; and advances strategies that ensure a safe and effective phase out of the Inglewood Oil Field (IOF). The 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. Therefore, the General Plan Update would prioritize infill and redevelopment of underutilized parcels to accommodate growth and based on the proposed land use map and goals and policies in the Mobility Element, amenities and connectivity would be increased.

Encourage design and transportation options that reduce the reliance on and number of solo car trips (this could include mixed uses or locating and orienting close to existing
destinations)
Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy.

As discussed above, the location, design, and land uses of future development facilitated by the General Plan Update would implement land use and transportation strategies related to reducing vehicle trips for residents and employees of the City by distributing growth along corridors, including in areas well served by transit. In addition, the General Plan Update contains policies to reduce VMT such as prioritizing multimodal projects and integrated public transportation services, providing a cohesive active travel network, providing high-quality transit services, reducing first/last mile barriers, providing secure and covered bicycle parking at key destinations, providing equitable transit access, and providing accessible pedestrian facilities. See Section 4.16, Transportation, of this Draft PEIR for further discussion.

Promote low emission technologies such as neighborhood
electric vehicles, shared rides hailing, car sharing, bike sharing and scooters by providing supportive and safe infrastructure such as dedicated lanes, charging and parking/drop-off space Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy and would support these actions through the implementation of General Plan Update strategies for electric vehicle-ready and electric vehicle-capable infrastructure and parking spaces. The General Plan Update targets growth in major transit areas and higher densities, especially in mixed-use designations, would increase capacity for residential development near community-serving commercial, retail, and office uses as well as schools, parks, and recreational facilities. Proposed Improvements to the bicycle, pedestrian, and road networks identified in the proposed Mobility Element would make it easier for residents to travel throughout the community.

The policies recommended in the Mobility Element
supports transportation of people and
goods by various means, including automobile, transit, bicycle, pedestrian, and other emerging mode choices. Components of the network are designed, implemented, and operated according to functions aligning with the travel markets they are intended to serve, as well as the access needs of the surrounding communities along corridors. In addition to prioritizing traffic calming and other active transportation-focused projects at key intersections, the Mobility Element pedestrian network recommends improved connections to schools and increases opportunities for crossing Ballona Creek. The Mobility Element prioritizes Class II and Class IV facilities along major thoroughfares which would connect to Class II and Class III bikeways. The emerging mobility network in the Mobility Element includes dozens of mobility hubs located near corridors with supportive bicycle and pedestrian infrastructure, such as Ballona Creek, designated Transit Priority Corridors that support high-frequency transit service, and major activity centers such as schools, parks, commercial areas, and major employment centers.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-72 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Actions and Strategies Responsible Party(ies) Compliance/Consistency Analysis Identify ways to incorporate “micro-power grids” in
communities, for example solar energy, hydrogen fuel cell power storage and power generation
Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy.

The operation of future development facilitated by the General Plan Update would be designed in a manner that is consistent with relevant energy conservation plans designed to encourage development that results in the efficient use of energy resources.

Future 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, and implementing solar-ready rooftops.

Support local policies for renewable energy production, reduction of urban heat islands and carbon sequestration Local Jurisdictions, SCAG No Conflict. The General Plan Update would not conflict with this action and strategy.

Identify ways to improve access to public park space Local Jurisdictions No Conflict. The General Plan Update would not conflict with this action and strategy.

The General Plan Update would improve connectivity and land use compatibility within and between existing neighborhoods, thereby providing more linkages within the City and the region. The General Plan Update would provide for higher densities, especially in mixed-use and residential designations, and increased capacity for residential and mixed-use development near community-serving commercial, retail, and office uses as well as schools, parks, and recreational facilities. Identified improvements to the bicycle, pedestrian, and road networks would make it easier for residents to travel throughout the
community.

Transportation Demand Management (TDM) Strategic Plan
provide an objectives-driven, performance-based process to identify and promote TDM strategies and programs across the region. SCAG will pursue implementation of these strategies in coordination with regional and local partners.

Local Jurisdictions No Conflict. The General Plan Update would not conflict with this action and strategy and would include goals and policies that support TDM strategies, such as General Plan Update policies in the Mobility Element (refer to Section 4.16, Transportation, of this Draft PEIR, for a list of the proposed policies).

SOURCE: ESA, 2024.

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-73 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Culver City’s Green Building Program
As discussed in Chapter 2, Project Description, of the Draft PEIR, the General Plan Update includes a Greenhouse Gas Reduction Element, which includes goals and policies that address sustainability including greenhouse gas emissions, landfill disposal, water efficiency, and transportation. Future development projects under the General Plan Update would be required to comply with the goals and policies in the Greenhouse Gas Reduction Element and with the Culver City Green Building Program and ordinances and would achieve improved building energy efficiency, energy conservation, water conservation, TDM and mobility measures, and pedestrian- and bicycle-friendly site design. EV parking and charging spaces, as well as bicycle spaces would be required as per 2022 CALGreen Code Requirements. Therefore, the Project would not result in future development projects that would conflict with Culver City’s Green Building Program.

GHG Reduction Plans, Policies and Regulations
In summary, based on the analysis above, the General Plan Update, which would guide City development through 2045, would not conflict with plans, policies and regulations for reducing GHG emissions 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 GHG emissions control strategies and regulations as discussed above. Since the Zoning Code Update would be consistent with the General Plan Update, development that would occur under the Zoning Code Update would not conflict with applicable plans, policies and regulations for reducing GHG emissions and this impact would be less than significant.

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

Mitigation Measures
No mitigation measures are required.

Level of Significance After Mitigation
Not applicable. The Project would result in less than significant impacts related to conflicts with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.

4.7.5 Cumulative Impacts Analysis
Analysis of GHG emissions is cumulative in nature because impacts are caused by cumulative global emissions and additionally, climate change impacts related to GHG emissions do not necessarily occur in the same area as a project is located. The emission of GHGs by a single development project into the atmosphere is not itself necessarily an adverse environmental effect. Rather, it is the increased accumulation of GHGs from more than one project and many sources in the atmosphere that may result in global climate change. The resultant consequences

4. Environmental Impact Analysis

4.7. Greenhouse Gas Emissions
General Plan 2045 and Zoning Code Update Project 4.7-74 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
of climate change can cause adverse environmental effects. A project’s GHG emissions typically would be very small in comparison to state or global GHG emissions and, consequently, they would, in isolation, have no significant direct impact on climate change.

The state has mandated a GHG emissions target of reducing statewide emissions to 40 percent below 1990 levels by 2030, and 80 percent below 1990 levels by 2050 even while statewide population and commerce are predicted to continue to expand. In order to achieve this goal, CARB has established and is implementing regulations to reduce statewide GHG emissions.

Currently, there are no adopted CARB, SCAQMD, or City significance thresholds or specific numeric reduction targets applicable to the Project, and no approved policy or guidance to assist in determining significance at the cumulative level. Additionally, there is currently no generally accepted methodology to determine whether GHG emissions associated with a specific project represent new emissions or existing, displaced emissions. Therefore, consistent with CEQA Guidelines Section 15064h(3),
120 the City, as lead agency, has determined that the
Project’s contribution to cumulative GHG emissions and global climate change would be less than significant if the Project is consistent with the applicable regulatory plans and policies to reduce GHG emissions: 2022 Scoping Plan, SCAG’s 2020–2045 RTP/SCS, and Energy Action Plan.

Discretionary projects in other jurisdictions in California would also be required to evaluate project-level and cumulative impacts for GHG emissions, as applicable. Given that the Project would not conflict with applicable GHG reduction plans, policies, and regulations, emissions associated with future development that could occur under the proposed General Plan update would be less than significant on a cumulative basis.

120 As indicated above, the CEQA Guidelines were amended in response to SB 97. In particular, the CEQA Guidelines were amended to specify that compliance with a GHG emissions reduction program renders a cumulative impact insignificant. Per CEQA Guidelines Section 15064(h)(3), a proposed project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if a proposed project will comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of a project. 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. 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.”

4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.8-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.8 Hazards and Hazardous Materials

4.8.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on hazards and hazardous materials from implementation of the Project, including potential impacts related to routine use, transportation, or disposal of hazardous materials; accident or upset conditions involving the release of hazardous materials; emitting hazardous emissions or handling hazardous materials near schools; hazardous materials sites; impairing or interfering with emergency response plans; and wildland fire hazards. The section provides context regarding the Planning Area’s existing hazardous materials sites and emergency response process, as well as relevant federal, State, and local regulations and programs.

Additional analyses regarding hazards and health risk related to emissions of toxic air contaminants (TACs) are addressed in Section 4.2, Air Quality. Other geotechnical-related safety hazards, such as earthquakes, are addressed in Section 4.6, Geology and Soils. Flooding and inundation hazards, including those related to erosion and mudflow, are addressed in Section

4.9, Hydrology and Water Quality. Transportation-related safety hazards are addressed in Section 4.16, Transportation. Lastly, potential hazards to humans and structures from natural or human induced wildland fires are addressed in Section 4.19, Wildfire.

4.8.2 Environmental Setting
Hazardous Materials and Hazardous Waste
Materials and waste may be considered hazardous if they are poisonous (toxicity), can be ignited by open flame (ignitability), corrode other materials (corrosivity), or react violently, explode, or generate vapors when mixed with water (reactivity). Definitions of terms used in the characterization of baseline conditions, regulatory framework, and impact analysis for hazards and hazardous materials are provided below.
• Hazardous Material: The term “hazardous material” can have varying definitions depending on the regulatory programs. For the purposes of this Draft PEIR, the term refers to both hazardous materials and hazardous wastes. The California Health and Safety Code (HSC) Section 25501(p) defines hazardous material as any material that because of its quantity, concentrations, or physical or chemical characteristics, poses a significant present or potential hazard to human health and safety or to the environment if released into the workplace or the environment. Hazardous materials include, but are not limited to, hazardous substances, hazardous waste, and any material which a handler or the administering agency has a reasonable basis for believing would be injurious to the health and safety of persons or harmful to the environment if released into the workplace or the environment.
• Hazardous Waste: A “hazardous waste” is a waste that because of its quantity, concentration, or physical, chemical, or infectious characteristic, causes or significantly contributes to an increase in mortality or illness or poses substantial or potential threats to public health or the environment (42 U.S.C. 6903[5]). Hazardous wastes are further defined under the Resource Conservation and Recovery Act (RCRA) as substances exhibiting the

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characteristics of ignitability, reactivity, corrosivity, or toxicity. Chemical-specific concentrations used to define whether a material is a hazardous, designated, or nonhazardous waste include Total Threshold Limit Concentrations (TTLCs), Soluble Threshold Limit Concentrations (STLCs), and Toxic Characteristic Leaching Procedure (TCLPs), listed in California Code of Regulations (CCR) CCR Title 22, Chapter 11, Article 3, Section 66261, and used as waste acceptance criteria for landfills. Waste materials with chemical concentrations above TTLCs, STLCs, and TCLPs must be sent to Class I disposal facilities, may be sent to Class II disposal facilities depending on the waste material, and may not be sent to Class III disposal facilities.
• Screening Levels for Hazardous Materials in Soil, Soil Gas, or Groundwater: The United States Environmental Protection Agency (USEPA) Regional Screening Levels (RSLs) and San Francisco Bay Area Regional Water Quality Control Board (RWQCB) Environmental Screening Levels (ESLs) are guidelines used to evaluate the potential risk associated with chemicals found in soil or groundwater where a release of hazardous materials has occurred. Although developed and maintained by the San Francisco Bay Area RWQCB, ESLs are used by regulatory agencies throughout the state.
1 Screening levels have been
established for both residential and commercial/industrial land uses, and for construction workers. Residential screening levels are the most restrictive; soil with chemical concentrations below these levels generally would not require remediation and would be suitable for unrestricted uses if disposed of offsite. Commercial/industrial screening levels are generally less restrictive than residential screening levels because they are based on potential worker exposure to hazardous materials in the soil (and these are generally less than residential exposures). Screening levels for construction workers are also less restrictive than for commercial/industrial workers because construction workers are only exposed to the chemical of concern during the duration of construction, while industrial workers are assumed to be exposed over a working lifetime. Chemical concentrations below these screening levels generally would not require remediation and would be suitable for unrestricted uses. In addition, there are other more specific but similar screening levels used more narrowly focused human health or ecological risk assessment considerations.

Regulation of hazardous wastes is undertaken on the federal, State, and local levels. The USEPA and the California Department of Toxics Substances Control (DTSC) have developed and continue to update lists of hazardous wastes subject to regulation. The South Coast Air Quality Management District (SCAQMD), in coordination with the California Air Resources Board (CARB), is responsible for developing and implementing rules and regulations regarding air toxins on a local level. SCAQMD establishes permitting requirements, inspects emissions sources, and enforces measures through educational programs and/or fines.

Potential Receptors/Exposure
The sensitivity of potential receptors in the areas of known or potentially hazardous materials contamination is dependent on several factors. The primary factor is an individual’s potential pathway for exposure. Exposure pathways include external exposure, inhalation, and ingestion of tainted air, water, or food. The magnitude, frequency, and duration of human exposure can

1 The San Francisco Bay Area RWQCB develops ESLs for the use of all California RWQCBs.

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cause a variety of health effects ranging from short term acute symptoms to long term chronic effects. Potential health effects from exposure can be evaluated in a health risk assessment. The principle elements of exposure assessments typically include:
• Evaluation of the fate and transport processes for hazardous materials at a given site; • Identification of potential exposure pathways;
• Identification of potential exposure scenarios;
• Calculation of representative chemical concentrations; and • Estimation of potential chemical update.

Hazardous Building Materials
Many buildings and structures can be of an age where the potential exists for the presence of hazardous building materials. Older buildings can contain building materials that consist of hazardous components such as lead-based paint (LBP), asbestos, mercury, and polychlorinated biphenyls (PCBs). When these buildings or structures are demolished for renovation or new development, these hazardous building materials can become exposed.

Before the USEPA ban in 1978, LBP was commonly used on interior and exterior surfaces of buildings. Old peeling paint has been found to contaminate near-surface soil, and exposure to residual lead has resulted in illness in children.

Asbestos is a naturally occurring fibrous material that was extensively used as a fireproofing and insulating agent in building construction before such uses were banned by the USEPA in the 1970s. Asbestos can lead to lung disease by inhaling its tiny fibers.

Spent fluorescent light tubes commonly contain mercury vapors. In February 2004, regulations took effect in California classified all fluorescent lamps and tubes as a hazardous waste. When these lamps or tubes are broken, mercury is released to the environment. Mercury can be absorbed through the lungs into the bloodstream and can be washed by rainwater into waterways.

PCBs are organic oils that were formerly used primarily as insulators in many types of electrical equipment, including transformers and capacitors. After PCBs were determined to be a carcinogen in the mid to late1970’s, USEPA banned PCB use in most new equipment and began a program to phase out certain existing PCB containing equipment. Fluorescent lighting ballasts manufactured after January 1, 1978, do not have PCBs and are required to have a label clearly stating that PCBs are not present in the unit.

Hazardous Materials Storage and Transportation
Releases, leaks, or disposal of chemical compounds, such as petroleum hydrocarbons, on or below the ground surface, can lead to contamination of underlying soil and groundwater and into the bay. Disturbance of a previously contaminated area through grading or excavation operations could expose the public to health hazards from physical contact with contaminated

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General Plan 2045 and Zoning Code Update Project 4.8-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
materials or hazardous vapors. Improper handling or storage of contaminated soil and groundwater can further expose the public to these hazards, or potentially spread contamination through surface water runoff or airborne dust. In addition, contaminated groundwater can spread down gradient, potentially contaminating subsurface areas of surrounding properties.

Areas where historical or ongoing activities have resulted in the known or suspected release of hazardous materials to soil and groundwater, and where current investigation and clean-up activities are located, are monitored by DTSC or the State Water Resources Control Board (SWRCB). According to DTSC’s Envirostor database, there are eight sites listed in the Planning Area of which two are active cleanup sites, three are certified and require no further action, two are inactive, and one has been referred to another agency. 2 The Geotracker database
maintained by the SWRCB, identified a total of 114 sites for the Planning Area.3 However, 97 of those listings have been closed and require no further action, three are inactive, and two are eligible for closure. The remaining 12 sites are actively being remediated, assessed, or in a verification monitoring program (see Figure 4.8-1, Hazard Sites within the Planning Area).

Various hazardous materials are commonly transported, stored, used, and disposed of in activities such as construction, industry (both light and heavy), dry cleaning, film processing, landscaping, automotive maintenance and repair, and common residential/commercial maintenance activities. The use, transport, storage, and disposal of hazardous materials is regulated by USEPA, California EPA (Cal/EPA) including the six boards, departments, and offices:

Air Resources Board, Department of Pesticide Regulation, DTSC, Office of Environmental Health Hazard Assessment (OEHHA), and SWRCB. Also, the Department of Public Health Center for Environmental Health and other local regulatory agencies closely monitor businesses and industry in the control of hazardous materials. In addition, businesses that handle more than a certain amount of hazardous materials are required to report their inventories to the California Environmental Reporting System (CERS).

Hazardous materials require special methods of disposal, storage, and treatment, and any unintentional release of hazardous materials requires an immediate response to protect human health and safety, and the environment. Improper disposal can harm the environment, nearby people and workers exposed to the waste, and people who work in the waste management industry. Transportation of hazardous materials by truck and rail is regulated by the United States Department of Transportation (USDOT). USDOT regulations establish criteria for safe handling procedures. Federal safety standards are included in the California Administrative Code. In addition, the California Health Services Department regulates the haulers of hazardous waste.

2 California Department of Toxics Substances Control, 2023. EnviroStor Online Database. https://www.envirostor.dtsc.ca.gov/public/. Accessed May 2023. 3 State Water Resources Control Board, 2023. GeoTracker Online Database. https://geotracker.waterboards.ca.gov/. Accessed May 2023.

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); DTSC (2023); SWRCB (2023).

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
GF EnviroStor Site (DTSC)
GF Geotracker (SWRCB)
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); DTSC (2023); SWRCB (2023).

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
GF EnviroStor Site (DTSC)
GF Geotracker (SWRCB)
Culver City General Plan 2045
Figure 4.8-1
Hazard Sites within the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021; DTSC, 2023; SWRCB, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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General Plan 2045 and Zoning Code Update Project 4.8-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Inglewood Oil Field
The Inglewood Oil Field (IOF), which is one of the largest urban oil fields in the nation and has been in continuous operation since 1924, is located within Culver City and the unincorporated area of Los Angeles County known as Baldwin Hills. The IOF is approximately 1,000 acres in size with roughly 78 acres located in the city. The first oil-producing well was drilled in the IOF in 1924, and by 1925 over 50,000 barrels of oil were produced per day.4 By the early 2000s, as many as 368 million barrels of oil and 269 billion cubic feet of natural gas (mostly methane) were being produced. Over IOF’s history, 1,600 wells have been drilled within the historical boundaries of the IOF.
5 As of 2022, the IOF has more than 400 active producing wells, producing an average of 4,700 barrels of oil and 2.6 million cubic feet of natural gas gross daily. 6 Numerous laws have been enacted to regulate hazardous materials and waste, including regulations specific to the oil and gas industry. California has the most stringent regulations and oversight of oil and gas operations in the country, with the primary oversight agency being California Geologic Energy Management Division (CalGEM). The Culver City Fire Department (CCFD) can respond to hazardous materials emergencies at the IOF at the First Responder Operations (FRO) level and has prompt access to specialized hazardous materials resources via the California Master Mutual Aid plan.

Following a series of accidental gas release and odor events in late 2005 and early 2006, community, County, and City interest in the IOF activities peaked. Subsequently, the County initiated a process to regulate oil and gas production activities within the unincorporated County portion of the IOF. In 2008, the Los Angeles County Board of Supervisors adopted the Baldwin Hills Community Standards District (BHCSD), which established the oil and gas regulations for operation of the majority area of the IOF, within the unincorporated County just easterly of and adjacent to Culver City. The BHCSD includes requirements for monitoring and managing potential concerns related to the release of hazardous materials.

Independent of the County’s BHCSD regulatory program, in 2017, Culver City Council initiated preparation of an amortization
7 study to evaluate and financially and factually support ending oil and gas extraction activities within the Culver City portion of the IOF. As a result of the information learned through the completed amortization study, in concert with other community safety considerations, in October 2021, the City Council adopted an Oil Termination Ordinance to implement an amortization program that would terminate and phase out what

4 Culver City, 2017. Inglewood Oil Field Specific Plan Project Draft Environmental Impact Report. https://www.culvercity.org/files/assets/public/documents/city-manager/inglewood-oil-field/environmental- review-process/toc091117.pdf. Accessed April 2023.
5 Sentinel Peak Resources California, LLC, 2017. History of Inglewood Oil Field. https://inglewoodoilfield.com/history-future/history-inglewood-oilfield/. Accessed May 2023. 6 Sentinel Peak Resources California, LLC, 2022. The Inglewood Oil Field: 2022 Annual Newsletter and Community Announcement. https://inglewoodoilfield.com/wp-content/uploads/2022/09/2022-IOF-Annual-Newsletter.pdf.

Accessed May 2023.
7 Amortization is a common accounting concept that refers to how a capital account is allocated over time. Loans are often amortized by regularly paying principal and interest over a fixed term. Investments in capital assets are amortized for accounting and tax purposes by allocating the capital investment to specific periods over the life of the asset.

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General Plan 2045 and Zoning Code Update Project 4.8-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
are now nonconforming oil and gas activities within the Culver City portion of the IOF by November 24, 2026.

From 2013-2019, there have been two reportable releases of hazardous materials from the IOF within city boundaries, neither of which reached Ballona Creek. In 2013, an inter-facility pipeline leaked seven barrels of produced water
8 that drained onto the street and then into the storm
drain near Blackwelder Street (near the intersection of La Cienega Boulevard and Fairfax Avenue). In April 2019, there was an oil-water leak along Leash Lane near the Bone Yard dog park. The leak traveled along the curb and gutter to a storm drain inlet, was redirected from the storm drain, and the flow traveled toward, but was fully contained just short of, the intersection at Jefferson Boulevard and Duquesne Avenue.

Schools
Some populations, such as children, are more susceptible to health effects of hazardous materials than the general population. Hazardous materials used near schools and day care centers must consider potential health effects to these populations, often referred to as “sensitive receptors.” Construction or redevelopment on contaminated properties that could potentially generate vapors or fugitive dust containing contaminants may potentially pose a health risk to these populations. In addition, commercial businesses in proximity to sensitive receptors may have hazardous emissions or handle hazardous or acutely hazardous materials or wastes that could pose a health risk to these sensitive receptors.

To protect sensitive receptors, Section 17210 et seq. of the State Education Code, Sections 21151.2 and 21151.4, and 21151.8 of the Public Resources Code (PRC) require that prospective school sites be reviewed to determine that such sites are not a current or former hazardous waste disposal site, a hazardous substance release site, or the site of hazardous substance pipelines. These laws also require consultation with local hazardous materials agencies and air quality districts to ensure that sites within one-quarter mile of a school that handle or emit hazardous substances would not potentially endanger future students or workers at the prospective school site.

Pursuant to the State Education Code, all school districts receiving State funds are required to prepare a Phase I Environmental Site Assessment (ESA) on prospective school sites. The Phase I ESA details the historical uses of the property and indicates any potential for contamination.

DTSC must review this assessment and make one of the following findings: (1) that no further action is required; or (2) that concerns about contamination exist and the district must conduct a Preliminary Endangerment Assessment (PEA). The PEA process entails site sampling and the development of a detailed risk assessment of any contaminants present on the proposed school property.

8 Produced water is water trapped underground that surfaces during oil and gas exploration and production. It may include any chemicals added during the oil and gas drilling, production, and treatment processes.

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The following schools are located within city limits:
• El Marino Elementary School – 1450 Port Road
• El Rincon Elementary School – 11177 Overland Avenue
• Farragut Elementary School – 10820 Farragut Drive
• La Ballona Elementary School – 10915 Washington Boulevard • Linwood E. Howe Elementary School – 4100 Irving Place • Culver City Middle School – 4601 Elenda Street
• Culver City High School – 4401 Elenda Street
Emergency Response
Emergency response plans include elements to maintain continuity of government during an emergency, emergency functions of governmental agencies, mobilization and application of resources, mutual aid, and public information. Emergency response plans are maintained at the federal, State, and local level for all types of disasters, including human-made and natural. It is the government’s responsibility to undertake an ongoing comprehensive approach to emergency management in order to avoid or minimize the effects of hazardous events. Local governments have the primary responsibility for preparedness and response activities. The Los Angeles County Office of Emergency Management (County OEM) maintains the Los Angeles County Operational Area Emergency Response Plan and the County of Los Angeles All-Hazard Mitigation Plan. The County OEM leads and coordinates disaster plans and disaster preparedness exercises for all cities and 288 special districts in Los Angeles County. The Planning Area is located within Areas A and H, Los Angeles County, Region 1, Southern Administrative Region of the State Office of Emergency Services.
9 City staff have been designated to coordinate
all State Emergency Management System (SEMS) functions. During the response phase, the Fire Station Number 1’s Emergency Operations Center (EOC) serves as the coordination and communication point, and the access to the Los Angeles County Operational Area.

Evacuation of the Planning Area, if necessary because of an emergency, would be conducted by the City’s Public Works Department, Los Angeles County Sherriff’s Department (LACSD), and Los Angeles County Fire Department (LACFD) in accordance with the City’s Multi-Jurisdictional Hazard Mitigation Plan (MJHMP). Pursuant to regulatory requirements, the MJHMP is being updated concurrently with the General Plan Update. In the event that an emergency occurs, evacuation routes have been identified that lead to gateway exit points located at the City boundary. The designated evacuation routes throughout the city are depicted in Figure 4.8-2, Primary Evacuation Routes. Additional evacuation routes include those streets that lead to evacuation centers within the City. Three evacuation reception centers have been identified in the City’s Disaster Preparedness Guide, including the Culver City Senior Center, Veterans Memorial Building and Culver City Teen Center. Through coordination with the City’s Public

9 Emergency Network Los Angeles, 2023. Disaster Management Areas, Cities, and Unincorporated Areas. https://enla.org/map/. Accessed May 2023.

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Preliminary − Subject to Revision
Works Department, LACSD, and LACFD, three representative emergency scenarios have been identified which would require an evacuation of populations within select evacuation zones within the City. Three emergency scenarios studied in an Evacuation Study include a potential wildfire hazard scenario, a dam inundation scenario, and a flood inundation scenario.10 Interstates 10 and 405, Venice Boulevard, Lincoln Boulevard, Jefferson Boulevard, and Sepulveda Boulevard all serve as potential evacuation routes, along with other roadways as needed. Information about emergency evacuation routes is shown in the maps contained in the MJHMP. These maps identify areas and communities with only one access route, particularly in residential areas, and distances to destinations for three evacuation scenarios.

Wildland Fire Hazards
Wildfires often occur in forests or other wildlands with ample vegetation. In areas where structures and other human development meet or intermingle with wildlands or vegetative fuels (referred to as the wildland-urban interface [WUI]), wildfires can cause significant property damage and pose extreme threats to public health and safety. Wildland fires have historically occurred in the surrounding Los Angeles County region but have not affected the city, including the 2019 Getty Fire in Los Angeles, 2003 Padua Fire in Los Angeles County, and the 1993 Topanga Fire in Malibu.

Fire Hazard Severity Areas in Los Angeles County are designated by the California Department of Forestry and Fire Prevention (CAL FIRE), LACFD and the Culver City Fire Department (CCFD) within the Planning Area. Fire hazard severity zones (FHSZs) range from Moderate to Very High.

There are three types of FHSZs based on who is financially responsible for preventing and suppressing wildfires.
• Federal Responsibility Areas (FRAs): The federal government is financially responsible for wildfire suppression.
• State Responsibility Areas (SRAs): The State is financially responsible for wildfire suppression.
• Local Responsibility Areas (LRAs): Cities or the County are financially responsible for wildfire suppression. The Planning Area falls under the LRA.

The Planning Area falls under the LRA, with the eastern portion mapped as being within a Very High FHSZ (VHFHSZ).
11 Refer to Section 4.19, Wildfire, for a detailed discussion pertaining to the potential impacts of the Project related to wildfire and fire hazards.

10 Culver City and Culver City Unified School District, 2023. Evacuation Route Capacity and Viability Study. 11 California Department of Forestry and Fire Protection, 2011. Very High Fire Hazard Severity Zones in Local Responsibility Areas (Culver City). September 2011.

Culver City General Plan 2045
Figure 4.8-2
Primary Evacuation Routes
SOURCE: City of Culver City and Culver City Unified School District, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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

Federal
Resource Conservation and Recovery Act
The federal RCRA (42 United States Code [U.S.C.] secs. 6901–6992k), which amended and revised the Solid Waste Disposal Act, regulates the generation, transportation, treatment, storage, and disposal of hazardous waste. Under RCRA regulations, generators of hazardous waste must register and obtain a hazardous waste activity identification number. RCRA allows individual states to develop their own programs for the regulation of hazardous waste as long as they are at least as stringent as RCRA’s.

Underground Storage Tanks (USTs) are regulated under Subtitle I of RCRA and its regulations, which establish construction standards for UST installations installed after December 22, 1988, as well as standards for upgrading existing USTs and associated piping. Since 1998, all non- conforming tanks were required to be either upgraded or closed.

Emergency Planning and Community Right-to-Know Act
The Emergency Planning and Community Right-to-Know Act (EPCRA) of 1986 was created to help communities plan for chemical emergencies.12 It also requires industry to report on the storage, use, and releases of hazardous substances to federal, State, and local governments.

EPCRA requires State and local governments, and Indian tribes to use this information to prepare for and protect their communities from potential risks.

Occupational Safety and Health Act of 1970
The Occupational Safety and Health Act of 1970, which is implemented by the federal Occupational Safety and Health Administration (OSHA), contains provisions with respect to hazardous materials handling. OSHA was created to assure safe and healthy working conditions by setting and enforcing standards and by providing training, outreach, education, and assistance. OSHA provides standards for general industry and construction industry on hazardous waste operations and emergency response. OSHA requirements, as set forth in 29 Code of Federal Regulations (CFR) Section 1910, et. seq., are designed to promote worker safety, worker training, and a worker’s right–to-know. The United States Department of Labor has delegated the authority to administer OSHA regulations to the State of California. The California OSHA program (Cal/OSHA) (codified in CCR, Title 8, or 8 CCR generally and in the Labor Code secs. 6300–6719) is administered and enforced by the Division of Occupational Safety and Health (DOSH). Cal/OSHA is very similar to the OSHA program. Among other provisions, Cal/OSHA requires employers to implement a comprehensive, written Injury and Illness

12 United States Environmental Protection Agency, 2023. Emergency Planning and Community Right-to-Know Act (EPCRA). https://www.epa.gov/epcra/what-epcra. Accessed April 2023.

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Preliminary − Subject to Revision
Prevention Program (IIPP) for potential workplace hazards, including those associated with hazardous materials.

Toxic Substances Control Act
In 1976, the federal Toxic Substances Control Act (15 U.S. Code (U.S.C.) Sections 2601–2671) established a system of evaluation in order to identify chemicals which may pose hazards. The Toxic Substances Control Act is enforced by USEPA through inspections of places in which asbestos-containing materials (ACM) are manufactured, processed, and stored and through the assessment of administrative and civil penalties and fines, as well as injunctions against violators. The Toxic Substances Control Act establishes a process by which public exposure to hazards may be reduced through manufacturing, distribution, use and disposal restrictions or labeling of products. PCBs are hazardous materials regulated by USEPA under the Toxic Substances Control Act (TSCA). These regulations ban the manufacture of PCBs although the continued use of existing PCB-containing equipment is allowed. PCBs were formerly used in such applications as hydraulic fluids, plasticizers, adhesives, fire retardants, and electrical transformers, among others. TSCA also contains provisions controlling the continued use and disposal of existing PCB-containing equipment. The disposal of PCB wastes is also regulated by TSCA (40 CFR 761), which contains life cycle provisions similar to those in RCRA. In addition to TSCA, provisions relating to PCBs are contained in the Hazardous Waste Control Law (HWCL), which lists PCBs as hazardous waste.

Under the TSCA, USEPA has enacted strict requirements on the use, handling, and disposal of ACM. These regulations include the phasing out of friable asbestos and ACM in new construction materials began in 1979. In 1989, USEPA banned most uses of asbestos in the country. Although most of the ban was overturned in 1991, the current banned product categories include corrugated paper, rollboard, commercial paper, specialty paper, flooring felt, and any new uses. TSCA also establishes USEPA’s Lead Abatement Program regulations, which provide a framework for lead abatement, risk assessment, and inspections. Those performing these services are required to be trained and certified by USEPA.

Hazardous Materials Transportation Act
USDOT prescribes strict regulations for the safe transportation of hazardous materials, including requirements for hazardous waste containers and licensed haulers who transport hazardous waste on public roads. The Secretary of the USDOT receives the authority to regulate the transportation of hazardous materials from the Hazardous Materials Transportation Act (HMTA), as amended and codified in 49 U.S.C. Section 5101 et seq. The Secretary is authorized to issue regulations to implement the requirements of the HMTA. The Pipeline and Hazardous Materials Safety Administration (PHMSA),
13 formerly the Research and Special Provisions Administration, was delegated the responsibility to write the hazardous materials regulations, which are contained in Title 49 of the CFR Parts 100–180.
14 Title 49 of the CFR, which contains the
regulations set forth by the HMTA, specifies requirements and regulations with respect to the

13 United States Department of Transportation, 2021. Federal Hazmat Law, September 2021. 14 CFR, Title 49, Parts 100–180, Transportation, revised as of October 1, 2010.

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Preliminary − Subject to Revision
transport of hazardous materials. It requires that every employee who transports hazardous materials receive training to recognize and identify hazardous materials and become familiar with hazardous materials requirements. Under the HMTA, the Secretary "may authorize any officer, employee, or agent to enter upon, inspect, and examine, at reasonable times and in a reasonable manner, the records and properties of persons to the extent such records and properties relate to: (1) the manufacture, fabrication, marking, maintenance, reconditioning, repair, testing, or distribution of packages or containers for use by any "person" in the transportation of hazardous materials in commerce; or (2) the transportation or shipment by any "person" of hazardous materials in commerce."
Research and Special Programs Administration
Research and Special Programs Administration (RSPA) regulations cover definition and classification of hazardous materials, communication of hazards to workers and the public, packaging and labeling requirements, operational rules for shippers, and training. They apply to interstate, intrastate, and foreign commerce by air, rail, ships, and motor vehicles, and also cover hazardous waste shipments. RSPA’s Federal Highway Administration (FHWA) is responsible for highway routing of hazardous materials and highway safety permits. The United States Coast Guard regulates bulk transport by vessel. The hazardous material regulations include emergency response provisions, including incident reporting requirements. Reports of major incidents go to the National Response Center, which in turn is linked with CHEMTREC, a service of the chemical manufacturing industry that provides details on most chemicals shipped in the United States.

Federal Emergency Management Act
The Federal Emergency Management Act (FEMA) was established in 1979 via executive order and is an independent agency of the federal government. In March 2003, FEMA became part of the United States Department of Homeland Security with the mission to lead the effort in preparing the nation for all hazards and effectively manage federal response and recovery efforts following any national incident.
15 FEMA also initiates proactive mitigation activities, trains first responders, and manages the National Flood Insurance Program and the United States Fire Administration.

Disaster Mitigation Act of 2000
Disaster Mitigation Act (42 U.S.C. Section 5121) provides the legal basis for FEMA mitigation planning requirements for State, local, and Indian Tribal governments as a condition of mitigation grant assistance. It amends the Robert T. Stafford Disaster Relief Act of 1988 (42 U.S.C. Section 5121–5207) by repealing the previous mitigation planning provisions and replacing them with a new set of requirements that emphasize the need and creates incentives for State, Tribal, and local agencies to closely coordinate mitigation planning and implementation efforts. This Act reinforces the importance of pre-disaster infrastructure mitigation planning to reduce disaster losses nationwide and the streamlining of the

15 Federal Emergency Management Act, 2023. History of FEMA. https://www.fema.gov/about/history. Accessed April 2023.

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administration of federal disaster relief and programs to promote mitigation activities. Some of the major provisions of this Act include:
• Funding pre-disaster mitigation activities;
• Developing experimental multi-hazard maps to better understand risk; • Establishing state and local government infrastructure mitigation planning requirements; • Defining how states can assume more responsibility in managing the Hazard Mitigation Grant Program (HMGP); and
• Adjusting ways in which management costs for projects are funded.

The mitigation planning provisions outlined in Section 322 of this Act establish performance- based standards for mitigation plans and require states to have a public assistance program (Advance Infrastructure Mitigation [AIM]) to develop county government plans. The consequence for counties that fail to develop an infrastructure mitigation plan is the chance of a reduced federal share of damage assistance from 75 percent to 25 percent if the damaged facility has been damaged on more than one occasion in the preceding 10-year period by the same type of event.

Other Hazardous Materials Regulations
In addition to USDOT regulations for the safe transportation of hazardous materials, other applicable federal laws that also address hazardous materials. These include:
• Community Environmental Response Facilitation Act (CERFA) of 1992 • Clean Water Act
• Clean Air Act
• Safe Drinking Water Act
• Atomic Energy Act
• Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) State
State Policies and Regulations
The primary State agencies with jurisdiction over hazardous chemical materials management are DTSC and the Los Angeles Regional Water Quality Control Board (LARWQCB). Other State agencies involved in hazardous materials management include Cal/OSHA and the State Office of Emergency Services (Cal OES).

Authority for the statewide administration and enforcement of RCRA rests with DTSC. While DTSC has primary State responsibility in regulating the generation, storage, and disposal of hazardous materials, DTSC may further delegate enforcement authority to local jurisdictions. In addition, DTSC is responsible and/or provides oversight for contamination cleanup and administers statewide hazardous waste reduction programs. DTSC operates programs to accomplish the following: (1) manage the aftermath of improper hazardous waste management

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by overseeing site cleanups; (2) prevent releases of hazardous waste by ensuring that those who generate, handle, transport, store, and dispose of wastes do so properly; and (3) evaluate soil, water, and air samples taken at sites.

The storage of hazardous materials in USTs is regulated by SWRCB, which delegates authority to the RWQCB on the regional level, and typically to the local fire department on the local level.

The Cal/OSHA program is administered and enforced by DOSH. Cal/OSHA is very similar to the federal OSHA program. For example, both programs contain rules and procedures related to exposure to hazardous materials during demolition and construction activities. In addition, Cal/OSHA requires employers to implement a comprehensive, written IIPP. An IIPP is an employee safety program for potential workplace hazards, including those associated with hazardous materials.

The Cal OES Hazardous Materials (HazMat) section under the Fire and Rescue Division coordinates statewide implementation of hazardous materials accident prevention and emergency response programs for all types of hazardous materials incidents and threats. In response to any hazardous materials emergency, the HazMat section staff is called upon to provide State and local emergency managers with emergency coordination and technical assistance.

California Hazardous Materials Release Response Plans and Inventory Law of 1985
The California Hazardous Materials Release Response Plans and Inventory Law of 1985, also referred to as the Business Plan Act, requires preparation of Hazardous Materials Business Plans (HMBPs) and disclosure of hazardous materials inventories, including an inventory of hazardous materials handled, plans showing where hazardous materials are stored, an emergency response plan, and provisions for employee training in safety and emergency response procedures for businesses that handle, store, or transport hazardous materials in amounts exceeding specified minimums (California HSC, Division 20, Chapter 6.95, Article 1). Statewide, DTSC has primary regulatory responsibility for management of hazardous materials, with delegation of authority to local jurisdictions that enter into agreements with the State. Local agencies are responsible for administering these regulations.

Several State agencies regulate the transportation and use of hazardous materials to minimize potential risks to public health and safety, including Cal/EPA and the California Emergency Management Agency. The California Highway Patrol (CHP) and the California Department of Transportation (Caltrans) enforce regulations specifically related to the transport of hazardous materials. Together, these agencies determine container types used and license hazardous waste haulers for hazardous waste transportation on public roadways.

Hazardous Waste and Substances Sites
Government Code Section 65962.5, amended in 1992, requires the Cal/EPA to develop and update annually the Hazardous Waste and Substances Sites (Cortese) List, which is a list of hazardous waste sites and other contaminated sites. The Cortese List is a planning document

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used by the State, local agencies, and developers to comply with California Environmental Quality Act (CEQA) requirements pertaining to providing information about the location of hazardous materials release sites. While the Cortese List is no longer maintained as a single list, the following databases provide information that meet the Cortese List requirements:

1. List of Hazardous Waste and Substances sites from DTSC’s EnviroStor database (HSC Sections 25220, 25242, 25356, and 116395);

2. List of open and active leaking underground storage tank (LUST) Sites by County and Fiscal Year from SWRCB’s GeoTracker database (HSC 25295);

3. List of solid waste disposal sites identified by SWRCB with waste constituents above hazardous waste levels outside the waste management unit (Water Code Section 13273[e] and 14 CCR Section 18051);

4. List of “active” Cease and Desist Orders and Cleanup and Abatement Orders from SWRCB (Water Code Sections 13301 and 13304); and

5. List of hazardous waste facilities subject to corrective action pursuant to Section 25187.5 of the HSC, identified by DTSC.

Hazardous Waste Control Law
The HWCL empowers DTSC to administer the State’s hazardous waste program and implement the federal program in California. CCR Titles 22 and 23 address hazardous materials and wastes.

Title 22 defines, categorizes, and lists hazardous materials and wastes. Title 23 addresses public health and safety issues related to hazardous materials and wastes and specifies disposal options.

License to Transport Hazardous Materials – California Vehicle Code, Section 32000.5 et seq.

Caltrans regulates hazardous materials transportation on all interstate roads. Within California, the State agencies with primary responsibility for enforcing federal and State regulations and for responding to transportation emergencies are CHP and Caltrans. Together, federal and State agencies determine driver-training requirements, load labeling procedures, and container specifications for vehicles transporting hazardous materials.

Underground Storage Tanks Program
The State regulates USTs through a program pursuant to HSC, Division 20, Chapter 6.7, and CCR Title 23, Division 3, Chapter 16 and Chapter 18. The State’s UST program regulations include among others, permitting USTs, installation of leak detection systems and/ or monitoring of USTs for leakage, UST closure requirements, release reporting/corrective action, and enforcement. Oversight of the statewide UST program is assigned to SWRCB, which has delegated authority to RWQCBs and typically on the local level, to fire departments. The Culver City Fire Department (CCFD) and the LACFD administer and enforce federal and State laws and local ordinances for USTs within the Planning Area. Plans for the construction/installation, modification, upgrade, and removal of USTs are reviewed by fire department inspectors. If a release affecting groundwater is documented, the project file is transferred to the appropriate RWQCB for oversight.

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Aboveground Petroleum Storage Act
In 1989, California established the Aboveground Petroleum Storage Act instituting a regulatory program covering aboveground storage tanks (ASTs) containing specified petroleum products (HSC Sections 25270–25270.13). The Aboveground Petroleum Storage Act applies to facilities with storage capacities of 10,000 gallons or more or are subject to oil pollution prevention and response requirements under 40 CFR Part 112. Under the Aboveground Petroleum Storage Act, each owner or operator of a regulated AST facility must file a storage statement biennially with SWRCB disclosing the name and address of the AST facility; the contact person for the facility; and the location, size, age, and contents of each AST that exceeds 10,000 gallons in capacity and that holds materials that are at least five percent petroleum. In addition, each owner or operator of a regulated AST must prepare a Spill Prevention Control and Countermeasure Plan in accordance with federal and State requirements (40 CFR Part 112 and HSC Section 25270.5[c]).

The responsibility for inspecting ASTs and ensuring that Spill Prevention Control and Countermeasure Plans have been prepared lies with RWQCBs.

Asbestos-Containing Materials Regulations
State- level agencies, in conjunction with the USEPA and OSHA, regulate removal, abatement, and transport procedures for ACMs. ACM is regulated under State regulations in CCR, Title 8, Division 1, Chapter 4, Article 4, Sections 1529 and 5208; SCAQMD has local regulations, as discussed further below. Releases of asbestos from industrial, demolition, or construction activities are prohibited by these regulations and medical evaluation and monitoring is required for employees performing activities that could expose them to asbestos. In addition, the regulations include warnings that must be heeded and practices that must be followed to reduce the risk for asbestos emissions and exposure. Finally, federal, State, and local agencies must be notified prior to the onset of demolition or construction activities with the potential to release asbestos.

Lead Based Paint Regulations
LBP is defined as any paint, varnish, stain, or other applied coating that has a one milligram per square centimeter (mg/cm
2) (5,000 microgram per gram (μg/g) or 0.5 percent by weight) or more of lead. The United States Consumer Product Safety Commission (16 CFR 1303) banned paint containing more than 0.06 percent lead for residential use in 1978. Buildings built before 1978 are much more likely to have LBP.

The demolition of buildings containing LBPs is subject to a comprehensive set of California regulatory requirements that are designed to assure the safe handling and disposal of these materials. Cal/OSHA has established limits of exposure to lead contained in dusts and fumes, which provides for exposure limits, exposure monitoring, and respiratory protection, and mandates good working practices by workers exposed to lead, particularly since demolition workers are at greatest risk of adverse exposure. Lead-contaminated debris and other wastes must also be managed and disposed of in accordance with applicable provisions of the HSC.

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PCB Regulations
USEPA prohibited the use of PCBs in the majority of new electrical equipment starting in 1979 and initiated a phase
-o
ut for much of the existing PCB-c
ontaining equipment. The inclusion of
PCBs in electrical equipment and the handling of those PCBs are regulated by the provisions of the Toxic Substances Control Act, 15 U.S.C. Section 2601 et seq. (TSCA) and CCR, Title 22, Division 4.5, Chapter 11, Article 3, Section 66261.24. Relevant regulations include labeling and periodic inspection requirements for certain types of PCB -
containing equipment and outline
highly specific safety procedures for their disposal. The State of California likewise regulates PCB
-
laden electrical equipment and materials contaminated above a certain threshold as hazardous waste; these regulations require that such materials be treated, transported, and disposed of accordingly. At lower concentrations for non -l
iquids, RWQCBs may exercise
discretion over the classification of such wastes.

California Division of Occupational Safety and Health
Cal/OSHA is responsible for developing and enforcing workplace safety standards and ensuring worker safety in the handling and use of hazardous materials (8 CCR, Section 1529). Among other requirements, Cal/OSHA requires entities handling specified amounts of certain hazardous chemicals to prepare injury and illness prevention plans and chemical hygiene plans and provides specific regulations to limit exposure of construction workers to lead.

The Safe Drinking Water and Toxic Enforcement Act
The Safe Drinking Water and Toxic Enforcement Act (HSC, Section 25249.5, et seq.), Proposition 65, lists chemicals and substances believed to have the potential to cause cancer or deleterious reproductive effects in humans. It also restricts the discharges of listed chemicals into known drinking water sources above the regulatory levels of concern, requires public notification of any unauthorized discharge of hazardous waste, and requires that a clear and understandable warning be given prior to a known and intentional exposure to a listed substance.

California Water Code
The California Water Code (CWC) authorizes SWRCB to implement provisions of the Clean Water Act (CWA), including the authority to regulate waste disposal and require cleanup of discharges of hazardous materials and other pollutants. With regard to construction dewatering discharge analysis and treatment, groundwater may be encountered during deeper excavations for the underground parking structure and building foundations. Under the CWC, discharge of any such groundwater to surface waters, or any point sources hydrologically connected to surface waters, such as storm drains, is prohibited unless conducted in compliance with a Waste Discharge Requirement (WDR) permit. In addition to the CWC, these permits implement and are in compliance with the federal CWA’s National Pollutant Discharge Elimination System (NPDES) program. The dewatering program is implemented on the regional scale by the various RWQCBs, as discussed further below.

Government Code Section 3229, Division
In compliance with Section 3229, Division 3 of the PRC, before commencing any work to abandon any oil or natural gas well, the owner or operator shall request approval from the

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CalGEM, formerly the Division of Oil, Gas, and Geothermal Resources, via a written notice of intention to abandon the well.

California Fire Code
The 2019 California Fire Code (CFC), written by the California Building Standards Commission, is based on the 2018 International Fire Code (IFC). The IFC is a model code that regulates minimum fire safety requirements for new and existing buildings, facilities, storage, and processes. The IFC addresses fire prevention, fire protection, life safety, and safe storage and use of hazardous materials in new and existing buildings, facilities, and processes.

The CFC, Chapter 9 of Title 24 of the CCR, was created by the California Building Standards Commission based on the IFC and is updated every three years. The overall purpose of the CFC is to establish the minimum requirements to safeguard the public health, safety, and general welfare from the hazards of fire, explosion, or dangerous conditions in new and existing buildings, structures, and premises, and to provide safety and assistance to firefighters and emergency responders during emergency operations. Chapter 49 of the CFC contains minimum standards for development in the wildland–urban interface and fire hazard areas. The CFC also provides regulations and guidance for local agencies in the development and enforcement of fire safety standards.

Uniform Fire Code
The Uniform Fire Code, Article 80 (Section 80.103 of the Uniform Fire Code as adopted by the State Fire Marshal pursuant to HSC Section 13143.9), includes specific requirements for the safe storage and handling of hazardous materials. These requirements are intended to reduce the potential for a release of hazardous materials and for mixing of incompatible chemicals, and specify the following specific design features to reduce the potential for a release of hazardous materials that could affect public health or the environment:
• Separation of incompatible materials with a noncombustible partition; • Spill control in all storage, handling, and dispensing areas; and • Separate secondary containment for each chemical storage system. The secondary containment must hold the entire contents of the tank, plus the volume of water needed to supply the fire suppression system for a period of 20 minutes in the event of catastrophic spill.

California Governor’s Office of Emergency Services (Cal OES) In 2009, the State passed legislation creating Cal OES and authorized it to prepare a SEMS program (Title 19 CCR Section 2401 et seq.), which sets forth measures by which a jurisdiction should handle emergency disasters. In California, SEMS provides the mechanism by which local governments request assistance. Non-compliance with SEMS could result in the State withholding disaster relief from the non-complying jurisdiction in the event of an emergency disaster. Cal OES coordinates the State’s preparation for, prevention of, and response to major disasters, such as fires, floods, earthquakes, and terrorist attacks. During an emergency, Cal OES serves as the lead State agency for emergency management in the State. It also serves as the lead agency for mobilizing the State’s resources and obtaining federal resources. Cal OES

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coordinates the State response to major emergencies in support of local government. The primary responsibility for emergency management resides with the local government. Local jurisdictions first use their own resources and, as they are exhausted, obtain more from neighboring cities and special districts, the county in which they are located, and other counties throughout the state through the statewide mutual aid system (see discussion of Mutual Aid Agreements, below). California Emergency Management Agency (Cal-EMA) maintains oversight of the State’s mutual aid system.

Government Code Sections 65302.15 and 65302(g)(5)
In 2019 and 2020, California enacted two pieces of legislation regarding evacuation and require that cities update their Safety Elements, Emergency Operations Plan, or MJHMP, to identify and evaluate evacuation routes. California Government Code Section 65302.15, adopted through Assembly Bill (AB) 747, includes the requirement to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios. In addition, California Government Code Section 65302(g)(5), adopted through Senate Bill (SB) 99, requires identification of residential developments in hazard areas that do not have at least two emergency evacuation routes. These evacuation routes are included in the five-year update to the City’s MJHMP. Findings from this evacuation planning analysis and process may be found as Appendix C in the City’s MJHMP.

Emergency Managed Mutual Aid System
Cal OES developed the Emergency Managed Mutual Aid (EMMA) System in response to the 1994 Northridge Earthquake. The EMMA System coordinates emergency response and recovery efforts along the coastal, inland, and southern regions of California. The purpose of EMMA is to provide emergency management personnel and technical specialists to afflicted jurisdictions in support of disaster operations during emergency events. Objectives of the EMMA Plan is to provide a system to coordinate and mobilize assigned personnel, formal requests, assignment, training, and demobilization of assigned personnel; establish structure to maintain the EMMA Plan and its procedures; provide the coordination of training for EMMA resources, including SEMS training, coursework, exercises, and disaster response procedures; and to promote professionalism in emergency management and response. The EMMA Plan was updated in November 2012 and supersedes the 1997 EMMA Plan and November 2001 EMMA Guidance.

Regional
South Coast Air Quality Management District Rule 1403
SCAQMD Rule 1403, Asbestos Emissions from Renovation/Demolition Activities, regulates asbestos as a toxic material and controls the emissions of asbestos from demolition and renovation activities by specifying agency notifications, appropriate removal procedures, and handling and clean up procedures. Rule 1403 applies to owners and operators involved in the demolition or renovation of structures with ACM, asbestos storage facilities, and waste disposal sites.

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Los Angeles County Operational Area Emergency Response Plan The County of Los Angeles developed the Emergency Response Plan (ERP) to ensure the most effective allocation of resources for the maximum benefit and protection of the public in time of emergency. The ERP does not address normal day-to-day emergencies or the well-established and routine procedures used in coping with them. Instead, the operational concepts reflected in this plan focus on potential large-scale disasters like extraordinary emergency situations associated with natural and man-made disasters and technological incidents which can generate unique situations requiring an unusual or extraordinary emergency response. The purpose of the ERP is to incorporate and coordinate all facilities and personnel of the County government, along with the jurisdictional resources of the cities and special districts within the County, into an efficient Operational Area organization capable of responding to any emergency using a SEMS, mutual aid, and other appropriate response procedures. The goal of the plan is to take effective life-safety measures and reduce property loss, provide for the rapid resumption of impacted businesses and community services, and provide accurate documentation and records required for cost-recovery.

Los Angeles County All-Hazards Mitigation Plan
Los Angeles County’s All-Hazards Mitigation Plan was adopted in May 2020.16 The plan includes risk assessments and hazard mitigation strategies for a variety of hazards including wildfire. It describes the fireproof coating of and provision of auxiliary power for critical assets; Los Angeles County’s brush program, vegetation management program, and education and awareness programs to mitigate wildfire hazard risks; the Wildland Urban-Interface Ordinance as a codification of development standards to guide development in WUI areas; and various community wildfire protection plans to identify strategic sites and methods for fuel reduction projects across the landscape.

Local
Culver City Fire Code
At the local level, CCFD monitors the storage of hazardous materials for compliance with local requirements. Specifically, businesses and facilities that store more than threshold quantities of hazardous materials as defined in Chapter 6.95 of the HSC are required to file an Accidental Risk Prevention Program with the CCFD.
17 This program includes information such as emergency
contacts, phone numbers, facility information, chemical inventory, and hazardous materials handling and storage locations. CCFD also issues permits for hazardous materials handling and enforces California’s Hazardous Materials Release Response Plans and Inventory Law (HSC sec. 25500 et seq.). Basic requirements of California’s Hazardous Materials Release Response Plans and Inventory Law include the development of detailed hazardous materials inventories used

16 Los Angeles County Chief Executive Office, 2020. 2020 County of Los Angeles All-Hazards Mitigation Plan. https://ceo.lacounty.gov/wp-content/uploads/2022/04/County-of-Los-Angeles-All-Hazards-Mitigation-Plan- APPROVED-05-2020.pdf. Accessed May 2023.
17 The California Accidental Release Prevention program encompasses both the federal “Risk Management Program,” established in the CFR, Title 40, Part 68, and the State of California program, in accordance with the Title 19 of the CCR, Division 2, Chapter 4.5.

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and stored on-site, a program of employee training for hazardous materials release response, identification of emergency contacts and response procedures, and reporting of releases of hazardous materials. Any facility that meets the minimum reporting thresholds (i.e., a mixture containing a hazardous material that has a quantity at any one time during the reporting year that is equal to, or greater than, 55 gallons for materials that are liquids, 500 pounds for solids, or 200 cubic feet for compressed gas) must comply with the reporting requirements and file a Business Emergency Plan (BEP) with the local administering agency. 18 CCFD also administers, enforces, and inspects applicable standards of the Fire Code, Title 19, Uniform Building Code, Culver City, and national codes concerning new construction and remodeling. As part of inspections, businesses that store hazardous waste or hazardous materials in amounts exceeding the thresholds noted above are subject to review. Businesses that handle any single hazardous material at any one time in any amount greater than or equal to 55 gallons for a liquid, 500 pounds for a solid, or 200 cubic feet for a gas, have a reportable quantity and must report the inventory to CCFD.

CCFD provides emergency services within Culver City, including for fire, emergency medical, technical rescue (vehicle accident response, natural disaster response, swift water rescue, confined space rescue, low and high angle rope rescue, and structural collapse rescue), and hazardous materials incidents. CCFD works with City departments, municipalities and with community-based organizations to ensure that the City and its residents have the resources and information they need to prepare, respond, and recover from emergencies, disasters, and significant events.

Culver City Hazardous Waste Management Plan
As stated in Chapter 9.03.300 of the City’s Municipal Code, pursuant to State requirements, the City, in its efforts to assist in the proper management of hazardous waste and to provide adequate protections for its citizens, adopted the Culver City Hazardous Waste Management Plan (CCHWMP) for the management of hazardous waste, including the siting of hazardous waste storage, transfer and/or disposal facilities, which is consistent with the provisions of the Los Angeles County Hazardous Waste Management Plan (LA CoHWMP). The CCHWMP includes the following elements:
• An analysis of the hazardous waste stream generated in Los Angeles County, including an accounting of the volumes of hazardous waste produced in the county by type of waste, and estimates of the expected rates of hazardous waste production until 1994, by type of waste. • A description of the existing hazardous waste facilities which treat, handle, recycle, and dispose of the hazardous waste produced in the county, including a determination of the existing capacity of each facility.
• An analysis of the potential in the county for recycling hazardous waste and for reducing the volume and hazard of hazardous waste at the source of generation.

18 California Health and Safety Code, Division 20, Chapter 6.95, Article 1; CCR, Title 19, Sections 2620–2732; CCR, Title 24, Part 9, Section 80.115; Los Angeles Municipal Code, Article 7 of Chapter V, Section 57.120.1, and

57.120.1.4.

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• A consideration of the need to manage the small volumes of hazardous waste produced by businesses and households.
• A determination of the need for additional hazardous waste facilities to properly manage the volumes of hazardous waste currently produced or that are expected to be produced during the planning period.
• Siting criteria to be utilized in selecting sites for new hazardous waste facilities. • A statement of goals, objectives, and policies for the siting of hazardous waste facilities and the general management of hazardous wastes through the year 2000, as well as a statement of the goals of the City.
• A schedule which describes County and City actions necessary to implement the LA CoHWMP and CCHWMP through the year 2000, including the assigning of dates for carrying out the actions.

Culver City Hazardous Materials Disclosure Reporting Program Senate Bill (SB) 1082, passed in 1993, created the Unified Hazardous Waste and Hazardous Materials Management Regulatory Program (Unified Program) which requires the administrative consolidation of six hazardous materials and waste programs under one agency, a Certified Unified Program Agency (CUPA). Culver City is a member of the Los Angeles County CUPA, which requires that every business that handles more than 55 gallons, 5 pounds, or 200 cubic feet or more of a hazardous material (as defined by HSC) at any one time report their inventories of hazardous materials to LACFD and CCFD. This requirement is also applicable to quantities as low as one pound of materials classified as “extremely hazardous” (as defined by HSC). Per the City’s CUPA/Hazardous Materials Disclosure Reporting Program, business that meet the above hazardous materials thresholds must submit Reporting Forms manifesting the hazardous materials used, and an Emergency Plan for responding to any potential spills of these materials, to LACFD and CCFD to be kept on file by these departments. 19 Culver City and Culver City Unified School District (CCUSD) Multi- Jurisdictional Hazard Mitigation Plan
Culver City and CCUSD received a grant to prepare a MJHMP. The MJHMP presents a strategy for reducing the City's and CCUSD’s vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The MJHMP is a framework that guides the City in making decisions and developing policies to reduce or eliminate risk to life and property. The plan assesses the community’s risks and vulnerabilities to natural hazard events such as earthquakes, flooding, and wildfire. The MJHMP includes a set of goals related to the overall goal of hazard mitigation planning and mitigation measures that will serve to advance the plan goals. The MJHMP was approved by Cal OES and FEMA on June 1, 2017. The MJHMP process has allowed the City to review and expand upon the policies contained in the General Plan’s Safety Element.

The City views the General Plan and the MJHMP as complementary planning documents that work together to achieve the ultimate goal of the reduction of risk exposure to residents within

19 Culver City Fire Department, 2005. Hazardous Materials Disclosure Program, Business Reporting Forms and Emergency Plan Packet, July 2005.

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the Planning Area. Many of the ongoing recommendations identified in the MJHMP’s mitigation strategy further the goals and policies of the General Plan and other adopted plans.20 Pursuant to regulatory requirements, the MJHMP is being updated concurrently with the General Plan Update. [Note to Team: What is the status of the MJHMP? Will information be available for the PEIR?]

4.8.4 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 hazards and hazardous materials if the project would:

Threshold HAZ-1: Create a significant hazard to the public or the environment through the routine use, transport, or disposal of hazardous materials.

Threshold HAZ-2: Create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the
environment.

Threshold HAZ-3: Emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.

Threshold HAZ-4: Be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or environment.

Threshold HAZ-5: Impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan.

Threshold HAZ-6: Expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

Threshold HAZ-7: For a project located within an airport land use plan or, where such plan has not been adopted, within two miles or a public airport or public use airport, would the project result in a safety hazard or excessive noise for people residing in or working in the project area.

The Initial Study (Appendix A) found no potentially significant impacts related to airport land use plans (Threshold HAZ-7); therefore, this issue is not evaluated in this section. Please see Appendix A for further discussion.

20 Culver City and Culver City Unified School District, 2017. Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/files/assets/public/documents/planning-amp- development/multijurisdictionalhazardm.pdf. Accessed July 2023.

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Methodology
Impacts related to hazards and hazardous materials resulting from implementation of the Project (collectively, the General Plan Update and Zoning Code Update) are discussed below.

The following impact analysis is based on an assessment of baseline conditions for the Planning Area, including locations of hazardous materials use and storage through a review of various databases identifying existing contaminated sites and City emergency response and evacuation plan requirements. This analysis identifies potential impacts based on the interaction between the affected environment and construction, operation, and maintenance activities related to future development allowed under the Project.

Development and activities occurring under the General Plan and Zoning Code Update would be regulated by the various laws, regulations, and policies summarized in the Regulatory Framework above. Compliance by the Project 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.

Project Impacts Analysis
Routine Use, Transportation, and Disposal of Hazardous Materials Threshold HAZ-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would create a significant hazard to the public or the environment through the routine use, transport, or disposal of hazardous materials.

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

General Plan Update
Future development allowed under the proposed General Plan would result in additional residential and nonresidential development, as well as other private and public improvements throughout the Planning Area, which could result in an increase in the routine transportation, use, and disposal of hazardous materials. Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description, of this Draft PEIR, identifies several land use designations in which uses within these areas have the potential to generate hazardous materials, including Mixed Use Corridor 2, Mixed Use Medium, Mixed Use High, and Mixed Use Industrial.

Construction
During construction activities, commercially available hazardous materials, including fuels, solvents, and paints, would be used resulting in the generation of hazardous waste. However, construction activities would be temporary, and the use of the materials would be required to comply with applicable laws and regulations governing the use and storage of hazardous materials.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-26 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Grading and excavation in infill areas may expose construction workers and the public to known or potentially unknown hazardous materials in the soil or groundwater. As discussed in Section

4.8.2, Environmental Setting, above, there are a number of sites throughout the Planning Area that contain hazardous materials and have the potential to pose health hazards. However, future development on contaminated sites would be required to be remediated prior to construction activities. In addition, any unknown contamination discovered during excavation would require halting of all construction activities and remediation. Remediation would be required to occur to the satisfaction of the appropriate responsible agency, DTSC, RWQCB, LACFD, or CCFD.

Future development allowed under the General Plan Update could involve demolition of older buildings that contain ACMs or LBP, resulting in potential exposure of these hazardous materials to workers or persons living in the area. There are various regulations pertaining to exposure, abatement, and protection from exposure to ACM and LBP. Future development requiring demolition would be required to comply with the California HSC, OSHA, and SCAQMD Rule 1403 related to removal of ACM and LBP. Compliance would require the preparation of LBP and ACM surveys for any building demolitions and appropriate remediation measures for removal of LBP and ACM during demolition activities. Asbestos and lead abatement are required to be performed and monitored by certified contractors. In addition, OSHA regulations require proper labeling, safety training, hazardous materials exposure warnings, and emergency action and fire prevention plan preparation.

The use, transport, and disposal of construction-related hazardous materials would be required to comply with mandatory regulations for hazardous materials adopted by USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD as described above in Section 4.8.3, Regulatory Framework. Compliance with applicable laws and regulations governing the use, transport, and disposal of hazardous materials would ensure that all potentially hazardous materials are used and handled in an appropriate manner and would minimize the potential for safety impacts to occur. For example, all spills or leakage of petroleum products during construction activities are required to be immediately contained, the hazardous material identified, and the material remediated in compliance with applicable regulations. All contaminated waste would be required to be collected and disposed of at an appropriately licensed disposal or treatment facility. In addition, CCFD, and Culver City Building and Safety Division coordinate review of building permits to ensure hazardous materials requirements are met prior to construction, including required separation between hazardous materials and sensitive land uses and proper hazardous materials storage facilities. Therefore, potential construction impacts would be less than significant.

Operation
Future development allowed under the General Plan Update would increase the number of residents and businesses within the city, mainly within activity centers and along commercial corridors, resulting in an increase in the amount of hazardous materials being transported, used, and stored, and the potential number of people being exposed to these materials. The transport of hazardous materials along Interstate 405, Interstate 10, State Route 90, and the City’s local roadways creates potential risks for spills or leaks from nonstationary sources. In addition,

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-27 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
seismic activity, flooding, and fires could result in hazardous materials being released onto land or into the air and water, contaminating the environment and endangering public safety.

The use, storage, transport, and disposal of hazardous materials by residents and commercial and industrial businesses of development under the Project would be required to comply with mandatory regulations for hazardous materials adopted by USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD as described above in Section 4.8.3, Regulatory Framework, during operation. Compliance with applicable laws and regulations governing the use, storage, and transportation of hazardous materials would ensure that all potentially hazardous materials are used and handled in an appropriate manner and would minimize the potential for safety impacts to occur.

In addition, CCFD conduct inspections for fire safety and hazardous materials management of businesses and residential dwellings. Businesses handling or storing hazardous materials over threshold quantities are required to submit an HMBP to the Los Angeles County CUPA. These HMBPs must include measures for safe storage, use, and handling of hazardous materials, along with an emergency plan that describes the facility’s response procedures in the event of a hazardous materials release. Should an accident occur during transport of hazardous materials, CCFD would respond. In addition, CHP conducts regular inspections of licensed transporters to ensure regulatory compliance and responds to hazardous materials emergencies on roadways.

The General Plan Update contains policies that would further minimize risk to the public or environment resulting from the transportation of hazardous materials and waste such as identifying and establishing specific travel routes to transport hazardous materials and wastes (Policy S-8.5); coordinating with CCFD and Los Angeles County’s CleanLA to prepare for and respond to hazardous materials incidents (Policy S-8.1); requiring businesses that transport, use, and/or store hazardous materials to adopt measures that protect public health and safety (Policy S-8.2); maintaining the City’s website and other outlets with information on how to safely handle household chemicals (Policy S-8.3); and revising, updating, and maintaining standards to dispose of hazardous waste and construction materials properly and effectively (Policy S-8.4). Therefore, potential operation impacts would be less than significant.

The Project identifies future land uses but does not describe specific development projects that would be undertaken during the planning horizon, and thus, estimating project-specific impacts would involve unreasonable speculation. In reviewing individual project applications and plans, the City would determine which General Plan Update policies and actions and Zoning Ordinance chapters apply, depending on the specific characteristics of the project type and/or project site during the development review process.

While future development allowed under the General Plan Update could result in an increase in the transportation, use, and disposal of hazardous materials in the Planning Area, future projects would be required to comply with requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD.

Therefore, impacts related to the transportation, use, and disposal of hazardous materials would be less than significant.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-28 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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 will occur throughout the City over time. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not create a significant hazard to the public or the environment through the routine use, transport, or disposal of hazardous materials.

Furthermore, the City would review development applications for subsequent development under the Project for compliance with the applicable regulations, policies of the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not create a significant hazard to the public or the environment through the routine use, transport, or disposal of hazardous materials, and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-8: Hazardous materials. Local code enforcement actions are strengthened to minimize threats to public and health and safety from hazardous materials. For example, the risk of multiple releases caused by earthquakes, industrial uses, and activities within the IOF will be minimal.

S-8.1: Hazardous materials coordination. Coordinate with the Culver City Fire Department and Los Angeles County’s CleanLA to prepare for and respond to hazardous materials incidents.

S-8.2: Hazardous materials use, storage, and transport. Require businesses that use, store, or transport hazardous materials to adopt measures that protect public health and safety.

S-8.3: City website updates. Maintain the City’s website and other outlets with information on how to safely handle and dispose of household chemicals.

S-8.4: Disposal of hazardous waste and construction materials. Revise, update, and maintain standards to dispose of hazardous waste and construction materials properly and effectively.

S-8.5: Travel routes for hazardous material transport. Identify and establish specific travel routes to transport hazardous materials and waste. Consider capacity to safely accommodate additional truck traffic, avoiding residential areas, and using interstate or State divided highways as preferred routes.

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 the routine use, transportation, or disposal of hazardous materials.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-29 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Accident and Upset Conditions
Threshold HAZ-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would create a significant hazard to the public or the environment through reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment.

Impact Statement HAZ-2: The Project would be required to comply with State law and implement federal, State, and local General Plan Update policies during construction activities, which would ensure that future development allowed under the General Plan Update would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment. Therefore, the Project would result in a less than significant impact related to accident and upset conditions.

General Plan Update
Construction
The General Plan Update would result in additional residential and nonresidential development throughout the city, which has the potential to result in upset or accident conditions. As Culver City is mostly “built out,” or developed, new development would primarily occur on parcels that are already developed. The majority of the future growth would occur within activity centers and along commercial corridors. In addition, the Project may result in other private and public improvements, such as road widenings and connections to existing utilities, throughout the city with the potential to result in upset or accident conditions. Construction activities have the potential to release potentially hazardous soil- and groundwater-based materials into the environment during site grading and excavation operations. Likewise, demolition of existing structures could potentially result in the release of hazardous building materials, such as asbestos and lead paint. To prevent and minimize upset or accident hazardous conditions to below a level of significance, existing local, State, and federal laws, including those listed above in Section 4.8.3, Regulatory Framework, would be enforced at all construction sites.

Future development (including redevelopment of existing developed sites) allowed under the General Plan Update must comply with Title 8 of the CCR, which establishes Cal/OSHA requirements related to public and worker protection. Topics addressed include materials exposure limits, equipment requirements, protective clothing, hazardous materials, and accident prevention. Construction safety and exposure standards for lead and asbestos are set forth in Title 8. Title 17 of the CCR establishes regulations relating to the use and disturbance of materials containing naturally occurring asbestos. Soil excavated during construction is regulated under Title 22 of the CCR. Los Angeles County CUPA, the local CUPA, is responsible for ensuring that the CCR and all other programs related to hazardous materials are implemented during construction activities.

As stated in Section 4.9, Hydrology and Water Quality, future development that disturbs one acre or more of soil, or that is part of a common plan of development that disturbs one acre or more of soil, must obtain permit coverage under the Construction General Permit by developing

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-30 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
and implementing a Storm Water Pollution Prevention Plan (SWPPP) with RWQCB prior to commencement of construction. The SWPPP must 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, maintenance responsibilities, and non-stormwater management controls. The best management practices in the SWPPP include measures to prevent spills and require on-site materials for cleanup.

As discussed in Impact HAZ-1, compliance with mandatory regulations would reduce all potential construction-related impacts to a less than significant level, and proposed General Plan policies would further reduce potential impacts to ensure they remain less than significant.

Operation
Future development resulting from implementation of the General Plan Update would comply with Cal/OSHA regulations concerning the use of hazardous materials, including requirements for safety training, exposure warnings, availability of safety equipment, and preparation of emergency action/prevention plans. All contaminated waste would be collected and disposed of at an appropriately licensed disposal or treatment facility.

As noted in Impact HAZ-1, in reviewing individual project applications and plans, the City would determine which General Plan Update policies apply depending on the specific characteristics of the project type and/or project site during the development review process.

In addition, all new development would be required to comply with applicable regulations for hazardous materials adopted by USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD, as described above in Section 4.8.3, Regulatory Framework, during operation, which would ensure that all operational impacts would be less than significant.

The General Plan Update contains policies that would minimize risk to the public or environment resulting from reasonably foreseeable upset and accident conditions involving the release of hazardous materials into the environment such as eliminating and safely removing all infrastructure that is vulnerable to failure and poses a threat to public safety, health, welfare, and the environment from within the Culver City portion of the IOF and continuing to work with the County of Los Angeles to address and eliminate safety concerns for oil and gas operations continuing within the County portion of the IOF (Goal S-9 and Policy S-9.1); evaluating the potential for methane or hydrogen sulfide gas releases due to active or abandoned oil facilities or natural conditions; prioritizing the public health, safety, and welfare of the community and developing a strategy for end-of-life considerations for the IOF (Policy S-9.2); and ensuring development is consistent with federal, State, and local safety guidelines, standards, and requirements related to soil gas releases (Policy S-8.6).

Compliance with State law and implementation of federal, State, and local General Plan Update policies and actions during construction and operational activities would ensure that future development allowed under the General Plan Update would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
involving release of hazardous materials into the environment. Therefore, impacts would be less than significant.

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 will occur throughout the city over time. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment. Furthermore, the City would review development applications for subsequent development under the Project for compliance with the applicable regulations, as well as the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment, and impacts would be less than significant.

S-8.6: Gas releases. Evaluate the potential for methane or hydrogen sulfide gas releases due to active or abandoned oil facilities or natural conditions. Ensure development is consistent with federal, State, and local safety guidelines, standards, and requirements related to soil gas releases.

Goal S-9: Inglewood Oil Field. Oil production uses are phased out or replaced with land uses that the City determines to be more compatible with the adjacent communities and their character.

S-9.1: IOF safety. Eliminate and safely remove all infrastructure that is vulnerable to failure and poses a threat to public safety, health, welfare, and the environment from within the Culver City portion of the IOF and continue to work with the County of Los Angeles to address and eliminate safety concerns for oil and gas operations continuing within the County portion of the IOF that is just easterly but adjacent to Culver City.

S-9.2: IOF strategy. Prioritize the public health, safety, and welfare of the community and develop a strategy for end of operations for the IOF.

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 accident and upset conditions.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-32 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Emit Hazardous Materials Within One-Quarter Mile of a School Threshold HAZ-3: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one -quarter mile of an existing or proposed school.

Impact Statement HAZ-3: The Project would be required to comply with existing federal, State, and local regulations related to hazardous materials, which would ensure that future development allowed under the General Plan Update would not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Therefore, the Project would result in a less than significant impact related to emitting hazardous materials within one-quarter mile of a school.

General Plan Update
As discussed in Section 4.14, Public Services, the city is served by CCUSD, which is comprised of five elementary schools, one middle school, one high school, one independent learning academy, and one adult education school. In addition, there are a variety of higher education institutions located in the Planning Area including Antioch University Los Angeles and West Los Angeles College. Given the distribution of schools in the Planning Area, it is possible that future development and redevelopment allowed under the General Plan Update, which may involve hazardous emissions or handling of hazardous materials and wastes, may occur within one- quarter mile of an existing or future school.

As described under Impacts HAZ-1 and HAZ-2, development allowed under the General Plan Update would be required to comply with existing federal, State, and local regulations related to hazardous materials, including General Plan Update Policies S-8.2, S-8.4, and S-8.6.

In particular, CCFD and Culver City Building and Safety Division coordinate review of building permits to ensure hazardous materials requirements are met prior to construction, including required separation between hazardous materials and sensitive land uses and proper hazardous materials storage facilities. Future development (including redevelopment of existing developed sites) allowed under the General Plan Update would be required by Los Angeles County CUPA, the local CUPA, to store, manage, and dispose of the materials in accordance with the Unified Program. Therefore, impacts would be less than significant.

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 will occur throughout the city over time. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not result in hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school. Furthermore, the City would review development applications for subsequent development under the Project for compliance with applicable regulations, the policies of the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
result in hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school, and impacts would be less than significant.

S-8.2: Hazardous materials use, storage, and transport. Require businesses that use, store, or transport hazardous materials to adopt measures that protect public health and safety.

S-8.4: Disposal of hazardous waste and construction materials. Revise, update, and maintain standards to dispose of hazardous waste and construction materials properly and effectively.

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 emitting hazardous materials within one-quarter mile of a school.

Hazardous Materials Sites
Threshold HAZ-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would be located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 and, as a result, would it create a significant hazard to the public or environment.

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

General Plan Update
According to an EnviroStor search performed on May 25, 2023, there are a total of eight sites on the list that are located within the Planning Area, including two active sites. According to a GeoTracker search performed on May 25, 2023, there are a total of 114 sites on the list that are

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
located within the Planning Area. However, 97 of those listings have been closed and require no further action, three are inactive, and two are eligible for closure. The remaining 12 sites are actively being remediated, assessed, or are in a verification monitoring program. As such, future development allowed under the General Plan Update could occur on a contaminated site. In addition, other properties could be added to the lists if contamination is discovered during the construction or operation of future development.

As discussed in Impact HAZ-1, HAZ-2, HAZ-3, and Section 4.8.3, Regulatory Framework, any development on a contaminated site would be required to comply with mandatory regulations, which would ensure that the development does not create a significant hazard to the public or the environment. For instance, Cal/EPA is authorized by USEPA to enforce and implement certain federal hazardous materials laws and regulations. DTSC, a department of Cal/EPA, protects California and California residents from exposure to hazardous waste, primarily under the authority of the RCRA and the HSC. DTSC requirements include the need for written programs and response plans, such as HMBPs. DTSC programs include dealing with aftermath clean-ups of improper hazardous waste management; evaluation of samples taken from sites; enforcement of regulations regarding use, storage, and disposal of hazardous materials; and encouragement of pollution prevention.

As described under Impact HAZ-1, should any hazardous materials be inadvertently encountered during construction activities from future development allowed under the General Plan Update, the handling, transportation, and disposal of hazardous materials would be required to comply with the requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD. In reviewing individual project applications, the City would determine applicable regulations and General Plan Update policies, depending on the specific characteristics of the project type and/or project site during the development review process. Therefore, impacts would be less than significant.

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. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not create a significant hazard to the public or environment as a result of locating development on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5.

Furthermore, the City would review development applications for subsequent development under the Project for compliance with applicable regulations, policies of the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not create a significant hazard to the public or environment as a result of being located on a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
No applicable proposed goals or policies were identified relevant to this threshold.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-35 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 hazardous materials sites.

Impairment or Interference with Emergency Response Plan Threshold HAZ-5: The Project would have a potentially significant impact if implementation of the General Plan Update and Zoning Code Update would impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan.

Impact Statement HAZ-5: The Project would not interfere with implementation of the Culver City MJHMP or operations of CCFD, LACFD, CCPD, LACSD, or other agencies that would respond in the event of a disaster or major emergency in Culver City. Therefore, the Project would result in a less than significant impact related to impairment or interference with an emergency response plan.

General Plan Update
Continued growth and development associated with implementation of the General Plan Update has the potential to strain the emergency response and recovery capabilities of federal, State, and local governments. Coordination among various City and County departments is necessary to ensure adequate emergency response.

The Los Angeles County Operational Area Emergency Response Plan provides the framework for responding to major emergencies or disasters. The goals of this plan are to outline a strategy to prepare for, respond to, and recover from an emergency or disaster for 88 cities, 137 unincorporated communities and 288 special districts in the county. In addition, the City’s MJHMP provides a strategy for reducing the City's and CCUSD’s vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The General Plan Update contains policies that aim to continually strengthen emergency response and emergency evacuation such as continuing to update emergency-related planning documents (including the MJHMP) every five years to ensure consistency with State and federal law, best practices, local conditions, and recent science (Policy S-1.1); continuing to incorporate the hazards and mitigation measures identified in the MJHMP into City emergency planning, capital projects, and programs (Policy S-1.2); continuing to develop and maintain an evacuation plan for the City to effectively communicate protocols to residents, distribute evacuation notices, and ensure that all transportation modes can effectively execute their evacuations (Policy S-1.3); and requiring all development proposals to identify existing evacuation routes or establish new evacuation routes as needed (S-7.14).

Furthermore, CCFD provides emergency response services within the Planning Area, including hazardous materials emergency response. The City’s participation in the SEMS as required under Government Code Section 8607(a) allows Culver City to receive State support and funding in the event of an emergency. SEMS incorporates the use of the Incident Command System, California

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Disaster and Civil Defense Master Mutual Aid Agreement, the Operational Area concept, and multiagency or interagency coordination. State agencies are required to use SEMS, and local government entities must use SEMS in order to be eligible for any reimbursement of response- related costs under the State’s disaster assistance programs. These resources would be utilized by Culver City in an emergency event. Implementation of the General Plan Update would not interfere with the implementation of the Culver City MJHMP because the MJHMP is being updated concurrently with the General Plan Update for consistency and the plan would be implemented by the City and CCUSD. In addition, the Project would not interfere with operations of CCFD, LACFD, CCPD, Los Angeles Sheriff’s Department, or other agencies (see Section 4.14, Public Services) that would respond in the event of a disaster or major emergency in Culver City. No project would be permitted to block any designated evacuation routes.

Evacuation of the Planning Area, if necessary because of an emergency, would be conducted by the City’s Public Works Department, LACSD, and LACFD. An evacuation route vulnerability assessment was prepared as part of the City’s Evacuation Route Capacity and Viability Study.

Evacuation route vulnerability can relate to physical features along an evacuation route that can be damaged during emergency scenarios and cause the evacuation route to be disrupted and unusable. Evacuation route vulnerability can also be expressed in term of vulnerability to residents where development areas are isolated and/or areas that have access to only one evacuation route. Residential areas that only have one access point to primary evacuation routes include Higuera Street Neighborhoods, Palm Court Retirement Living; Tompkins Way Neighborhood; Clarmon Place Neighborhoods; Huntley Avenue Neighborhood. In the evacuation scenarios prepared, these neighborhoods could be exposed to an increased risk due to the lack of egress opportunities and would be given earlier evacuation consideration. As such, the City has a process in place and growth associated with the General Plan Update would not conflict with the process or interfere with evacuation routes. Implementation of the General Plan Update would not impair or interfere with an emergency response plan. Therefore, impacts would be less than significant.

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 will occur throughout the city over time. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan. Furthermore, the City would review development applications for subsequent development for compliance with applicable regulations, policies of the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, and impacts would be less than significant.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-37 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-1: Community resilience. The City proactively advances community resilience and is prepared for all hazards, including climate disruption.

S-1.1: Emergency-related planning documents. Continue to update emergency-related planning documents (including the Multi-Jurisdictional Hazard Mitigation Plan) every five years to ensure consistency with State and federal law, best practices, local conditions, and recent science.

S-1.2: Multi-Jurisdictional Hazard Mitigation Plan. Continue to incorporate the hazards and mitigation measures identified in the Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) into City emergency planning, capital projects, and programs.

S-1.3: Evacuation plan. Continue to develop and maintain an evacuation plan for the City to effectively communicate protocols to residents, distribute evacuation notices, and ensure that all transportation modes can effectively execute their evacuations.

Goal S-7: Fire hazards. Threats to public safety from wildland and urban fire hazards are reduced and property damage minimized.

S-7.14: Evacuation routes. Require all development proposals to identify evacuation routes or establish new evacuation routes as needed.

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 impairment or interference with an emergency response plan.

Wildland Fire Hazards
Threshold HAZ-6: The Project would have a potentially significant impact if implementation of the General Plan Update and Zoning Code Update would expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires.

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

General Plan Update
A wildland fire is an uncontrolled fire in areas of little or no development. However, these fires can quickly spread to the urban/wildland interface where development meets expanses of vegetative fuels. As shown in Figure 4.14-2, Fire Hazard Zone within the Planning Area, in Section 4.14, Public Services, the majority of the Planning Area is not within a VHFHSZ; however, CAL FIRE classifies the eastern portion of the Planning Area, including the Culver Crest and Blair

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-38 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Hills neighborhoods and areas within West Los Angeles College and the IOF, as a VHFHSZ.

Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development. Future development allowed under the General Plan Update could include the development of additional residential uses in these neighborhoods, which could expose additional people and structures to wildland fire hazards.

Fire suppression services in the Planning Area are provided by CCFD and LACFD. To help protect the city and its residents from fire hazards, the City has building and fire codes that provide required regulations that must be implemented in development projects. The fire chief may also use their authority to instate certain building, planning, or landscaping requirements.

The City adopted the 2022 CFC, as amended, which is based on the 2021 IFC. These codes are revised on a triennial cycle. Provisions include sprinkler and fire hydrant requirements in new structures and remodels, methods intended to mitigate wildfire exposure, hazardous vegetation and fuel management, road widths and configurations designed to accommodate the passage of fire trucks and engines, methods to create defensible space around all buildings and structures, and requirements for minimum fire flow rates for water mains. The fire chief is authorized and directed to enforce the provisions of the CFC throughout the city. The City also adopted the most recent (currently 2022) version of the California Building Code (CBC) that includes sections on fire-resistant construction material requirements based on building use and occupancy. The construction requirements are a function of building size, purpose, type, materials, location, proximity to other structures, and the type of fire suppression systems installed.

Furthermore, the General Plan Update contains policies to minimize the risk of fire hazard such as continuing to adopt and enforce the CFC and Municipal Fire Code Amendments for new construction in fire hazard areas, including the use of sprinklers in residential structures (Policy S-7.13); developing stringent site design and maintenance standards for areas with high fire hazard or soil erosion potential (S-7.10); requiring new development to meet the State’s minimum standards for fire safety unless the City’s Municipal Code defines more conservative standards (Policy S-7.5); and developing design standards and strengthening performance review and code enforcement programs to ensure proposed development incorporates fire prevention features (Policy S-7.4). Given the State of California, County of Los Angeles, and Culver City require adherence to building codes and review by CCFD to reduce fire hazards, implementation of the General Plan Update would not expose people or structures to substantial wildfire hazards, and impacts would be less than significant.

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. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. Furthermore, the City would review development applications for compliance with applicable regulations, policies of the General Plan Update, the City’s Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-39 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
would not expose people or structures, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires, and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Safety
Goal S-7: Fire Hazards. Threats to public safety from wildland and urban fire hazards are reduced and property damage minimized.

S-7.4: Fire prevention code enforcement. Develop design standards and strengthen performance review and code enforcement programs to ensure proposed development incorporates fire prevention features.

S-7.5: Comply with minimum standards for fire safety. Require new development to meet the State’s minimum standards for fire safety unless the City’s Municipal Code defines more conservative standards. These standards include:
• Adequate road widths to accommodate emergency vehicles and developments; and • Enforcing Municipal Code provisions that require automatic fire extinguishing systems and other fire safety standards.

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.

S-7.13: Fire code enforcement. Continue to enforce the California Fire Code and Municipal Fire Code Amendments for new construction in fire hazard areas, like using sprinklers in residential structures.

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 wildland fire hazards.

4.8.5 Cumulative Impacts Analysis
The geographic scope of the cumulative impact analysis for hazards and hazardous materials is the Planning Area as well as the adjacent areas of the city of Los Angeles and unincorporated areas of Los Angeles County.

Routine Use, Transportation, Disposal, or Accidental Release of Hazardous Materials
The Project’s incremental contribution to cumulative impacts would not be significant. As previously discussed, future development allowed under the Project would result in additional residential and nonresidential development, as well as other private and public improvements throughout the Planning Area, which could result in an increase in the routine transport, use,

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-40 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
and disposal of hazardous materials. Potential impacts would be reduced less than significant with compliance with the CCR and implementation of a SWPPP to prevent hazardous materials spills and protect public safety. To ensure that development allowed under the General Plan Update would result in a less than significant contribution to cumulative impacts, applications for development would be reviewed by the City for compliance with General Plan Update policies and the Zoning Code Update to further reduce potential impacts related to sites with known hazardous materials to a less than significant level.

In addition, future development allowed under the Project would be required to comply with all requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD related to the transport, use, and disposal of hazardous materials. Accordingly, development allowed under the Project would not result in physical changes that would incrementally contribute to a significant environmental effect. For these reasons, the Project’s contribution to cumulative impacts would be considered less than significant.

Cumulative projects would be subject to the requirements and regulations set forth by the USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD related to the transport, use, and disposal of hazardous materials. Accordingly, cumulative development would not result in physical changes that would result in a significant environmental effect.

Cumulative projects would also be required to implement a SWPPP and comply with the CCR during construction, site grading, excavation operations, and building demolition. For these reasons, the Project in conjunction with cumulative projects would have a less than significant cumulative effect.

Emit Hazardous Materials Within One-Quarter Mile of a School The potential exists for the routine transport of hazardous materials and waste to result in the release of hazardous materials from an accident near a school site or the release of contamination near a school site resulting from the development of a site that has been previously contaminated, which could result in a potentially significant cumulative impact.

However, compliance with existing federal, State, and local regulations related to the transport, use, and disposal of hazardous materials mentioned above in Impacts HAZ-1 and HAZ-2 would reduce potential Project and cumulative impacts related to handling hazardous materials and waste near a school to a less than significant level. Therefore, the Project’s contribution to this cumulative impact would not be cumulatively considerable and cumulative impacts would be less than significant.

Hazardous Materials Sites
Existing hazardous materials sites could potentially be impacted if cumulative development is proposed on a previously-identified site. However, as discussed under Impact HAZ-4, any development on a contaminated site would be required to comply with mandatory regulations, which would ensure it does not create a significant hazard to the public or the environment. In addition, should any hazardous materials be inadvertently encountered during construction activities from cumulative development, the handling, transportation, and disposal of hazardous

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-41 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
materials would be required to comply with the requirements and regulations set forth by Culver City, USEPA, OSHA, USDOT, DTSC, Caltrans, CHP, Los Angeles County CUPA, and SCAQMD.

In reviewing individual cumulative project applications, local jurisdictions in the area would determine which regulations and general plan policies apply, depending on the specific characteristics of the project type and/or project site during the development review process.

Therefore, the Project’s contribution to this cumulative impact would not be cumulatively considerable and cumulative impacts related to hazardous materials sites would be less than significant.

Emergency Response and Evacuation Plans
The General Plan Update’s incremental contribution to cumulative impacts would not be significant. To ensure a less than significant contribution to cumulative impacts, future development allowed under the Project would be required to implement all applicable regulations and policies during the design review process. The City would review development applications for subsequent development under the Project for compliance with applicable regulations, the policies of the General Plan Update and Zoning Code Update related to emergency response plans and emergency evacuation plans. In addition, future development allowed under the Project would be considered in the context of the City’s General Plan Safety Element and MJHMP and is not expected to impair implementation of or physically interfere with the plan. Therefore, the Project’s contribution to cumulative impacts would be considered less than significant.

The CCFD manages and maintains emergency plans and training of City staff and community members and focuses on activities that will prepare the community to take care of itself in the period immediately following a local disaster. For example, the CERT program educates volunteers about disaster preparedness for the hazards that may impact their area and trains them in basic disaster response skills, such as first aid, light search and rescue, minor fire suppression, and other skills that are critical in the first few hours of disaster. In addition, Culver City has a MJHMP that is regularly updated. Adjacent jurisdictions also have emergency response plans and emergency evacuation plans. Furthermore, larger regional and statewide resource areas are regulated by State agencies to address larger-scale statewide issues. For these reasons, cumulative impacts associated with emergency response and evacuation plans would be less than significant.

Wildland Fire Hazards
Similar to future development under the Project, cumulative projects would be required to comply with the General Plan Update policies and implementation actions as well as local, State, and federal regulations, which would ensure that people or structures in the region are not exposed, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. For this reason, the contribution of the Project to this impact would not be cumulatively considerable. Therefore, cumulative impacts related to wildland fire hazards would be less than significant.

4. Environmental Impact Analysis

4.8. Hazards and Hazardous Materials
General Plan 2045 and Zoning Code Update Project 4.8-42 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.9-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.9 Hydrology and Water Quality

4.9.1 Introduction
This section evaluates potential environmental impacts to hydrology and water quality conditions in the Planning Area from implementation of the Project, including potential impacts related to water quality standards and waste discharge requirements, groundwater supplies and groundwater recharge, drainage patterns, and water quality control and sustainable groundwater management plans. This section also provides context regarding the Planning Area’s existing hydrologic setting, surface water quality, groundwater, planned improvements, and flooding hazards, as well as relevant federal, State, and local regulations and programs.

Hydrology refers to the distribution and circulation of water, both on land and underground.

Water quality refers to the quality of surface and groundwater. Surface water is on the surface of the land and includes lakes, rivers, streams, and creeks. Groundwater is below the surface of the earth.

Wetlands and waters of the United States are discussed in Section 4.3, Biological Resources, and water supply and wastewater conveyance and treatment are discussed in Section 4.18, Utilities and Service Systems.

4.9.2 Environmental Setting
Surface Water
Hydrologic Setting
The California Department of Conservation has divided California into 10 hydrologic regions, where the Planning Area is located in the Los Angeles Region under the jurisdiction of the Los Angeles Regional Water Quality Control Board (LARWQCB). 1 A hydrologic region is the area
drained by a river system or a segment of a river system, a closed basin(s), or a group of streams forming a coastal drainage area. The Los Angeles Region encompasses all coastal drainages flowing to the Pacific Ocean between Rincon Point (on the Coast of Western Ventura County) and the eastern Los Angeles County line, as well as the drainages of five coastal islands (Anacapa, San Nicolas, Santa Barbara, Santa Catalina, and San Clemente). The region also includes all coastal waters within three miles of the continental and island coastlines. A watershed is the area of land where all of the water that is under it or drains off of it goes into the same place. Los Angeles County includes part or all of six major watersheds. 2 The Planning
Area is located predominantly within the Ballona Creek Watershed with a few parcels on the western side of the city located within the Marina Del Rey Watershed, as shown in Figure 4.9-1, Existing Hydrologic Setting.

1 County of Los Angeles, 2014. Los Angeles County General Plan Update Draft Environmental Impact Report. Figure

5.9-1, Hydrologic Regions. Available at: https://planning.lacounty.gov/assets/upl/project/gp_2035_deir.pdf.

Accessed March 2023.
2 County of Los Angeles, 2014. Los Angeles County General Plan Update Draft Environmental Impact Report. Figure

5.9-2, Major Watersheds. Available at: https://planning.lacounty.gov/assets/upl/project/gp_2035_deir.pdf.

Accessed March 2023.

SEPULVEDA CHANNEL

CENTINELA CREEK CHANNELBALLONA CREEK
Reach 1
Reach 2
Reach 3
§¨¦405
§¨¦10
!(90
§¨¦5
!(1
!(2
§¨¦110
!(2
Los Angeles
County
Santa
Monica
°0 1.5 30.75
Miles
Sources: City of Culver City (2021); County of Los Angeles (2023); NHD (2018); CA Water Board (2018); ESRI (2021).

SEPULVEDA CHANNEL

CENTINELA CREEK CHANNELBALLONA CREEK
Reach 1
Reach 2
Reach 3
§¨¦405
§¨¦10
!(90
§¨¦5
!(1
!(
2 §¨¦110
!(2
Los Angeles
County
Santa
Monica
°0 1.5 30.75
Miles
Sources: City of Culver City (2021); County of Los Angeles (2023); NHD (2018); CA Water Board (2018); ESRI (2021).

Metro Station
City Limits
Sphere of Influence
E Line (Expo)
Major Roads
Local Roads
City Park
County and State Park
Other Open Space
Waterbody
Waterbody
Reach Limit
Watershed
Ballona Creek
Marina Del Rey
Inglewood
Beverly Hills
West Hollywood
Los Angeles
Marina Del Rey
Santa Monica
Bay
Ballona
Estuary
Ballona
Wetlands
Baldwin
Hills
Culver City General Plan 2045
Figure 4.9-1
Existing Hydrologic Setting
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; NHD, 2018; CA Water Board, 2018; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The Ballona Creek Watershed is located on the coastal plain of the Los Angeles Basin and includes a portion of the Santa Monica Mountains to the north and the Baldwin Hills to the south.
3 The Ballona Creek Watershed is approximately 128 square miles and extends across the cities of Culver City, Beverly Hills, and West Hollywood, and portions of the cities of Los Angeles, Inglewood, Santa Monica, and unincorporated areas of the County of Los Angeles. The Ballona Creek Watershed’s main water bodies are Ballona Creek, which runs centrally through the city, and Ballona Estuary located southwest of the city adjacent to the Pacific Ocean. Ballona Creek runs through the center of the Planning Area, extending for roughly 9.5 miles from the northeast portion of the city to the western boundary, where it continues to Ballona Estuary and the Pacific Ocean. Ballona Creek and the Estuary are collectively divided into three hydrological units:
• Ballona Creek Reach 1 is approximately two miles long from Cochran Avenue (which is outside of the city limits) to National Boulevard, in the northeastern portion of the city. This portion of the creek is channelized with vertical concrete walls. • Ballona Creek Reach 2 extends through the Planning Area, and is approximately four miles long between National Boulevard, in the northeast portion of the city, and Centinela Avenue where Ballona Estuary starts (outside of the Planning Area). Reach 2 is also channelized for the most part, with trapezoidal walls.
• Ballona Estuary Reach 3 is located entirely outside the Planning Area and starts at Centinela Creek and continues to the Pacific Ocean. This portion of the creek is approximately 3.5 miles of soft-bottom channel and experiences tidal inundation.

Major tributaries to Ballona Creek include Sepulveda Canyon Channel and the Centinela Creek. 4 Other water bodies in the Ballona Creek Watershed include the Del Rey Lagoon and the Ballona Wetlands, which are both connected to the Ballona Estuary through tide gates and are both outside of the Planning Area.

The Marina Del Rey Watershed is also located on the coastal plain of the Los Angeles Basin and is considered a sub-watershed located within the larger Santa Monica Bay Watershed. 5 The
Marina Del Rey Watershed is approximately 3 square miles and extends across the portions of the cities of Santa Monica, Los Angeles and Culver City and unincorporated areas of the County of Los Angeles.
6 The Marina Del Rey Watershed contains the Marina Del Rey Harbor, which is

3 Ballona Creek Watershed Management Group. 2016. Enhanced Watershed Management Program for the Ballona Creek Watershed. https://www.waterboards.ca.gov/losangeles/water_issues/ programs/stormwater/municipal/watershed_management/ballona_creek/BallonaCreek_RevisedEWMP_ corrected2016Feb1.pdf. Accessed March 2023.
4 Ballona Creek Watershed Management Group. 2016. Enhanced Watershed Management Program for the Ballona Creek Watershed. https://www.waterboards.ca.gov/losangeles/water_issues/ programs/stormwater/municipal/watershed_management/ballona_creek/BallonaCreek_RevisedEWMP_ corrected2016Feb1.pdf. Accessed March 2023.
5 Los Angeles County Flood Control District (LACFCD). 2018. Marina Del Rey Enhanced Watershed Management Program Plan.
https://www.waterboards.ca.gov/rwqcb4/water_issues/programs/stormwater/municipal/watershed_manageme nt/marina_delrey/20180226MdREWMPrevised.pdf. Accessed March 2023. 6 Los Angeles County. 2023. Marina Del Rey Watersehd webpage. https://dpw.lacounty.gov/wmd/watershed/mdr/index.cfm. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
open to the Pacific Ocean through its main channel and shares a common breakwater with Ballona Creek, as well as the Venice Canals and the tributary area to the Ballona Lagoons. 7 Surface Water Quality
Surface water quality can be affected by many variables, including but not limited to land use, hydrology, meteorology, geology, and soils. In general, urban stormwater runoff occurs following precipitation events (also known as wet weather runoff), especially during the early phases of precipitation events called first-flush, with the volume of runoff flowing into the drainage system depending on the intensity and duration of the rain event. Contaminants that may be found in stormwater from urban areas include sediments, trash, bacteria, metals, nutrients, organics, and pesticides. The source of contaminants includes surface areas where precipitation falls, as well as the air through which it falls. Contaminants on surfaces such as roads, maintenance areas, parking lots, and buildings, which are usually contained in dry weather conditions, may be carried by rainfall runoff into drainage systems.

Dry weather runoff also occurs in urban areas, which can be attributed to watering lawns, washing vehicles, or hosing down sidewalks. Pollutants in dry weather runoff can include fertilizer, pesticides, and pet waste, which are also directed into drainage systems.

In receiving waters, stormwater runoff can discharge excess sediments, which can cause high turbidity and rapid accumulation of sediments in lakes and ponds, with adverse impacts on biological organisms. In urban areas, metals such as zinc, copper, and lead, which can cause toxic effects in high concentrations, are most commonly associated with surface runoff.

Additionally, other toxic elements, especially those associated with hazardous waste, can be present within surface water flows.

Receiving Waters
Under the Clean Water Act Section 303(d), states are required to submit to the United States Environmental Protection Agency (USEPA) a list identifying waters within its boundaries not meeting water quality standards (impaired waters) and the water parameter (i.e., pollutant) not being met. The 2018 Clean Water Act Section 303(d) List of Impaired Waters, approved by the USEPA in 2021 and is current as of 2023, is a combined list of all water quality limited segments (WQLSs) and associated pollutants identified by the State Water Resources Control Board (SWRCB) as requiring a total maximum daily load (TMDL) under Section 303(d).

As illustrated in Figure 4.9-1, the receiving waterbodies that receive stormwater runoff from the Planning Area include Ballona Creek, Centinela Creek, Ballona Creek Estuary, Ballona Wetlands, Dockweiler Beach, Santa Monica Bay, and Marina Del Rey Harbor. Table 4.9-1, Receiving Waters for Urban Runoff in Culver City, lists the Section 303(d) impairments for the city’s receiving waters as well as the beneficial uses for receiving waters as designated by LARWQCB.

7 LACFCD. 2018. Marina Del Rey Enhanced Watershed Management Program Plan. https://www.waterboards.ca.gov/rwqcb4/water_issues/programs/stormwater/municipal/watershed_manageme nt/marina_delrey/20180226MdREWMPrevised.pdf. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Designated beneficial uses allow for appropriate water quality objectives and programs to maintain or enhance water quality.

TABLE 4.9-1

RECEIVING WATERS FOR URBAN RUNOFF IN CULVER CITY
Receiving Waters 303(d) List Impairmentsa Designated Beneficial Usesb Ballona Creek Cadmium (sediment), Coliform Bacteria,
Dissolved Copper, Cyanide, Lead, Selenium,
Toxicity, Trash, Viruses (enteric), Zinc
Reach 1: Municipal and Domestic Supply (MUN)
(potential), Warm Freshwater Habitat (WARM)
(potential), Wildlife Habitat (WILD), Water Contact
Recreation (REC1) (potential), Non-contact Water
Recreation (REC2)
Reach 2: MUN (potential), WARM (potential),
WILD (potential), REC1 (potential), Limited Water
Contact Recreation (LREC1), REC2
Centinela Creek
(Channel)
None None
Ballona Creek Estuary Cadmium, Chlordane (tissue and sediment), Indicator Bacteria, Copper, DDT, Lead
(sediment), Polycyclic Aromatic Hydrocarbons
(PAHs) (sediment), Polychlorinated Biphenyls
(PCBs) (tissue and sediment), Toxicity, Silver,
Zinc (sediment)
Navigation (NAV), Commercial and Sport Fishing
(COMM), Estuarine Habitat (EST), Marine Habitat
(MAR), WILD, Rare, Threatened, or Endangered
Species (RARE), Migration of Aquativ Organisms
(MIGR), Spawning Reproduction, and/or Early
Development (SPWN), Shellfish Harvesting
(SHELL), REC1, REC2
Ballona Wetlands Exotic Vegetation, Habitat Alterations, Reduced Tidal Flushing, Trash
EST, WILD, RARE, MIGR, SPWN, Wetland
Habitat (WET), REC1, REC2
Dockweiler Beach Indicator Bacteria Industrial Service Supply (IND), NAV, COMM, MAR, WILD, SPWN (potential), REC1, REC2
Santa Monica Bay DDT (tissue and sediment), Trash , PCBs (tissue and sediment), mercury, arsenic,

NAV, COMM, MAR, WILD, MIGR, SPWN, SHELL,
REC1, REC2
Marina Del Rey Harbor
(Back Basins)
Chlordane (tissue and sediment), Copper
(sediment), DDT (tissue), Dieldrin (tissue),
Dissolved Oxygen, Indicator Bacteria, Lead
(sediment), PCBs (tissue and sediment),
Sediment Toxicity, Zinc (sediment)
Harbor: NAV, COMM, MAR, WILD, SHELL,
REC1, REC2
Entrance Channel: NAV, COMM, MAR, WILD,
RARE, SHELL, REC1, REC2
All Other Areas: NAV, COMM, MAR, WILD,
RARE, SHELL, REC1 (potential), REC2
Marina Del Rey Harbor
(Beach)
None Public Beach Areas: NAV, COMM, MAR, WILD,
RARE, REC1, REC2
SOURCES:
a State Water Resources Control Board. 2018 California 2018 Integrated Report [Clean Water Act Section 303(d) List and 305(b) Report] b LARWQCB. 2019. Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties.

As shown in Table 4.9-1, Ballona Creek and Estuary, Dockweiler Beach, Santa Monica Bay, and Marina Del Rey Harbor and back basins are considered impaired water bodies; however, Ballona Creek is the only impaired water body within the Planning Area. To address the impaired conditions of Ballona Creek, multiple entities and agencies monitor water quality and implement various programs to prevent further creek degradation (e.g., Ballona Wetlands Foundation, Friends of Ballona Wetlands Education/Ecology Center, Santa Monica Bay Restoration Project, LARWQCB Trash TMDL for Ballona Creek and Wetland).

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Stormwater Drainage System
Urban runoff and stormwater in the Planning Area are managed by the Culver City Public Works Department Environmental Programs and Operations Division.8 The City is required to comply with the Municipal Separate Storm Sewer System (MS4) permit issued by the LARWQCB. The MS4 permit requires the City to implement best management practices (BMPs) that would improve water quality in the Ballona Creek Watershed Plan. The City is a member of the Ballona Creek Watershed Management Group, along with the cities of Beverly Hills, Inglewood, Los Angeles, Santa Monica, West Hollywood, and unincorporated areas of Los Angeles County. The City is also a member of the Marina Del Rey Watershed, which includes the cities of Los Angeles and Santa Monica and the County of Los Angeles.

Groundwater
Groundwater Basin Hydrology
The California Department of Water Resources (DWR) defines state groundwater basins based on geologic and hydrogeologic conditions. Groundwater basins are further divided into forebay and pressure areas. In general, forebay areas refer to areas of higher permeability and recharge to underlying aquifers. Pressure areas refer to areas where groundwater percolation is impeded by deposits of low permeability and where groundwater is confined.

According to the DWR, the Planning Area is located within the Coastal Plain of the Los Angeles Groundwater Basin. The Coastal Plain of Los Angeles Groundwater Basin is bound on the north by the Santa Monica Mountains, the Hollywood fault, and the Elysian, Repetto, Merced, Puente, and Chino Hills areas; on the west by the Pacific Ocean; on the east by the Santa Ana Mountains; and on the south by the San Juaquin Hills and the Pacific Ocean. 9 The water bearing units in the
Coastal Plain of the Los Angeles Groundwater Basin include multiple unconfined and confined aquifers.

In the vicinity of the Planning Area, the Coastal Plain of the Los Angeles Groundwater Basin is divided into three subbasins, consisting of the Central Subbasin, Santa Monica Subbasin, and the West Coast Subbasin. As shown in Figure 4.9-2, Existing Groundwater Subbasins within the Planning Area, the majority of the Planning Area is located within the Santa Monica Subbasin, while a small eastern portion of the Planning Area is located in the Central Subbasin and the southernmost portion is located in the West Coast Subbasin. The primary forebay areas are identified in the northeast portion of the Central Groundwater Sub-Basin. The rest of the Central Groundwater Sub-Basin and the entire West Coast Groundwater Sub-Basin are identified as pressure areas.10 Each groundwater subbasin is described in greater detail below.

8 Culver City. 2023. Stormwater and Urban Runoff. https://www.culvercity.org/City-Hall/Departments/Public- Works/Culver-City-Environmental-Initiatives/Stormwater-and-Urban-Runoff. Accessed March 2023. 9 California Department of Water Resources. 2015. California’s Groundwater Update 2013: A Compilation of Enhanced Content for California Water Plan Update 2013. https://water.ca.gov/-/media/ DWR-Website/Web-Pages/Programs/Groundwater-Management/Data-and-Tools/Files/Statewide- Reports/California-Groundwater-Update-2013/California--Groundwater-Update-2013---Chapter-6---South- Coast.pdf. Accessed March 2023.
10 Department of Water Resources. 2015. California’s Groundwater Update 2013: A Compilation of Enhanced Content for California Water Plan Update 2013.

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

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); DWR (2000); ESRI (2021).

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
Coastal Plain of Los Angeles Groundwater Basin
Central Subbasin
Santa Monica Subbasin
West Coast Subbasin
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); DWR (2000); 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
Coastal Plain of Los Angeles Groundwater Basin
Central Subbasin
Santa Monica Subbasin
West Coast Subbasin
Culver City General Plan 2045
Figure 4.9-2
Existing Groundwater Subbasins within
the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; DWR, 2000; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Santa Monica Subbasin
The Santa Monica Subbasin underlies the northwestern portion of the Coastal Plain of Los Angeles Groundwater Basin.11 It is bounded by impermeable rocks of the Santa Monica Mountains to the north, the Ballona Escarpment to the south, the Pacific Ocean to the west, and the Inglewood fault to the east. The Ballona Escarpment is an abandoned erosional channel from the Los Angeles River.
12 The Bellflower, Ballona, and Silverado aquifers are present in the subbasin. Replenishment of groundwater in the Santa Monica Subbasin is mainly percolation of precipitation and surface runoff from the Santa Monica Mountains. Groundwater in the subbasin moves mainly southward towards the Ballona Gap (an erosional channel cutting into and across the Inglewood fault), then flows toward the ocean. 13 Total storage of the subbasin is
estimated to be approximately 1,100,000 acre-feet.14 Under the Sustainable Groundwater Management Act (SGMA), the Santa Monica Subbasin is considered a “medium” priority basin.15 Groundwater recharge for the Santa Monica subbasin is a result mainly from percolation of precipitation and surface runoff from the Santa Monica Mountains. 16 Central Subbasin
The Central Subbasin occupies a large portion of the southeast part of the Coastal Plain of Los Angeles Groundwater Basin.
17 This subbasin is bounded to the north by a surface divide called the La Brea high and to the northeast and east by the Elysian, Repetto, Merced, and Puente Hills. The southeast boundary between the Central Subbasin and Orange County Groundwater Basin roughly follows Coyote Creek, which is a regional drainage province boundary. The southwest boundary is formed by the Newport Inglewood fault system and the associated folded rocks of the Newport Inglewood uplift.

As previously detailed, the Central Subbasin includes forebay areas (areas of higher permeability that provide recharge to underlying aquifers). This subbasin includes the Los Angeles and Montebello forebays, both of which have unconfined groundwater conditions and relatively interconnected aquifers that extend up to 1,600 feet deep to provide recharge to the aquifer system of this subbasin.
18 Throughout much of the subbasin, the aquifers are confined, but areas with semi-permeable aquicludes (a geologic formation or stratum that confines water in

11 California Department of Water Resources. 2004a. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Santa Monica Subbasin.
12 California Department of Water Resources. 2004b. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, West Coast Subbasin.
13 California Department of Water Resources. 2004a. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Santa Monica Subbasin.
14 California Department of Water Resources. 2004a. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Santa Monica Subbasin.
15 Golden State Water Company. 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed March 2023. 16 California Water Boards. 2004. California Groundwater Bulletin 118 – Coastal Plain of Los Angeles Groundwater Basin, Santa Monica Subbasin.
17 Department of Water Resources. 2004c. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Central Subbasin.
18 Department of Water Resources (DWR). 2004c. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Central Subbasin.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
an adjacent aquifer) allow some interaction between aquifers. Aquifers in the Central Subbasin include: Gaspur, Semiperched, Bellflower, Gardena, Gage, Silverado, Lynwood, and Sunnyside.

Total storage capacity of the Central Subbasin is approximately 13,800,000 acre-feet.19 Groundwater enters the Central Subbasin through surface and subsurface flow and by direct percolation of precipitation, stream flow, and applied waters. Also, groundwater replenishes the aquifers dominantly in the forebay areas. The Central Subbasin was adjudicated in 1965 (meaning groundwater rights were determined by the courts), and the DWR was appointed as water master. Under the SGMA, the unadjudicated portion of the Central Subbasin is considered a “high” priority basin and must be managed under a Groundwater Sustainability Plan. 20 The
major groundwater recharge basins in the Central Basin are the Rio Hondo and San Gabriel Coastal Spreading Grounds along the Rio Hondo and the San Gabriel Rivers, in the city of Montebello and city of Pico Rivera.

West Coast Subbasin
The West Coast Subbasin is bounded to the north by the Ballona Escarpment, to the east by the Newport-Inglewood fault zone, and to the south and west by the Pacific Ocean and the Palos Verdes Hills. The surface of the subbasin is crossed in the south by the Los Angeles River and the San Gabriel River. In 1961, the West Coast Subbasin was adjudicated, and DWR is retained as water master. Aquifers present in the West Coast Subbasin include: Semiperched, Bellflower, Gaspur, Gardena, Gage, Lynwood, Silverado, and an unnamed aquifer. The groundwater in underlying aquifers is confined throughout most of the Basin, though the Gage and Gardena aquifers are unconfined where water levels have dropped below the Bellflower aquiclude.

The storage capacity of the primary water producing aquifer, the Silverado aquifer, is estimated to be approximately 6,500,000 acre-feet.
21 Natural replenishment of groundwater in the West
Coast Subbasin is largely limited to underflow from the Central Subbasin through and over the Newport-Inglewood fault zone. Seawater intrusion occurs in some aquifers that are exposed to the ocean offshore. Also, minor replenishment occurs from the infiltration of surface inflow from both the Los Angeles and San Gabriel Rivers into the uppermost aquifers. Groundwater recharge in the West Coast Basin is primarily done through injection wells.

Existing Groundwater Use and Supply
The Golden State Water Company (GSWC), which provides water to the city, has not used groundwater as a supply source since 1998.
22 In 2004, GSWC sold some groundwater pumping
rights to the City of Santa Monica. However, GSWC still has historical water rights in the Santa Monica Subbasin and the unadjudicated portion of the Central Subbasin. SGMA requires that groundwater basins in California create Groundwater Sustainability Agencies (GSA) and Groundwater Sustainability Plans (GSP) to sustainably manage groundwater conditions in

19 Department of Water Resources (DWR). 2004c. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Central Subbasin.
20 Golden State Water Company (GSWC). 2016. 2015 Urban Water Management Plan: Culver City. 21 Department of Water Resources. 2004c. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Central Subbasin.
22 Golden State Water Company. 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed March 2023.

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4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
impacted groundwater basins. Groundwater basins that are medium priority basins that are not adjudicated must complete a GSP no later than January 2022.23 The Santa Monica Basin Groundwater Sustainability Agency (SMBGSA) was formed in 2017 between the City of Santa Monica, City of Beverly Hills, City of Los Angeles, City of Culver City, and County of Los Angeles to develop a GSP for the Santa Monica Basin.
24 The Santa Monica Groundwater Subbasin GSP
was submitted to the California DWR in January 2022.25 This action may limit the use of the GSWC’s Culver City System’s single well, the Sentney well, in the future.

The Water Replenishment District (WRD) manages the groundwater replenishment and groundwater quality activities for the West Coast and Central Basins. The WRD annually analyzes its monitoring well network to test for more than 100 water quality constituents, focusing on 11 key constituents that represent overall groundwater quality in the basins: total dissolved solids (TDS), iron, manganese, chloride, nitrate, trichloroethylene (TCE), tetrachloroethylene (PCE), arsenic, perchlorate, hexavalent chromium, and 1,4-dioxane. Since 2018, WRD has also completed a district-wide assessment for presence of per- and polyfluoroalkyl substance (PFAS) constituents, which are also included in their water quality reports. Overall, groundwater in the Los Angeles Coast Basin continues to be of high quality that is suitable for potable and non-potable uses, with only some areas facing poor water quality due to natural or anthropogenic sources that WRD monitors.
26 Flooding Hazards
Flooding occurs when a waterway, either natural or artificial, receives more water than it is capable of conveying, causing the water level in the waterway to rise. Depending on how long these conditions last and the amount of water the waterway receives in proportion to its capacity, the rising water level may eventually overtop the waterway’s banks or other boundaries to the drainage area, resulting in flooding in the surrounding area. The severity of a flood event also depends on the local topography and the ability of the soil in the area to absorb water. Floods often occur during heavy precipitation events, when the amount of rainwater exceeds the capacity of storm drains or flood control channels. Floods can also happen when infrastructure, such as levees, dams, or culverts fail, or when a section of drainage infrastructure fails, and water cannot be drained from an area fast enough. These failures can be linked to precipitation events or can be a consequence of other emergencies, such as earthquakes.

The main waterway in the Planning Area is Ballona Creek, which runs approximately 9.5 miles from the Mid-Wilshire neighborhood of Los Angeles through the city and out to the Pacific

23 Golden State Water Company. 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed March 2023. 24 Golden State Water Company. 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed March 2023. 25 California Department of Water Resources. 2023a. Groundwater Sustainability Plan 4-011.01 SANTA MONICA. https://sgma.water.ca.gov/portal/gsp/preview/129. Accessed March 2023. 26 Water Replenishment District of Southern California, 2021. Regional Groundwater Monitoring Report Water Year 2019–2020. March.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Ocean at Marina Del Rey.27 Ballona Creek was channelized, straightened, and deepened in the 1930s to control flooding. A tributary of Ballona Creek, Centinela Creek, runs along part of the community’s southern border and was channelized in the 1960s.

According to the Federal Emergency Management Agency (FEMA), while the majority of the Planning Area is not located within a flood zone, there are various small pockets within the Planning Area that are located within a 100-year flood zone, as shown in Figure 4.9-3, Flood Zones in the Planning Area. The northern area is bounded roughly by Ballona Creek, Fairfax Avenue, and Adams Boulevard and is located within a 100-year flood zone for a 1 to 3-foot flood, meaning that there is a one in 100 chance that a flood event sufficient to cause 1 to 3 feet of inundation will occur in any given year (Zone AO).
28 Two additional areas nearby, one
between Eastham Drive and Ballona Creek and the second in the area immediately adjacent to Ballona Creek between National Boulevard and Sentney Avenue, are also within a 100-year flood zone, although FEMA does not specify the potential amount of inundation in this area (Zone A). Another part of the Planning Area, between Adams Boulevard and Dauphin Street, is at risk from a flood capable of causing inundation of less than 1 foot with a chance of occurring between one in 100 and one in 500 in any given year (Zone X).

Tsunami and Seiche Hazards
Tsunamis are ocean waves generated by vertical movement of the sea floor, normally associated with earthquakes or volcanic eruptions. The Planning Area is approximately 1.5 miles inland from nearby coastal areas, which is considered to be located outside of tsunami inundation zones according to the California Department of Conservation. 29 Seiches are oscillations of enclosed or semi-enclosed bodies of water that result from seismic events, wind stress, volcanic eruptions, underwater landslides, and local basin reflections of tsunamis. While Ballona Creek runs through the Planning Area, the creek is not considered an open body of water where seiches could occur. Furthermore, the Planning Area does not contain nor is it adjacent to open bodies of water subject to seiches.

27 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.
28 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.
29 California Department of Conservation, 2023. Tsunami Hazard Area Map, Los Angeles County; produced by the California Geological Survey and the California Governor's Office of Emergency Services. https://www.conservation.ca.gov/cgs/tsunami/maps. Accessed March 2023.

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

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
Sources: City of Culver City (2021); County of Los Angeles (2023); FEMA (2018); ESRI (2021).

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
100-year Flood 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 (2023); FEMA (2018); 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
100-year Flood Zone
Culver City General Plan 2045
Figure 4.9-3
Flood Zones in the Planning Area
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; FEMA, 2018; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.9.3 Regulatory Framework
Federal
Clean Water Act
The Clean Water Act (CWA) is the primary federal law that protects the quality of the nation’s surface waters, including lakes, rivers, and coastal wetlands. It is based on the principle that all discharges into the nation’s waters are unlawful unless specifically authorized by a permit.

Permit review is the CWA’s primary regulatory tool. A key component of the CWA is Section 402, which regulates point-source and nonpoint-source discharges to surface waters through the National Pollution Discharge Elimination System (NPDES) program. In California, the SWRCB oversees the NPDES program, which is administered by the RWQCBs. The NPDES program provides for both general permits (those that cover a number of similar or related activities) and individual permits. General permits in California designed for compliance with the NPDES program include the Construction General Permit and Industrial General Permit issued by the SWRCB, as well as MS4 permits issued by the RWQCBs. The Construction General Permit and the MS4 permits discussed below comply with Section 402.

The CWA also requires states to adopt water quality standards for receiving waters. Water quality standards designate beneficial uses for receiving waters (e.g., wildlife habitat, agricultural supply, fishing), and include the criteria required to support those uses. Water quality criteria are either narrative statements related to the quality of the water that support a particular use or maximum concentration levels for pollutants (i.e., lead, suspended sediment, bacteria, etc.). As part of the CWA, when monitoring data indicate that a concentration level for a pollutant has been exceeded, the receiving water is classified as impaired and placed on the CWA Section 303(d) List of Water Quality–Limited Segments Requiring TMDLs (303[d] list). A TMDL is then developed for the pollutant(s) that caused the impairment. A TMDL is an estimate of the total load of pollutants from point, non-point, and natural sources that a water body may receive without exceeding applicable water quality standards (plus a “margin of safety”). The purpose of the TMDL is to limit the volume of pollutants discharged into the receiving water from all sources (i.e., Stormwater runoff, wastewater, agriculture).

Executive Order 11988
Executive Order 11988 directs federal agencies to avoid to the extent practicable and feasible short- and long-term adverse impacts associated with the occupancy and modifications of floodplains and to avoid direct and indirect support of floodplain development wherever there is a practicable alternative. Furthermore, this Executive Order requires the prevention of uneconomic, hazardous, or incompatible use of floodplains; protection and preservation of the natural and beneficial floodplain values; and consistency with the standards and criteria of the National Flood Insurance Program (NFIP).

Federal Highway Administration (FHA) regulations require that a local hydraulic study and risk assessment be performed where a planned facility or action would encroach on a base floodplain or support incompatible floodplain development. When the hydraulic study indicates significant encroachment, findings must be made that it is the only practicable alternative. The

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
hydraulic study and risk assessment protocols are set forth in the Caltrans Highway Design Manual. This manual provides guidance and procedures whenever an encroachment permit is anticipated.

Federal Antidegradation Policy, 40 Code of Federal Regulations 131.12 The Federal Antidegradation Policy was released in 1968 and was included in the USEPA’s first Water Quality Standards Regulation. The Antidegradation Policy represents a three-tiered approach to maintaining and protecting water quality. First, all existing beneficial uses and levels of water quality necessary to protect those uses must be preserved and protected from degradation. Second, water quality must be protected in areas where the quality cannot support the propagation of fish, shellfish, and wildlife and recreation (“fishable/swimmable”). Third, the policy provides special protection of waters for which the ordinary water quality criteria are not sufficient. These waters are called “Outstanding National Resources Waters” and have been designated as unique or ecologically sensitive. If an activity is going to be allowed to degrade or lower water quality (in situations where existing water quality is higher than that needed to maintain established beneficial uses), the Antidegradation Policy requires that proposed projects meet the following criteria: (1) The activity is necessary to accommodate important economic or social development in the area; and (2) water quality is adequate to protect and fully maintain existing beneficial uses.

National Flood Insurance Program
The National Flood Insurance Act of 1968 established the National Flood Insurance Program, which is based on the minimal requirements for floodplain management and is designed to minimize flood damage within Special Flood Hazard Areas. FEMA is responsible for determining flood elevations and floodplain boundaries based on studies and surveys conducted by the U.S.

Army Corps of Engineers (USACE). FEMA is also responsible for distributing the FIRMs used in the National Flood Insurance Program. These maps identify the locations of special flood hazard areas, including the 100-year floodplain. FEMA allows nonresidential development in the floodplain; however, construction activities are restricted within flood hazard areas, depending on the potential for flooding within each area. Federal regulations governing development in a floodplain are set forth in Title 44, Part 60 of the Code of Federal Regulations, enabling FEMA to require municipalities that participate in the National Flood Insurance Program to adopt certain flood hazard reduction standards for construction and development in 100-year floodplains.

National Pollutant Discharge Elimination System Program The NPDES program was established per 1972 amendments to the Federal Water Pollution Control Act to control discharges of pollutants from point sources30 (Section 402). The 1987 amendments to the CWA created a section devoted to Stormwater permitting (Section 402[p]), with individual states designated for administration and enforcement of the provisions of the CWA and the NPDES program. The NPDES permit program is administered in the State of California by the SWRCB and RWQCBs under the authority of the USEPA to control water pollution by regulating point sources that discharge pollutants into waters of the United States.

30 Point sources are discrete water conveyances such as pipes or human-made ditches.

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Preliminary − Subject to Revision
If discharges from industrial, municipal, and other facilities go directly to surface waters, those project applicants must obtain NPDES permits. An individual NPDES permit is specifically tailored to a discharge to waters of the United States. A general NPDES permit covers multiple facilities within a specific activity category such as construction activities. A general permit applies with same or similar conditions to all dischargers covered under the general permit. The state Construction General Permit is discussed in the State subsection further below.

National Toxics Rule
In 1992, the USEPA promulgated the National Toxics Rule under the CWA to establish numeric criteria for priority toxic pollutants for 14 states to bring all states into compliance with the requirements of Section 303(c)(2)(B) of the CWA. The National Toxics Rule established water quality standards for 42 pollutants not covered under California’s statewide water quality regulations at that time. As a result of the court ordered revocation of California’s statewide Basin Plans in September 1994, the USEPA initiated efforts to promulgate additional federal water quality standards for California. In May 2000, the USEPA issued the California Toxics Rule, which includes all the priority pollutants for which USEPA has issued numeric criteria not included in the National Toxics Rule. The California Toxics Rule is discussed in greater detail below in the State subsection.

Safe Drinking Water Act
The Safe Drinking Water Act (SDWA), administered by the USEPA in coordination with the states, is the main federal law that ensures the quality of drinking water. Under the SDWA, the USEPA sets standards for drinking water quality and oversees the states, localities, and water suppliers who implement those standards. The Department of Public Health administers the regulations contained in the SDWA in the State of California.

State
Porter-Cologne Water Quality Act
The Porter-Cologne Water Quality Control Act, also known as the California Water Code, is California’s statutory authority for the protection of water quality. The Porter-Cologne Water Quality Act is promulgated in the California Code of Regulations Title 22. Under this act, the state must adopt water quality policies, plans, and objectives that protect the state’s waters.

The act sets forth the obligations of the SWRCB and RWQCBs pertaining to the adoption of Basin Plans and establishment of water quality objectives. Unlike the federal CWA, which regulates only surface water, the Porter-Cologne Water Quality Act regulates both surface water and groundwater. The Porter-Cologne Water Quality Act divided the state into nine regional basins, each with RWQCB. The Project area is located within the jurisdiction of the LARWQCB. The SWRCB is the primary state agency with responsibility to protect surface water and groundwater quality.

The Porter-Cologne Act authorizes the SWRCB to draft policies regarding water quality in accordance with CWA Section 303. In addition, the Porter-Cologne Act authorizes the SWRCB to issue waste discharge requirements (WDRs) for projects that would discharge to state waters.

These requirements regulate discharges of waste to surface and groundwater, regulate waste

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4.9. Hydrology and Water Quality
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Preliminary − Subject to Revision
disposal sites, and require cleanup of discharges of hazardous materials and other pollutants.

The Porter-Cologne Act also establishes reporting requirements for unintended discharges of any hazardous substance, sewage, or oil or petroleum product.

The Porter-Cologne Act requires the SWRCB or the RWQCBs to adopt water quality control plans (Basin Plans) and policies for the protection of water quality. The Basin Plan must conform to the policies set forth in the Porter-Cologne Act and established by the SWRCB in its State Water Policy. The Basin Plan identifies beneficial uses for the water to be protected, establishes water quality objectives for the reasonable protection of the beneficial uses, and establishes an implementation program for achieving the water quality objectives. Basin plans also provide the technical basis for determining WDRs, taking enforcement actions, and evaluating clean water grant proposals. Basin plans are updated and reviewed every 3 years in accordance with Article 3 of Porter-Cologne and CWA Section 303(c).

California Toxics Rule
The California Toxics Rule (40 CFR 131.38) is a USEPA-issued federal regulation that provides water quality criteria for potentially toxic constituents in California surface waters with designated uses related to human health or aquatic life. The rule fills a gap in California water quality standards that was created in 1994 when a state court overturned the state’s water quality control plans containing water quality criteria for priority toxic pollutants. These federal criteria are legally applicable in the State of California for inland surface waters, enclosed bays, and estuaries for all purposes and programs under the CWA. The California Toxics Rule establishes two types of aquatic life criteria: (1) Acute criteria represent the highest concentration of a pollutant to which aquatic life can be exposed for a short period of time without harmful effects;
31 and (2) Chronic criteria equal the highest concentration to which aquatic life can be exposed for an extended period of time (four days) without deleterious effects. Due to the intermittent nature of stormwater runoff, especially in Southern California, the acute criteria are considered to be more applicable to stormwater conditions than chronic criteria.

State Antidegradation Policy
Under the State’s Antidegradation Policy as set forth in SWRCB Resolution No. 68-16, whenever the existing quality of waters is better than what is needed to protect present and future beneficial uses, such existing quality must be maintained. This State policy has been adopted as a water quality objective in all the state’s Basin Plans. The State policy establishes a two-step process to determine if discharges with the potential to degrade the water quality of surface or groundwater will be allowed. The first step requires that, where a discharge would degrade high-quality water, the discharge may be allowed only if any change in water quality would be consistent with the maximum benefit to the people of the state, not reasonably affect present and anticipated beneficial uses of such water, or result in water quality that is not less than that which is prescribed in State policies (i.e., Basin Plans). The second step (as set forth in SWRCB Resolution No. 68-16) states that any activity resulting in discharge to high-quality waters is

31 The rule does not specify timeframe for “acute.” Standard practice would likely imply that any condition that is permanent or semi-permanent is chronic; all else would be short-term.

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4.9. Hydrology and Water Quality
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Preliminary − Subject to Revision
required to use the best practicable treatment or control of the discharge necessary in order to avoid the occurrence of pollution or nuisance and to maintain the “highest water quality consistent with the maximum benefit to the people of the state.” The State policy applies to both surface and groundwater, as well as to both existing and potential beneficial uses of the applicable waters.

National Pollutant Discharge Elimination System Permit Program As indicated above, in California, the NPDES stormwater permitting program is administered by the SWRCB through its nine RWQCBs. In the Project area, the NPDES stormwater permitting program is implemented and enforced by the LARWQCB (Region 4). The following NPDES permits address stormwater and dewatering.

Construction General Permit
The SWRCB adopted the original Construction General Permit for Stormwater Discharges from Construction Activities on September 2, 2009 (Order No. 2009-0009-DWQ, General NPDES Permit No. CAS000002) and recently adopted the updated Construction General Permit on September 8, 2022 (Order No. 2022-0057-DWQ). The Construction General Permit regulates construction activity, including clearing, grading, and excavation of areas one acre or more in size, and prohibits the discharge of materials other than stormwater, authorized non- stormwater discharges, and all discharges that contain a hazardous substance, unless a separate NPDES permit has been issued for those discharges.

For all construction activities disturbing one acre of land or more, California mandates the development and implementation of Stormwater Pollution Prevention Plans (SWPPP). The SWPPP documents the selection and implementation of best management practices (BMPs) to prevent discharges of water pollutants to surface or groundwater. The SWPPP also charges owners with stormwater quality management responsibilities. The developer or contractor for a construction site subject to the Construction General Permit must prepare and implement a SWPPP that meets the requirements of the Construction General Permit. 32 The purpose of a
SWPPP is to identify potential sources and types of pollutants associated with construction activity and list BMPs that would prohibit pollutants from being discharged from the construction site into the public stormwater system. BMPs typically address stabilization of construction areas, minimization of erosion during construction, sediment control, control of pollutants from construction materials, and post-construction stormwater management (e.g., the minimization of impervious surfaces or treatment of stormwater runoff). Routine inspection of all BMPs is required under the provisions of the Construction General Permit. In addition, the SWPPP is required to contain a visual monitoring program, a chemical monitoring program for non-visible pollutants, and a sediment monitoring plan if the site discharges directly to a water body listed on the 303(d) list for sediment.

32 Construction Stormwater Program, State Water Resources Control Board, October 30, 2019, https://www.waterboards.ca.gov/water_issues/programs/stormwater/construction.html. Accessed July 12, 2022.

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General Plan 2045 and Zoning Code Update Project 4.9-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
A site-specific SWPPP could include, but is not limited to the following BMPs:
• Erosion Control BMPs –protect the soil surface and prevent soil particles from detaching.

Selection of the appropriate erosion control BMPs would be based on minimizing areas of disturbance, stabilizing disturbed areas, and protecting slopes/channels. Such BMPs may include, but would not be limited to, use of geotextiles and mats, earth dikes, drainage swales, and slope drains.
• Sediment Control BMPs –treatment controls that trap soil particles that have been detached by water or wind. Selection of the appropriate sediment control BMPs would be based on keeping sediments on-site and controlling the site boundaries. These BMPs may include, but would not be limited, to use of silt fences, sediment traps, and sandbag barriers, street sweeping and vacuuming, and storm drain inlet protection. • Wind Erosion Control BMPs –applying water to prevent or minimize dust nuisance. • Tracking Control BMPs –preventing or reducing the tracking of sediment off-site by vehicles leaving the construction area. These BMPs include street sweeping and vacuuming. Project sites are required to maintain a stabilized construction entrance to prevent off-site tracking of sediment and debris.
• Non-Stormwater Management BMPs – also referred to as “good housekeeping practices,” keeping a clean, orderly construction site.
• Waste Management and Materials Pollution Control BMPs –implementing procedural and structural BMPs for handling, storing, and disposing of wastes generated by a construction project to prevent the release of waste materials into stormwater runoff or discharges through the proper management of construction waste.

To obtain coverage under the Construction General Permit, a developer is required to file a Notice of Intent (NOI) with the appropriate RWQCB and provide proof of the NOI prior to applying for a grading or building permit from the local jurisdiction and must prepare a State SWPPP that incorporates the minimum BMPs required under the permit as well as appropriate project specific BMPs. The SWPPP must be completed and certified by the developer, and BMPs must be implemented prior to the commencement of construction and may require modification during the course of construction as conditions warrant. When project construction is complete, the developer is required to file a Notice of Termination with the RWQCB certifying that all the conditions of the Construction General permit, including conditions necessary for termination, have been met.

Construction: NPDES Permit for Discharges of Groundwater from Construction and Project Dewatering
Dewatering operations are practices that discharge non-stormwater, such as ground water, that must be removed from a work location to proceed with construction into the drainage system.

Discharges from dewatering operations can contain high levels of fine sediments, which if not properly treated, could lead to exceedance of the NPDES requirements. A NPDES Permit for dewatering discharges was adopted by the LARWQCB on September 13, 2018 (Order No. R4- 2018-0125, General NPDES Permit No. CAG994004). Similar to the Construction General Permit, to be authorized to discharge under this Permit, the developer must submit a NOI to discharge

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
groundwater generated from dewatering operations during construction in accordance with the requirements of this Permit.33 In accordance with the NOI, among other requirements and actions, the discharger must demonstrate that the discharges will not cause or contribute to a violation of any applicable water quality objective/criteria for the receiving waters. The discharger must obtain and analyze (using appropriate methods) a representative sample of the groundwater to be treated and discharged under the Order. The analytical method used shall be capable of achieving a detection limit at or below the minimum level. The discharger must also provide a feasibility study on conservation, reuse, and/or alternative disposal methods of the wastewater and provide a flow diagram of the influent to the discharge point. 34 Operation: Los Angeles County Municipal Stormwater NPDES Program The County of Los Angeles, City of Los Angeles, and Culver City are Co-Permittees under the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No. CAS004004, effective September 11, 2021).35 The Los Angeles County MS4 Permit has been determined by the SWRCB to be consistent with the requirements of the CWA and the Porter-Cologne Act for discharges through the public storm drains in Los Angeles County to statutorily-defined waters of the United States (33 United States Code [USC] Section 1342(p); 33 CFR Part 328.11). On September 8, 2016, the LARWQCB amended the Los Angeles County MS4 Permit to incorporate modifications consistent with the revised Ballona Creek Watershed Trash Total Maximum Daily Load (TMDL), among other TMDLs incorporated into the Los Angeles County MS4 Permit and the Basin Plan for the Coastal Waters of Los Angeles and Ventura Counties.

Under the amended Los Angeles County MS4 Permit, the County and both Cities are required to implement development planning guidance and control measures that control and mitigate stormwater quality and runoff volume impacts to receiving waters as a result of new development and redevelopment. The County and both Cities also are required to implement other municipal source detection and elimination programs, as well as maintenance measures.

Under the Los Angeles County MS4 Permit, permittees are required to implement a development planning program to address stormwater pollution. This program requires project applicants for certain types of projects to implement a Low Impact Development (LID) Plan. The purpose of the LID Plan is to reduce the discharge of pollutants in stormwater by outlining BMPs, which must be incorporated into the design of new development and redevelopment.

These treatment control BMPs must be sufficiently designed and constructed to treat or retain the greater of an 85th percentile rain event or first 0.75 inch of stormwater runoff from a storm event.

33 LARWQCB, Order No. R4-2018-0125, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties, 2018.
34 LARWQCB, Order No. R4-2013-0095, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties, 2013.
35 LARWQCB, Order No. R4-2021-0105, NPDES Permit No. CAS004004, Regional Phase I MS4 NPDES Permit, Waste Discharge Requirements and National Pollutant Discharge Elimination System (NPDES) Permit For Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles and Ventura Counties. September 11, 2021.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The Los Angeles County MS4 Permit (Part VIII.F.4, Priority Development Project Structural BMP Performance Requirements) includes design requirements for new development and substantial redevelopment. These requirements apply to all projects that create or replace more than 5,000 square feet (sf) of impervious cover. Where redevelopment results in an alteration to more than 50 percent of impervious surfaces of a previously existing development and the existing development was not subject to post-construction stormwater quality control requirements (i.e., the existing development already has BMPs that comply with the MS4 Permit requirements), the entire project would be subject to post-construction stormwater quality control measures.

The Los Angeles County MS4 Permit contains provisions for implementation and enforcement of the Stormwater Management Program (SMP). The objective of the SMP is to reduce pollutants in urban stormwater discharges to the “maximum extent practicable” to attain water quality objectives and protect the beneficial uses of receiving waters in Los Angeles County. Special provisions are provided in the Los Angeles County MS4 Permit to facilitate implementation of the SMP. In addition, the Los Angeles County MS4 Permit requires that permittees implement a LID Plan, as discussed above, that designates BMPs that must be used in specified categories of development projects to infiltrate water, filter, or treat stormwater runoff; control peak flow discharge; and reduce the post-project discharge of pollutants into stormwater conveyance systems.

Similarly, Culver City adopted the Culver City Stormwater Quality Master Plan (SWQMP) in May 2021, to guide proposed actions for compliance with the MS4 permit and the EWMP. 36 Sustainable Groundwater Management Act
In September 2014, Governor Brown signed into law the SGMA, which provides a framework to regulate groundwater and strengthen local groundwater management of basins most critical to the state’s water needs. SGMA requires basins to be sustainably managed by local public agencies (e.g., counties, cities, and water agencies) who become GSAs. GSAs must assess conditions in their local water basins and adopt locally-based management plans to achieve long-term groundwater sustainability over the next 20 years. It protects existing surface water and groundwater rights and does not impact current drought response measures. The SGMA became effective January 1, 2015.

High- and medium-priority basins are required to develop GSPs to be submitted to the California DWR SGMA Portal. Adjudicated basins are not required to prepare GSPs but are required to submit annual basin reports to fulfill SGMA requirements. The most recent annual report submitted by the Central Basin and West Coast Basin are for the 2021 reporting year. 37 The
reports list total annual groundwater and surface water used for the reporting year.

36 Culver City Public Works Department. Culver City Stormwater Quality Master Plan. May 2021. 37 California Department of Water Resources. 2023b. Adjudicated Area Annual Reports. https://sgma.water.ca.gov/adjudbasins/report/publicview. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Regional
Enhanced Watershed Management Program for the Ballona Creek Group The Enhanced Watershed Management Program (EWMP) for the Ballona Creek Group [Los Angeles County, Los Angeles County Flood Control District (LACFCD), Beverly Hills, Culver City, Inglewood, Los Angeles, Santa Monica, and West Hollywood] describes a customized compliance pathway that participating agencies will follow to address the pollutant reduction requirements of the Los Angeles County MS4 Permit.
38 By electing the optional compliance pathway in the
MS4 Permit, the Ballona Creek Watershed Management Group (BCWM Group) has leveraged this EWMP to facilitate a robust, comprehensive approach to stormwater planning for the Ballona Creek watershed. The objective of the EWMP Plan is to determine the network of BMPs that will achieve required pollutant reductions while also providing multiple benefits to the community and leveraging sustainable green infrastructure practices. The Permit requires the identification of Watershed Control Measures, which are strategies and BMPs that will be implemented through the EWMP, individually or collectively, at watershed-scale to address the Water Quality Priorities in the EWMP. The Water Quality Priorities highlight the pollutants and waterbodies that are potentially not attaining water quality standards. 39 The EWMP
Implementation Strategy is used as a recipe for compliance for each jurisdiction to address Water Quality Priorities and comply with the provisions of the MS4 Permit. The EWMP Implementation Strategy includes individual recipes for each of the 8 jurisdictions and each watershed/assessment area— Ballona Creek, Centinela Creek, and Sepulveda Channel.

Implementation of the EWMP Implementation Strategy will provide a BMP-based compliance pathway for each jurisdiction under the MS4 Permit. The permit specifies that an adaptive management process will be revisited every two years to evaluate the EWMP and update the program. The EWMP Implementation strategy will evolve based on monitoring results by identifying updates to the EWMP Implementation Plan to increase its effectiveness.

Greater Los Angeles County Region Integrated Regional Water Management Plan
The Greater Los Angeles County Region (GLACR) Integrated Regional Water Management Plan (IRWMP) was most recently updated in 2014. The IRWMP is a regional plan designed to improve collaboration in water resources management. The first IRWMP for GLACR IRWMP was published in 2006 following a multi-year effort among water retailers, wastewater agencies, stormwater and flood managers, watershed groups, the business community, tribes, agriculture, and non-profit stakeholders to improve water resources planning in the Los Angeles Basin. It provides a mechanism for: (1) coordinating, refining, and integrating existing planning efforts within a comprehensive, regional context; (2) identifying specific regional and watershed-based priorities for implementation projects; and (3) providing funding support for the plans, programs, projects, and priorities of existing agencies and stakeholders.

38 Ballona Creek Watershed Management Group, Enhanced Watershed Management Program for the Ballona Creek Watershed, January 2016.
39 Ballona Creek Watershed Management Group, Enhanced Watershed Management Program for the Ballona Creek Watershed, p. ES-1, January 2016.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Los Angeles County General Plan
The Los Angeles County (County) General Plan governs the Sphere of Influence (SOI) portion of the Planning Area as it is within unincorporated Los Angels County. The County’s General Plan addresses flooding and drainage risks associated with stormwater runoff in the Safety and Conservation and Natural Resources Elements.

Los Angeles County Low-Impact Development Ordinance
In December 2012, the Los Angeles County Board of Supervisors updated the County Low Impact Development (LID) Ordinance (Chapter 12.84 of the County Code [LACC]) for compliance with the 2012 LARWQCB MS4 Permit. The updated LID Ordinance requires the integration into project design an array of feasible design features and operational practices for the retention, detention, storage, and filtration of stormwater and urban runoff, prior to discharge off-site. LID generally relies on an integrated system of decentralized, small-scale control measures that can be implemented at a project site, using structural devices, engineered systems, vegetated natural designs, and other techniques to control stormwater and urban runoff on-site and not solely through off-site conveyance or at an off-site collection point.

Los Angeles County Municipal Separate Storm Sewer System Permit As part of its NPDES program, the LARWQCB adopted a new MS4 Permit in 2021 (Order No. R4- 2021-0105). MS4 Permits were issued statewide in two phases. Phase I was initiated in 1990, under which the RWQCBs adopted NPDES MS4 Permits for medium (between 100,000 and 250,000 people) and large (more than 250,000 people) municipalities. As part of Phase II, the SWRCB adopted a General Permit for small MS4s (less than 100,000 people) and non-traditional small MS4s including governmental facilities such as military bases, public campuses, and prison and hospital complexes (WQ Order No. 2003-0005-DWQ).

The LARWQCB’s 2021 MS4 Permit named 85 incorporated cities, Los Angeles County, and the Los Angeles County Flood Control District as permittees. 40 The 2021 MS4 Permit imposes a
number of basic programs, called Minimum Control Measures, on all permittees in order to maintain a level of acceptable runoff conditions through the implementation of practices, devices, or designs, generally referred to as BMPs, that mitigate stormwater quality problems.

As an example, the development construction program requires the implementation of temporary BMPs during a project’s construction phase to protect water resources by preventing erosion, controlling runoff, protecting natural slopes and channels, storing fluids safely, managing spills quickly, and conserving natural areas.

Los Angeles Region Basin – Region 4, Water Quality Control Plan As required by the California Water Code, the LARWQCB has adopted the “Water Quality Control Plan, Los Angeles Region: Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties” (LA Basin Plan). Specifically, the LA Basin Plan designates beneficial uses for

40 California Water Boards – Los Angeles (R4). 2021. California Regional Water Quality Control Board Los Angeles Region Regional Phase I MS4 NPDES Permit (Order No. R4-2021-0105). https://www.waterboards.ca.gov/losangeles/water_issues/programs/stormwater/municipal/public_docs/2022/1 _Order(ACC-RPSignature).pdf. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
surface water and groundwater, sets narrative and numerical objectives that must be attained or maintained to protect the designated beneficial uses and conform to the state ’s Antidegradation policy, and describes implementation programs to protect all waters in the Los Angeles region. In addition, the LA Basin Plan incorporates (by reference) all applicable state and regional board plans and policies and other pertinent water quality policies and regulations.

Those of other agencies are referenced in appropriate sections throughout the LA Basin Plan.41 Local
Culver City Municipal Code
Culver City Municipal Code (CCMC) refers to the previously discussed Los Angeles County MS4 Permit for storm drain planning and design calculations. All drainage improvements in the vicinity of the Project are subject to review and approval by the Los Angeles County Department of Public Works and the Public Works Department of Culver City, as appropriate.

Section 5.05.010, Findings
CCMC Section 5.05.010 identifies Culver City as a permittee under the County of Los Angeles NPDES Permit (Permit Nos. R4-2012-0175 and CAS004001, MS4 Permit, since updated to R4- 2021-0105 as previously discussed) and subject to the discharge requirements of this permit.

This section also authorizes Culver City to adopt BMP requirements for new development and redevelopment (such as those below) to help Culver City comply with the discharge requirements.

Section 5.05.030, Requirements for Existing Properties; Good Housekeeping Provisions
CCMC Section 5.05.030 requires owners and occupants of property in Culver City to implement non-structural and/or structural BMPs to prevent or reduce the discharge of operational pollutants to the municipal storm drain system to the maximum extent practicable, such as:
minimizing washing down of paved areas and runoff from irrigation to the extent practicable; sweeping and collecting debris from paved areas; conducting vehicle maintenance in protected areas that avoid the discharge of associated pollutions to the storm drain system; periodic sweeping of parking lots with more than 25 parking spaces that are subject to stormwater runoff; and application of measures in areas where fuels, chemicals, animal waste, garbage, batteries, or other materials are used, stored or disposed of to avoid adverse impacts on water quality.

Code Section 5.05.035, Requirements for Industrial/Commercial and Construction Activities
CCMC Section 5.05.035 requires construction activities subject to NPDES requirements to implement non-structural and/or structural BMPs to reduce sediment, construction waste, trash, and other pollutants from construction activities be reduced to the maximum extent practicable; cover soil piles between October 1 and April 15 to avoid sedimentation; avoid washing construction vehicles where the runoff can enter the storm drain system; and

41 California Regional Water Quality Control Board. 2023. Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. https://www.waterboards.ca.gov/losangeles/ water_issues/programs/basin_plan/. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
implement a City-approved SWPPP and Wet Weather Erosion Control Plan for construction activities.

Section 5.05.040, Standard Urban Stormwater Mitigation Plan (SUSMP) Requirements for New Development and Redevelopment Projects
CCMC Section 5.05.040 requires the implementation of LID strategies and Standard Urban Stormwater Mitigation Plan (SUSMP) outlining pollution prevention control requirements during operation for projects meeting specified size and/or redevelopment criteria to mimic predevelopment hydrology. LID strategies include infiltration, evapotranspiration, bioretention, and/or rainfall harvest and use to retain stormwater runoff on-site for the Stormwater Quality Design Volume (SWQDv) defined as the 85 percentile 24-hour runoff event from the Los Angeles County 85th percentile precipitation isohyetal map. SUSMP stormwater pollution control strategies include but may not be limited to: minimizing impervious surface area; conserving natural areas; providing storm drain system stenciling and signage; conducting periodic street and parking lot sweeping; minimizing runoff during irrigation; avoiding motor vehicle washing where the runoff can enter the storm drain system; and installing grease/oil clarifiers.

Culver City Stormwater Quality Master Plan
Culver City Municipal Code refers to the previously discussed Los Angeles County MS4 Permit for storm drain planning and design calculations. Culver City developed the Culver City Stormwater Quality Master Plan (SWQMP), adopted in May 2021, to guide proposed actions for compliance with the MS4 permit and the Enhanced Watershed Management Program. 42 The Culver City
SWQMP is intended to be used as a custom compliance tool for Culver City to achieve stormwater quality goals, and includes guidance to assist developers in complying with the MS4 permit. LID projects are distributed, smaller-scale BMPs that capture, infiltrate, harvest, and use, or treat runoff on a parcel level. They are designed to receive surface runoff from either the surface directly or diversion from storm drainpipes. Examples generally include rainwater cisterns, rain gardens, permeable pavements, and infiltration BMPs.

4.9.4 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 hydrology and water quality if the project would:

Threshold HYD-1: Violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality.

Threshold HYD-2: Substantially decrease groundwater supplies or interfere substantially with groundwater recharge such that the project may impede sustainable groundwater management of the basin.

42 Culver City Public Works Department. 2021. Culver City Stormwater Quality Master Plan. https://www.culvercity.org/files/assets/public/documents/public-works/stormwater/stormwater-quality-master- plan-2021-final.pdf. Accessed March 2023.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-25 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Threshold HYD-3: Substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. Result in substantial erosion or siltation on- or off-site. ii. Substantially increase the create or amount of surface runoff in a manner which would result in flooding on- or off- site.
iii. Create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage
systems of provide substantial additional sources of
polluted runoff.
iv. Impede or redirect flood flows.

Threshold HYD-4: In flood hazard, tsunami, or seiche zones, risk release of pollutants due to project inundation.

Threshold HYD-5: Conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

Methodology
Potential impacts on surface and groundwater quality and the potential risk of flooding resulting from anticipated development under the Project were evaluated based on relevant information from FEMA, Los Angeles County, and Culver City. 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 4.9.3, 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. Note that the City requires compliance with many of the regulations as a condition of permit approval.

Project Impact Analysis
Violate Water Quality Standards or Waste Discharge Requirements Threshold HYD-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality.

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

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-26 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
General Plan Update
Impacts on water quality are closely related to the hydrologic context of the Planning Area and the sources and types of pollutants that can further degrade or impair the area’s water resources. The Planning Area is generally a developed, urban environment with limited vacant parcels, where the sources and types of stormwater pollutants are typical of an urban setting. As development occurs within the Planning Area to implement the land uses shown on Figure 2-6, Draft General Plan Land Use Map, the amount of impervious surfaces may increase due to the creation or expansion of roadways, parking lots, new buildings and other infrastructure.

Impervious surfaces generate higher runoff volumes than pervious surfaces. In addition, impervious surfaces collect urban pollutants that can be mobilized during a rain fall event. Thus, increasing impervious surfaces may also increase the amount of urban pollution in storm water runoff (e.g., sediment, fertilizers, bacteria, metal, trash, etc.).

Other sources of water quality impacts include direct discharge associated with industrial/commercial activities, automobiles, agriculture, and herbicides. Pollutant sources may be generated by past waste disposal practices and chemicals and fertilizers applied to landscaping. Contaminants may include sediment, PCBs, mercury, fuels and oils, metals, pesticides, nutrients, bacteria, and trash. However, the city is largely developed and although the General Plan Update anticipates approximately 10,996 new housing units, these would be primarily infill development in locations that are already developed with impervious surfaces.

Changes in land uses are also proposed that would increase the intensity of land uses on some parcels; however, that increase in intensity is not anticipated to result in a significant increase in runoff from existing conditions.

The General Plan Update could result in significant water quality impacts if future development facilitated under the Project were to violate the water quality standards or waste discharge requirements established in the NPDES Construction General Permit Order No. 2022-0057- DWQ, LARWCB CAG994004 Order No. R4-2018-0125/General NPDES Permit No. CAG994004, and Los Angeles County MS4 Permit No. Order No. R4-2021-0105/ NPDES Permit No.

CAS004004. Violation of these permits could occur if the development anticipated in the General Plan Update would substantially increase pollutant loading levels in the sanitary sewer system or in groundwater underlying the city, either directly through the introduction of pollutants generated by industrial land uses, or indirectly through stormwater pollution.

Implementation of the General Plan Update would include the development of a range of land uses, including residential, commercial, industrial, and open space. While some of the proposed land uses would increase impervious surfaces throughout the Planning Area, other land uses, such as new parks and dedicated open space, would increase pervious surfaces. Regardless of the type of land uses developed under the General Plan Update, future development would be required to comply with the laws, regulations, and permits that regulate water quality and stormwater discharge, as described in Section 4.9.3. Regulatory Framework, including the various water quality and waste discharge permits listed above. The City would require that future development projects demonstrate consistency and compliance, as applicable, with the applicable regulations and General Plan Update as part of the conditions of approval.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-27 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Implementation of the General Plan Update would require construction activities, such as grading, excavation, and trenching, which would generate the potential for increased soil erosion and sedimentation in stormwater runoff. Additionally, general construction activities could contribute pollutants such as construction waste, diesel and oil from equipment, solvents, and lubricants that could enter the City’s sewer system and enter downstream receiving waters. However, for future projects that disturb one acre or more, project applicants would be required to prepare and implement a project-specific SWPPP, which would identify site-specific BMPs to minimize stormwater runoff and reduce off-site pollution. These site-specific BMPs would be employed and monitored to prevent soil erosion and discharge of other construction-related pollution throughout the construction phase. In addition, all construction projects in the Planning Area would be required to demonstrate compliance with the CCMC, which also requires the preparation and implementation of a Wet Weather Erosion Control Plan for construction activities.

Some construction activities, such as excavation and trenching have the potential to encounter shallow water, which would require dewatering of the site. If improperly managed, these dewatering activities could result in discharge of contaminated groundwater. In accordance with the General NPDES Permit for Discharges of Groundwater from Construction and Project Dewatering Permit No. CAG994004 and the Permit Order No. R4-2018-0125 issued by LARWQCB, any contaminated groundwater would be treated prior to discharge or disposed of at an appropriate disposal facility or wastewater treatment plant. Also, discharges of dewatered groundwater to a storm drain must be conducted in a manner that complies with the Los Angeles MS4 Permit No. Order No. R4-2021-0105/ NPDES Permit No. CAS004004. All dewatering activities must also comply with the requirements of the CCMC. Therefore, compliance with the regional and local water quality and waste discharge requirements and permits would minimize risks of violating water quality standards or waste discharge requirements during construction of future development under the General Plan Update.

Once construction is completed, future development would also be required to comply with the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No. CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Requirements of these permits and ordinances include incorporating operational BMPs and LID features into project designs to minimize soil erosion and discharge of stormwater pollutants throughout the life of the projects. Operation BMPs could include, but are not limited to, bioswales, rainwater cisterns, rain gardens, permeable pavements, and infiltration BMPs, such as bio-retention basins. Implementation of the requirements and standards required by these permits and ordinances would reduce the volume of runoff from impervious surfaces and increase the amount of natural filtration of pollutants from stormwater occurring on site, generally improving the quality of stormwater before it enters the city’s and/or county’s stormwater system.

In addition to regulatory compliance, the General Plan Update also includes goals and policies to comply with the regional and City’s water quality regulations and standards, improve water quality with green infrastructure and incorporation of BMPs, such as naturalized filtration, swales and retention areas, and green streets, and increase stormwater collection and reuse systems (Goal INF-5, Policies INF-5.3, INF-5.4, INF-6.1,INF-6.2, and INF-6.3). The General Plan

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-28 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Update also includes various goals and policies to improve the water quality of Ballona Creek by improving incoming water quality as well as restoration of Ballona Creek (Goal C-6, Policies C-6.1 and C-6-2; Goal INF-6, Policies INF-6.1 to INF-6.4. Specifically, the General Plan Update includes the Ballona Creek Revitalization Project, which aims to improve water quality, better connect residents to Ballona Creek, and provide recreational, aesthetic, and ecological benefits. The General Plan Update also includes specific policies and implementation actions to handle the water quality at contaminated sites to improve the overall water quality within the Planning Area (Policies C-6.7, C-6.11, and C-6.12). Finally, the General Plan Update includes various stormwater infrastructure improvement efforts, including aligning the Ballona Creek Enhanced Watershed Management Program (BCEWMP) to its own stormwater ordinance, implementing a Culver City’s Clean Water measure (Measure CW), the County’s Safe Clean Water Program (Measure W), and exploring other funding resources. Overall, the proposed General Plan Update’s goals and policies would promote improved water quality within the Planning Area and continued compliance with federal, state, and local water quality regulations to ensure that water quality is protected to the maximum extent practicable.

For the reasons stated above, the proposed General Plan Update would not violate any water quality standards or waste discharge requirements or otherwise substantially degrade water quality. Therefore, impacts to water quality 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 the CWA and regulations enforced by the LARWQCB. In addition, future projects would comply with requirements related to water quality of the City’s Zoning Ordinance, CCMC, and the General Plan Update. Therefore, future development under the Project would not violate any water quality standards or waste discharge requirement or would otherwise substantially degrade surface or groundwater quality. As such, implementation of the Project would result in a less than significant impact related to water quality.

Applicable Proposed General Plan Goals and Policies
Infrastructure Element
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-5.3: Reduce impacts of development and redevelopment on water quality.

Require new development and redevelopment projects to, at a minimum, meet federal, State, regional, and local stormwater requirements around site design, stormwater treatment, stormwater infiltration, peak flow reduction, and trash capture.

Reduce impacts of development and redevelopment projects on water quality, encouraging private developers to address on- site stormwater management beyond what is required by law by:
• Requiring and incentivizing new development to construct bioswales or similar features to treat runoff before it enters the storm drains or receiving waters.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-29 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
• Requiring implementing Best Management Practices in parking lots to reduce pollutants in runoff and encourage pervious surfaces in new developments.

Goal INF-6: Water Quality. Water quality at downstream receptors and in Ballon Creek are improved.

INF-6.1: Naturalized filtration. Naturalized filtration. Expand naturalized filtration before discharge into Ballona Creek by connecting green infrastructure, integrating bioswales, and expanding green infrastructure strategies.

INF-6.2: Swales and retention areas in capital projects. Integrate vegetated swales and retention areas into pedestrian and bicycle planning capital improvement projects.

INF-6.3: Green streets. Implement green streets to manage 50 percent of stormwater runoff, encouraging stakeholders (i.e. property owners) to integrate green infrastructure with capital improvements.

INF-6.4: Water quality at contaminated sites. Ensure water quality of stormwater is managed appropriately at contaminated sites to protect natural systems from groundwater infiltration and stormwater runoff. Appropriate measures include:
• Proactive bioremediation measures at contaminated sites. • Collection of water over existing sumps on contaminated sites. • Contaminated site mediation activities as community educational opportunities to show-case naturalized regeneration and bioremediation technologies where feasible and at stages in the project deemed safe to do so.

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-6.1: Runoff capture and infiltration along Ballon Creek. Ensure City projects and proposed projects along Ballona Creek include features and BMPs to increase urban runoff capture and infiltration, while prioritizing nature-based solutions, like bioswales.

C-6.2: Runoff capture and infiltration along Ballon Creek. Ensure City projects and proposed projects along Ballona Creek include features and BMPs to increase urban runoff capture and infiltration, while prioritizing nature-based solutions, like bioswales.

C.6-7: Design innovation along the Ballona Creek corridor. Encourage design innovation in new development along the Ballona Creek corridor while avoiding significant noise and lighting effects on residential uses adjacent to the Creel. For example, orient improvements towards the creek, landscape open space areas, include public art like murals, decks/overlooks, seating, shade, bicycle facilities, and connections to the Ballona Creek path.

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.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-30 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
C-6.12: Ballona Creek funding strategies. Consider creative funding strategies like environmental impact bonds, mitigation banking, special taxes through assessment districts, private-public partnerships, and impact fees in addition to federal, State, and local measures and grants as mechanisms to implement Ballona Creek 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 water quality.

Groundwater Supplies and Groundwater Recharge
Threshold HYD-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update w ould substantially deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level.

Impact Statement HYD-2: The Project would not deplete groundwater supplies or interfere substantially with groundwater recharge such that there would be a net deficit in aquifer volume or a lowering of the local groundwater table level. Therefore, the Project would result in less than significant impacts related to groundwater supplies, the groundwater table level, and aquifer volumes.

General Plan Update
Implementation of the General Plan Update would accommodate a net increase in the population by approximately 21,600 residents, which would increase the demand for water, which in turn could lead to groundwater pumping. As discussed in Section 4.18, Utilities and Service Systems, the City’s water service is provided by Los Angeles Department of Water and Power (LADWP) and the Golden State Water Company (GSWC). Both providers use a combination of local groundwater and surface water purchased from Metropolitan Water District, which is imported from the Colorado River and the State Water Project in Northern California. While the City is not in control over the sources of its water supply provided by LADWP and the GSCW, the groundwater basins these agencies pump are regulated by the SGMA as well as individual basin plans, as applicable. Since the groundwater supply used by both of these water providers is regulated, there are limits on the amount of groundwater each provider can pump for potable use and for this reason, the potential for overdraft is limited. Additionally, neither of these water providers rely soley on groundwater to service the Planning Area and would be able to utlize other sources of potable water to supplemental a decrease in the amount of available groundwater, if needed. Therefore, implementation of the General Plan Update is not aniticipated to deplete groundwater supplies.

In regard to groundwater recharge, a substantial increase in impervious sufaces in the Planning Area would limit future groundwater recharge via infiltration of pervious surfaces. Existing land uses in the Planning Area with a majority of pervious surface area include approximatley 308.4 acres (9.9 percent) of parks, recreation, cemetary, and open space land uses, approximatley

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
431.8 acres (13.9 percent) of oil field land, and approximatley 74.6 acres (2.4 percent) of waterways.43 The remainder of the Planning Area (approximatley 2,302 acres or 73.8 percent) is already largely developed with land uses that require more impervious surface area (residential, commercial, institutional, industrial, mixed use, utilities, and transportation). The General Plan Update establishes land use designations that would encourage mixed uses and infill development, while maintaining existing parks and open space resources and expanding these resources. Therefore, implementation of the General Plan Update would not result in substantial increases of impervious surfaces such that groundwater recharge would be hindered.

As discussed above in Section 4.9.2, Environmental Setting, groundwater recharge in the Santa Monica Subbasin primarily consists of infiltration from precipitation and surface runoff from the Santa Monica Mountains; groundwater recharge basins in the Rio Hondo and San Gabriel Coastal Spreading Grounds along the Rio Hondo and the San Gabriel Rivers are used to recharge the Central Basin; and groundwater recharge for the West Coast Basin is primarily done through injection wells. Future development under the Project would not preclude any of these groundwater recharge processes established for the three underlying groundwater basins within the Planning Area. Therefore, replenishment of groundwater for any of these three groundwater basins is not solely reliant on natural recharge or percolation within the Planning Area.

Furthermore, the California Building Code (CBC) regulates any development that requires grading to submit an engineering geology report, which would include information about existing groundwater supplies and potential impacts to groundwater supplies. Therefore, any future development under the General Plan Update subject to the CBC would be required to account for its potential groundwater use and implement appropriate water conservation measures (or other mitigating actions) if the potential demand is projected to exceed the available supply.

For these reasons, the Project would not result in the depletion of groundwater supplies or interfere with groundwater recharge and impacts would be less than significant.

Zoning Code Update
Future development under the Zoning Code Update would be required to comply with the requirements related to groundwater of the CCMC, the City’s SUSMP and the General Plan Update. Therefore, future development under the Project would not deplete or interfere with groundwater supplies or recharge. As such, implementation of the Project would result in a less than significant impact related to groundwater.

Applicable Proposed General Plan Goals and Policies There are no applicable proposed goals or policies relevant to this threshold.

Mitigation Measures
No mitigation measures are required.

43 City of Culver City. 2020. Land Use and Community Design Existing Conditions Report. October 2020.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-32 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Level of Significance After Mitigation
Not applicable. The Project would result in less than significant impacts related to groundwater.

Substantially Alter Drainage Patterns
Threshold HYD-3: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would substantially alter the existing drainage pattern of the site or area, including through the alteration of the course of a stream or river or through the addition of impervious surfaces, in a manner which would:
i. result in substantial erosion or siltation on- or off-site. ii. substantially increase the create or amount of surface runoff in a manner which would result in flooding on- or off-site.
iii. create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems of provide substantial additional sources of polluted runoff. iv. impede or redirect flood flows.

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

General Plan Update
Ballona Creek is a major drainage that flows through the Planning Area. Implementation of the General Plan Update would not directly alter the course of Ballona Creek, or any other streams or rivers. The General Plan Update includes goals and policies that would support the goals of the Ballona Creek Revitalization Project, which aims to improve water quality, better connect residents to Ballona Creek, and provide recreational, aesthetic, and ecological benefits.

The Ballona Creek Revitalization Project builds on decades of prior initiatives and includes the Ballona Creek Greenway Plan and the Greening the Greenway Project, which received funding in 2021. Specific improvements under the Greening the Greenway Project would be required to undergo a separate project-level environmental review process to be approved by the City Council, where the project would need to demonstrate compliance with all applicable hydromodification and drainage regulations and standards. In addition, the Ballona Creek Revitalization Project would be designed in accordance with the CCMC, including all engineering and hydromodification requirements, and may be required to prepare a drainage technical report to address any alterations to the existing drainage patterns. Finally, any environmental impacts associated with the Ballona Creek Revitalization Project, including altering drainage patterns, would be assessed and mitigated, as necessary, during the separate project-specific

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
environmental review process prior to obtaining City approval. Therefore, implementation of the General Plan Update would not directly or indirectly alter the course of a stream or river.

In addition, implementation of the General Plan Update could impact the existing drainage systems within the Planning Area due to increases in impervious surfaces, which in turn could increase runoff from properties into the local sewer system. This increase in runoff volumes could in turn result in hydromodification effects— such as erosion, siltation, and flooding— on the hydrological systems within the Planning Area, which occur when rainfall runoff is increased from impervious areas above the natural rainfall rate that would otherwise occur. However, as discussed above, the majority of the city is currently developed and the land use patterns proposed by the General Plan Update would concentrate new housing primarily as infill development and would increase development intensity within currently developed areas.

Furthermore, future development would be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021- 0105, NPDES Permit No. CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections

5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Adherence to the regional and City’s permits, regulations, and ordinances would limit surface runoff from development under the General Plan Update, reducing siltation and erosion.

In addition, the Conservation Element includes policies such as maintaining and improving Ballona Creek’s capacity for flood control and ensuring City projects and other proposed projects along Ballona Creek include features and BMPs to increase capture of urban runoff and increase infiltration, which aim to reduce stormwater runoff and hydromodification effects, including erosion, siltation, and flooding related to Ballona Creek (Policies C-6.1 and C-6.2). The Safety Element also includes policies such as storm drain system evaluation and culvert and storm drain system maintenance to improve the City’s stormwater drainage system (Goal S-6, Policies S-6.6 and S-6.9). For these reasons, the impact of the General Plan Update with respect to the alteration of drainage patterns would be less than significant.

Zoning Code Update
The Zoning Code Update would provide specific landscape design standards, which would limit surface runoff for the various land use types identified in the General Plan Update. Future development under the Zoning Code Update would be required to comply with the requirements related to stormwater runoff of CCMC and the City’s SUSMP. Therefore, future development under the Project would not substantially alter drainage patterns. As such, implementation of the Project would result in a less than significant impact related to this topic.

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.

Policy C-6.1: Flood control coordination. Coordinate with other jurisdictions to forward plans and programs that help achieve regional goals for flood control and improve water quality.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Policy C-6.2: Runoff capture and infiltration along Ballon Creek. Ensure City projects and proposed projects along Ballona Creek include features and BMPs to increase urban runoff capture and infiltration, while prioritizing nature-based solutions, like bioswales.

Policy C-6.3: 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.

Safety Element
Goal S-6: Flood hazards. The community is resilient to flood and inundation hazards.

Policy S-6.6: Storm drain system evaluation. Continue to evaluate the effectiveness of City-owned storm drain systems and improve them as-needed.

Policy S-6.9: Culvert and storm drain system maintenance. Maintain the culverts and storm drain system to prevent debris or other obstructions from accumulating, as that would hamper the effectiveness of the system during rainy days.

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 substantially altering existing drainage patterns.

Release of Pollutant From Inundation by Flood, Tsunami, or Seiche Threshold HYD-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would risk release of pollutants due to inundation, if within a flood hazard, tsunami, or seiche zone.

Impact Statement HYD-4: The risk of release of pollutants as a result of inundation from being located in a flood, tsunami, or seiche zone would be considered extremely low for the Planning Area; therefore, impacts related to the risk of release of pollutants due to inundation from a flood, tsunami, or seiche would be less than significant.

General Plan Update
As described above in Section 4.9.2, Environmental Setting, the Planning Area is located approximately 1.5 miles inland from nearby coastal areas, which is located outside of tsunami inundation zones. In addition, there are no enclosed large water bodies within the Planning Area with potential for seiche effects or waves generated by failure of retaining structures.

Furthermore, as shown on Figure 4.9-3, the majority of the Planning Area is located outside of a flood hazard zone. For these reasons, the risk of release of pollutants as a result of inundation from being located in a flood, tsunami, or seiche zone would be considered extremely low for the Planning Area.

Additionally, future development facilitated under the Project would be required to comply with all applicable laws, regulations, and permits related to drainage and flooding hazards, which

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
would reduce the risk of onsite flooding and release of pollutants. Moreover, future development would also have to comply and demonstrate consistency with the Safety Element goals such as Goal S-6 (Flood Hazards) and policies such as monitoring City-owned drainage infrastructure and maintaining culverts and storm drain systems that address risks and hazards associated with flooding and discharge. Therefore, impacts associated with release of pollutants from inundation by flood, tsunami, or seiche would be less than significant.

Zoning Code Update
As described above, the risk of release of pollutants as a result of inundation from being located in a flood, tsunami, or seiche zone would be considered extremely low for the Planning Area and impacts would be less than significant. In addition, future development under the General Plan Update and the Zoning Code Update would be required to comply with the FEMA regulations for areas of the Planning Area within identified flood hazard zones. Therefore, the Zoning Code Update would not result impacts related to release of pollutants due to inundation, if within a flood hazard, tsunami, or seiche zone, and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-6: Flood hazards. The community is resilient to flood and inundation hazards.

Policy S-6.7: City-owners drainage systems. Monitor City-owned drainage infrastructure during rain events and take emergency action, as necessary, to avoid or minimize flooding.

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 release of pollutants from inundation by flood, tsunami, or seiche.

Conflict with a Water Quality Control Plan or Sustainable Groundwater Management Plan
Threshold HYD-5: The Project would have a potentially significant impact if implementation of the General Plan Update and Zoning Code Update would conflict with or obstruct implementation of a water quality control plan or sustainable groundwater management plan.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Statement HYD-5: The Project would not conflict with a water quality control plan or sustainable groundwater management plan and impacts would be less than significant.

General Plan Update
As described under Threshold HYD-1 above, implementation of the General Plan Update would not degrade water quality due to compliance with all applicable federal, state, regional and local water quality laws, regulations, and permits. Moreover, the General Plan Update contains goals and policies that promote improved water quality and groundwater sustainability in the Planning Area, as well as continued compliance with state and local water quality regulations, which is intended to ensure that water quality and groundwater sustainability is managed to the maximum extent practicable. As discussed in Section 4.9.3, Regulatory Framework, GSPs are not required for the West Coast Basin and Central Basin since these are considered adjudicated.

While there are no GSPs for these adjudicated subbasins, Groundwater Sustainability Agencies (GSAs) are still required to submit annual basin reports to fulfill SGMA requirements.

However, the Santa Monica Subbasin, is not an adjudicated basin and a GSP was adopted by the SMBGSA in January 2022.
44 Implementation of the General Plan Update would not interfere with or conflict with the GSP since the City is a member of SMBGSA and the Project includes various implementation actions that support the GSP, including incentivizing and mandating stormwater infiltration where feasible and participating in regional coordination regarding aquifer recharge and sustainable ground water supply. Furthermore, as described under Threshold HYD-2 above, due to the developed nature of the city and the proposed land use distribution, impacts to groundwater supplies as a result of new impervious surfaces would be less than significant. Thus, the General Plan Update would not conflict with the Santa Monica Subbasin GSP and impacts would be less than significant.

Zoning Code Update
Future development under the Zoning Code Update would also be required to comply with the CWA and regulations enforced by the LARWQCB. In addition, future development projects would comply with development requirements such as landscape standards provided in the Zoning Code Update, CCMC, and the General Plan Update. Therefore, future development under the Project would not conflict with a water quality control plan or sustainable groundwater management plan and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Land Use and Community Design
LU-17.4: Stormwater management throughout the Ballona Creek watershed. Continue to implement stormwater management practices across the Ballona Creek watershed to capture, treat, and store greywater to irrigate nearby landscapes, to improve water quality, and to increase trash capture.

44 California Department of Water Resources. 2023c. SGMA Portal. SGMA Groundwater Management (SGMA) Portal - Department of Water Resources (ca.gov) Accessed April 2023.

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4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-37 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Conservation Element
C-6.1: Flood control coordination. Coordinate with other jurisdictions to forward plans and programs that help achieve regional goals for flood control and improve water quality.

Infrastructure Element
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.

Goal INF-6: Water Quality. Water quality at downstream receptors and in Ballona Creek are improved.

INF-6.2: Swales and retention areas in capital projects. Integrate vegetated swales and retention areas into pedestrian and bicycle planning capital improvement projects.

INF-6.3: Green streets. Implement green streets to manage 50 percent of stormwater runoff, encouraging stakeholders (i.e. property owners) to integrate green infrastructure with capital 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 conflicting with a water quality control plan or sustainable groundwater management plan.

4.9.5 Cumulative Impacts Analysis
Water Quality
The geographic context for the analysis of cumulative impacts associated with water quality is the area covered by the Ballona Creek and Marina Del Rey Watersheds. Cumulative development in these watersheds may contribute to an incremental increase in impervious surfaces that could introduce pollutants that are typically associated with urban runoff into the

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-38 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
stormwater and impact water quality. Cumulative development could also contribute to water quality impacts in the watershed from construction activities. All future development in these watersheds, including development anticipated under the General Plan Update and Zoning Code Update, would be subject to the requirements of the NPDES program and other federal, State, and regional regulations such as pollution control ordinances. Adherence to these regulations would minimize degradation of water quality associated with the construction and operation of individual projects. As such, the cumulative impact with respect to water quality would be considered less than significant. Therefore, the Project would result in less than significant cumulative impacts related to water quality.

Groundwater
The geographic context for the analysis of cumulative impacts associated with groundwater is the area underlain by the Santa Monica Subbasin, West Coast Basin, and Central Basin. All basins are regulated, and thus have limits on the amount of groundwater that is pumped for potable use. Therefore, the potential for overdraft is limited. With respect to groundwater recharge, the areas overlaying these basins are heavily urbanized and primarily built out with impervious surfaces. Therefore, future development over these groundwater basins, including growth anticipated under the General Plan Update and the Zoning Code Update, would not result in substantial increases of impervious surfaces such that groundwater recharge would be hindered. In addition, groundwater recharge in the Santa Monica Subbasin primarily consists of infiltration from precipitation and surface runoff from the Santa Monica Mountains; groundwater recharge basins in the Rio Hondo and San Gabriel Coastal Spreading Grounds along the Rio Hondo and the San Gabriel Rivers are used to recharge the Central Basin; and groundwater recharge for the West Coast Basin is primarily done through injection wells. Thus, replenishment of groundwater is not reliant solely on natural recharge or percolation within the area. For these reasons, the cumulative impact with respect to depletion of groundwater supplies and groundwater recharge would be considered less than significant. Therefore, the Project would result in less than significant cumulative impacts related to groundwater.

Storm Drainage
The existing storm drain system in the city is currently owned and operated by the City, while the Los Angeles County Department of Public Works (LACPWD) is responsible for all regional drainage facilities within the County. Since local storm drain facilities within the city ultimately flow into the County facilities, the geographic context for cumulative impacts is western Los Angeles County. As the Planning Area and much of the County is heavily urbanized, future development would not involve the direct alteration of existing streams, rivers, or other drainage patterns. However, potential future development in western Los Angeles County, including growth anticipated under the General Plan Update and the Zoning Code Update, could impact the existing drainage system. All future development would be subject to floodplain management and stormwater and urban runoff pollution control ordinances for each jurisdiction that would prevent flood damage resulting from hydromodification. Adherence to these ordinances would also limit surface runoff from future development, thus reducing siltation and erosion. For these reasons, the cumulative impact with respect to storm drainage

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-39 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
would be considered less than significant. Therefore, the Project would result in less than significant cumulative impacts related to storm drainage and hydromodification effects.

Flood Hazards
The geographic context for the analysis of cumulative impacts associated with flooding hazards is the area served by Ballona Creek. Cumulative growth and development throughout the area has resulted in the introduction of new structures and impervious surfaces that increased stormwater runoff, leading to increased flood hazards associated with the water levels in Ballona Creek. Future development in the area, including growth anticipated under the General Plan Update and the Zoning Code Update, would be subject to floodplain management and stormwater and urban runoff pollution control ordinances for each jurisdiction that would prevent flooding. For these reasons, the cumulative impact with respect to flooding would be considered less than significant. Therefore, the Project would result in less than significant cumulative impacts related to flood hazards.

4. Environmental Impact Analysis

4.9. Hydrology and Water Quality
General Plan 2045 and Zoning Code Update Project 4.9-40 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.10-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.10 Land Use and Planning

4.10.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on land use and planning from implementation of the Project, including potential impacts related to physically dividing a community and consistency with applicable land use plans. The section provides context regarding the Planning Area’s existing land use pattern, as well as relevant federal, State, and local regulations and programs.

4.10.2 Environmental Setting
Culver City is located in the western part of Los Angeles County in Southern California. The city is surrounded on three sides (north, east, and west) by the City of Los Angeles and to the southeast by an unincorporated area of Los Angeles County, known as Ladera Heights. The city is located approximately 5 miles east of the Pacific Ocean, 5 miles north of Los Angeles International (LAX) Airport, and 8 miles west of downtown Los Angeles. Ballona Creek runs through the city in a south-westerly direction from its origin near Cochrane Avenue and Venice Boulevard in the city of Los Angeles ending at the Pacific Ocean. Regional access to the city is provided via Interstate 405 (I-405), which runs in a north-south direction in the western part of the city, and Interstate 10 (I-10), which runs in an east-west direction just outside the northern boundary of the city. Local access is provided via State Route 90 (SR-90), which intersects the city from the west and ends at Slauson Avenue in the Fox Hills neighborhood. The Metro Expo (E) lines connect the city west to Santa Monica and east to Downtown Los Angeles from the Culver City Station on National Boulevard.

The Planning Area includes the area within the City of Culver City’s jurisdictional boundaries and its Sphere of Influence (SOI), as shown in Figure 4.10-1, Planning Area. The SOI includes land within unincorporated portions of Los Angeles County located adjacent to the city. The SOI is located to the east of the city boundary in the Baldwin Hills area of Los Angeles County, west of La Cienega Boulevard. The Planning Area covers approximately 3,910 acres, of which about 3,280 acres (84 percent) are located within city limits, and approximately 630 acres (16 percent) are located in its SOI. The city is generally divided into 15 neighborhoods as shown on Figure

4.10-2, Planning Area Neighborhoods.

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

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

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

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

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

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

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

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 1
11User Guide Culver City General Plan 2045
Figure 4.10-1
Planning Area
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator Figure 3: Culver City’s Planning Areas/Neighborhoods
Figure 3: Culver City’s Planning Areas/Neighborhoods
Culver City General Plan 2045
Figure 4.10-2
Planning Area Neighborhoods
SOURCE: City of Culver City, 2019; County of Los Angeles, 2019D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 0 0.25 0.5 1
Miles

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Existing Land Use and Overall Pattern
As identified in Table 4.10-1, Existing Land Uses in the Planning Area (2020), the most prevalent land use in Culver City is single-family residential (covering 35.8 percent of land area),1 followed by retail and services (13.5 percent of land area), and civic and institutional, which includes government buildings, schools, healthcare facilities and churches (9.5 percent of land area).

Uses within the SOI include oil field (59.8 percent of land area), parks, recreation, cemeteries, and open space (25.5 percent of land area), and civic and institutional (14.7 percent of land area). In the Planning Area as a whole, the most prevalent land uses are single-family residential (28.8 percent), oil field (13.9 percent), retail and services (10.9 percent), and civic and institutional (10.5 percent). There are approximately 15.6 acres of vacant land in the Planning Area (0.5 percent), all of which are located within the city. Existing land uses within the Planning Area are mapped in Figure 4.10-3, Existing General Plan Land Use Map, and discussed throughout this section.

TABLE 4.10-1
E XISTING LAND USES IN PLANNING AREA (2020)
City of Culver City Sphere of Influence (SOI) Total Planning Area Existing Land Use Category Acres Percent Acres Percent Acres Percent Residential 1,233.8 49.2 0.0 0.0 1,233.8 39.6
Single-Family 898.4 35.8 0.0 0.0 898.4 28.8
Duplex, Triplex, Fourplex 185.5 7.4 0.0 0.0 185.5 6.0
Multi-Family (5+ units) 144.6 5.8 0.0 0.0 144.6 4.6
Mobile Homes 5.3 0.2 0.0 0.0 5.3 0.2
Commercial 594.0 23.7 0.0 0.0 594.0 19.1
Retail and Services 339.2 13.5 0.0 0.0 339.2 10.9
Office 186.5 7.4 0.0 0.0 186.5 6.0
Studios 68.3 2.7 0.0 0.0 68.3 2.2
Oil Field 68.0 2.7 363.9 59.8 431.8 13.9
Civic and Institutional 239.2 9.5 89.5 14.7 328.7 10.5
Parks, Recreation, Cemeteries, Open Space 153.6 6.1 154.8 25.5 308.4 9.9 Cemetery 0.1 0.0 154.8 25.5 154.9 5.0
Parks, Recreation, Open Space3 153.5 6.1 0.0 0.0 153.5 4.9 Industrial 120.2 4.8 0.0 0.0 120.2 3.9
Waterway 74.6 3.0 0.0 0.0 20.6 0.7
Vacant, Utilities, Transportation 20.6 0.8 0.0 0.0 20.6 0.7 Vacant 15.6 0.6 0.0 0.0 15.6 0.5
Utilities, Transportation 5.0 0.2 0.0 0.0 5.0 0.2

1 While single-family residential land use is the most prevalent in the city, there are slightly more multi-family housing units (54 percent) than single-family units (46 percent).

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
City of Culver City Sphere of Influence (SOI) Total Planning Area Existing Land Use Category Acres Percent Acres Percent Acres Percent Mixed Use 4.7 0.2 0.0 0.0 4.7 0.2
Total 2,508.6 100.0 608.2 100.0 3,116.8 100.0
NOTES:
1 Acreage total does not include roadway rights-of-way. 2 Totals may not add due to rounding.
3 Includes acreage of open spaces that are not public parks, such as greenways.

SOURCE: City of Culver City. 2020a. Land Use and Community Design Existing Conditions Report.

Residential
As shown in Table 4.10-1, residential uses are the most prevalent land use in the Planning Area.

Residential uses occupy approximately 1,234 acres, or 39.6 percent, of the Planning Area.

Residential uses, which are all located within the city, consist of single- family; duplex, triplex, and fourplex units; multifamily (5+ units), and mobile home uses. Within the city, single-family uses account for 28.8 percent, duplex/triplex/fourplex uses account for 6 percent, multifamily (5+ units) uses account for 4.6 percent, and mobile home uses account for 0.2 percent.

Single-family residential uses are mostly situated on gridded neighborhood streets within the City. Some neighborhoods, including Park West and Sunkist Park, are almost entirely comprised of single-family homes. Other neighborhoods, including Park East, Studio Village, Clarkdale, and Washington Culver, have a more even mix of single-family and multi-family housing. Multi- family housing in these neighborhoods is generally low density (fewer than approximately 20 dwelling units per acre). The most common multi-family housing types in these neighborhoods are townhomes, duplexes, triplexes, and fourplexes or "dingbats" (two- to three-story stucco apartment buildings with tuck-under parking). Many single-family residences, particularly in the Park East and West neighborhoods, have either stand-alone or above-garage accessory dwelling units (ADUs). ADUs are small housing units built on a property that has a primary residential use.

Housing is also located on regional arterials, including Washington, Venice, and Sepulveda Boulevards. Most of this housing stock is in the form of mixed-use apartment or condominium buildings that are between two and five stories high. Some of these mixed-use buildings have ground-floor commercial uses. The Fox Hills neighborhood has a significant amount of multi- family residential development, particularly along Green Valley Circle, Buckingham Parkway, and Canterbury Drive. Apartments and condominiums in this area are mostly garden or courtyard- style buildings and are usually at least three stories.

GreenValleyCir
Existing
Land Use
°0 0.5 10.25
Miles
Sources:

City of Culver City (2023);
County of Los Angeles (2021);
ESRI (2021).

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Existing Land Use
Single-Family Residential
Duplex, Triplex, Quadplex Residential
Multifamily residential (5+ units)
Mobile Home Park
Mixed Use
Commercial
Industrial
Oil Field
Civic/Institutional
Transportation/Utilities
Parks and Open Space
Cemetery
Agric
ulture/Natural Resources
Vacant
Waterway

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

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 11
100 Element 4Culver City General Plan 2045
Figure 4.10-3
Existing General Plan Land Use Map
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator GreenValleyCir
Existing
Land Use
°0 0.5 10.25
Miles
Sources:

City of Culver City (2023);
County of Los Angeles (2021);
ESRI (2021).

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

SepulvedaBlvd.

OverlandAve.CulverBlvd.

Slauson Ave.

Duquesne Ave.

National Blvd.

Bristol Park w
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

VeniceBlvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

FIGURE 11
100 Element 4

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Commercial
Commercial development occupies 19.1 percent of the Planning Area and is comprised of retail, services, office, and studio uses. Similar to residential uses, all commercial uses are located within the city. Most retail, restaurant, and personal service land uses are located along arterials, including Washington, Jefferson, and Culver Boulevards, and comprise approximately

10.9 percent of the Planning Area. Restaurants, bars, and small-scale retail are concentrated Downtown. Jefferson Boulevard, between Slauson and Overland Avenues, is lined mostly with strip malls and big-box stores set far back from the street. There are two car dealerships located on Washington Boulevard near the intersection with Culver Boulevard. Regional destinations, including the Westfield Culver City shopping mall and hotels, are located near I-405 in the Fox Hills area. Culver City's Costco is another regional draw and is located on Washington Boulevard in the western-most extent of the Planning Area.

Office uses (6 percent of the Planning Area), and studio uses (2.2 percent of the Planning Area) are spread throughout the Planning Area. The biggest concentration of office is in the Fox Hills business park. The most prominent studio use is Sony Pictures Studios, and Amazon Studios will be another prominent studio use once the Culver Studios project has been completed.

Apple, Amazon Studios, and HBO will have offices for their production headquarters in Culver City once construction, currently underway at their respective locations Apple and HBO's headquarters will be in the transit-oriented development (TOD) District and Amazon Studios in Downtown. TikTok offices are also located in Culver Pointe in the Fox Hills neighborhood.

Industrial and Oil Field
Industrial uses cover approximately 4 percent of the Planning Area and include warehouses, and manufacturing in buildings with large footprints. Creative companies, including those in film production, architecture, the arts, and fashion, use many warehouse-like industrial buildings.

Small industrial uses are located in a strip along Jefferson Boulevard between Overland Avenue and Hetzler Road. Many of the developments on these parcels face away from Ballona Creek.

The McManus area has a concentration of industrial uses near the intersection of Washington and La Cienega Boulevards. The most notable industrial district is the Hayden Tract, though the district has been experiencing a conversion to more office/creative office uses in recent years.

The Hayden Tract is home to various creative companies and is known for its contemporary industrial and office buildings designed by architect Eric Owen Moss.

The Inglewood Oil Field (IOF) comprises approximately 13.9 percent of the Planning Area. Of the 432 acres of land operated as an oil field in the Planning Area, about 68 acres or approximately

2.7 percent are within Culver City limits.

Civic/Institutional
Civic and institutional uses are distributed evenly throughout the Planning Area. They include places of worship, public and private schools, libraries, City Hall, police and fire stations, and other public uses. West Los Angeles College is located in the SOI in an unincorporated area of the county. Civic and institutional uses comprise approximately 10.5 percent of the Planning Area.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Parks, Recreation, Cemeteries, and Open Space
Parks, recreational facilities, cemeteries, and open spaces occupy approximately 10 percent of the Planning Area. Parks, recreational facilities, cemeteries, and open spaces occupy approximately 6 percent of land in the city and cemetery use is also located within the SOI.

Cemeteries comprise approximately 5 percent and parks, recreational facilities, and open spaces comprise approximately 5 percent. Parks are distributed throughout the city and are more commonly located in residential neighborhoods with convenient access for Culver City residents.

The biggest park facility in the city is Baldwin Hills, which is owned and managed by the State of California through the Baldwin Hills Conservancy.

Vacant
Vacant land is distributed throughout the Planning Area. The largest cluster of vacant parcels is near the intersection of Jefferson Boulevard and College Boulevard, just south of Culver City Park. Overall, vacant land occupies approximately 0.6 percent of land within the city and

0.5 percent of the Planning Area.

Development Projects
At the time of the preparation of the existing conditions reports, there were approximately 1,550 housing units, 480 hotel rooms, approximately 190,000 square feet of retail, and approximately 1.5 million square feet of office in the city development pipeline. 2 Many low
density (fewer than approximately 12 units) residential projects are infill developments in existing residential neighborhoods
. Higher density residential developments are being
developed along major roadways, Downtown, and in the TOD District near the Metro station.

Examples of higher density multi-family projects include Ivy Station (200 units), Jefferson Park (259 units), a senior housing development on Washington Boulevard (116 units), and 12717 Washington Boulevard (116 units). These projects are in the Lucerne Higuera, Studio Village, Clarkdale, and Culver West neighborhoods, respectively.

The most significant commercial developments are the Entrada office tower, Culver Crossroads, Culver Studios, and Ivy Station. Entrada, a 280,000 square foot office tower, is the most significant non-residential project in the Fox Hills area. Culver Studios will house Amazon Studios and consist of six new buildings containing studios and offices in the Downtown. Ivy Station will consist of retail, restaurants, apartments, a hotel, and offices, including offices for HBO.

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

There are no federal regulations which apply to the Project.

2 City of Culver City. 2020a. Culver City Land Use and Community Design Existing Conditions Report. https://static1.squarespace.com/static/5d950bfaae137b5f0cbd75f5/t/5f936f995f4c6062f85b1d27/16034980318 80/LUECR_Web.pdf. Accessed October 2023.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
State
California Government Code Section 65300
Government Code Sections 65300 states that each planning agency shall prepare, and the legislative body of each county and city shall adopt, a comprehensive, long-term general plan for the physical development of the county or city, and of any land outside its boundaries in which the planning agency’s judgment bears relation to its planning.

California Government Code Sections 65919 to 65919.11
Government Code Sections 65919 to 65919.11 summarize procedures related to interagency referrals for different types of lead agency actions, including general plan updates. Among other referrals, this part of the Government Code provides a procedure and protocols for requesting counties to keep cities informed regarding land use actions within the unincorporated portions of spheres of influences and planning areas.

Sustainable Communities and Climate Protection Act of 2008 (Chapter 728, Statutes of 2008)
The Sustainable Communities and Climate Protection Act of 2008, otherwise known as Senate Bill (SB) 375, requires the integration of land use, housing, and transportation planning to achieve regional greenhouse gas (GHG) emission reductions, adopted by the California Air Resources Board (CARB). SB 375 requires Metropolitan Planning Organizations (MPOs) to develop a Sustainable Communities Strategy (SCS)—an element of the regional transportation plan (RTP)— to plan for achieving these GHG reduction targets. The SCS must demonstrate the attainment of the regional GHG emissions reduction targets while accommodating the full projected population of the region.

Regional
Southern California Association of Governments 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal) The 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS, referred to as Connect SoCal) was adopted in September 2020 by the Southern California Association of Governments’ (SCAG) Regional Council.
3 Connect SoCal is a long-range plan that
guides land use and transportation strategies to increase mobility and achieve more sustainable growth patterns by locating housing, jobs, and transit closer together and increasing investment in transit and complete streets. These investments are targeted in Priority Growth Areas.

Regional Housing Needs Assessment
The Regional Housing Needs Assessment (RHNA) is mandated by State Housing Law as part of the periodic process of updating local housing elements of the General Plan. The RHNA quantifies the need for housing within each jurisdiction during specified planning periods, or cycles. In prior cycles, factors such as household growth and household income distribution were the primary factors considered in determining a jurisdiction’s RHNA allocation. SCAG’s 6th

3 SCAG is currently in the process of updating the RTP/SCS. Since the 2024-2050 RTP/SCS is not yet adopted, the analysis in this section compares the Project to the current RTP/SCS.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Cycle RHNA quantifies the regional need for housing and then allocates the regional need to each jurisdiction for a planning period between October 2021 and October 2029. The 6th Cycle RHNA is focused on existing need (current housing shortages and overcrowding) plus projected growth, which takes into account factors beyond what was used to determine the 2020 RTP/SCS’s projected growth. Therefore, the 6th Cycle RHNA allocation for the City results in a higher allocation of housing than what is represented in the 2020 RTP/SCS, which is focused solely on projected or future growth. For the 6th RHNA Cycle, SCAG considers other factors in addition to household growth. These factors include transit accessibility, job accessibility, and indicators that influence a community’s environmental, educational, and economic resource accessibility.

The final 6th Cycle RHNA methodology and allocations were adopted by the Regional Council on March 4, 2021, approved by HCD on March 22, 2021 and modified on July 1, 2021. As part of the RHNA draft allocations, the City’s allocation of housing between October 2021 and October 2029 is 3,341 units.

Consistent with the state housing law, the primary objectives the 6 th Cycle RHNA allocation plan
are to:
• Increase the housing supply and mix of housing types, tenure and affordability within each region in an equitable manner;
• Promote infill development and socioeconomic equity, the projection of environmental and agricultural resources, and the encouragement of efficient development patterns; • Promote an improved interregional relationship between jobs and housing; • Allocating a lower proportion of housing need in income categories in jurisdictions that have a disproportionately high share in comparison to the county distribution; • Affirmatively furthering fair housing.

Local jurisdictions are required to plan and zone to accommodate their respective RHNA allocation (housing units) by income categories through the process of updating the Housing Elements of their General Plans. Communities use the RHNA in land use planning, prioritizing local resource allocation, and in deciding how to address identified existing and future housing needs resulting from population, employment and housing unit growth. The RHNA does not necessarily encourage or promote growth, but rather allows communities to anticipate growth, so that collectively the region and sub region can grow in ways that enhance quality of life, improve access to jobs, promotes transportation mobility, addresses social equity, and distributes fair share housing needs.

Los Angeles County General Plan
Provisions of the Los Angeles County General Plan, adopted in 2015 with a horizon year of 2035, apply to unincorporated areas of Los Angeles County, including the SOI. The Land Use Element of the County’s General Plan guides future development and revitalization efforts by designating the general distribution, location, and extent of uses on these lands and is the main mechanism for accommodating growth and change in unincorporated areas.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Los Angeles County Subdivision and Zoning Codes (Title 21 and 22) The County’s Zoning Code, Subdivision Code, and zoning map are implementation tools of the General Plan that provide details on allowable uses, design and development standards, and procedures. Zoning and subdivision regulations govern the division, design and use of individual parcels of land, including minimum lot size, lot configuration, access, height restrictions, and yard setbacks standards for structures. These apply to the unincorporated SOI portion of the Planning Area.

Local
Culver City General Plan
State law requires that every city and county prepare and adopt a long-range comprehensive General Plan to guide future development and to identify the community’s environmental, social, and economic goals. By law, a general plan must be an integrated, internally consistent statement of City policies. Government Code Section 65302 requires that a general plan include the following seven elements: Land Use, Circulation, Housing, Conservation, Open Space, Noise, and Safety. Senate Bill (SB) 1000 and Gov. Code, § 65302 require that since disadvantaged communities have been identified within the city, the General Plan must also address Environmental Justice (EJ) either as a standalone element or integrating related goals, policies, and objectives throughout other elements.

The City’s adopted General Plan includes nine elements that have been updated at various points between 1968 and 2014. The City’s General Plan includes the Land Use Element (adopted in 1996 and amended through 2004), the Circulation Element (amended through 1995), the Housing Element (most recently updated in 2022), the Open Space Element (approved in 1996), the Noise Element (approved in 1996), Conservation Element (adopted in 1973), Seismic Safety Element (adopted in 1974), Public Safety Element (adopted in 1975), and Recreation Element (adopted in 1968). The City’s General Plan is the principal land use policy instrument. An update of the General Plan is the proposed Project.

The General Plan Update includes a Community Health and Environmental Justice element.

Additional elements may be included as well, at the discretion of the City. The General Plan Update includes six optional elements: Governance and Leadership; Arts, Culture, and the Creative Economy; Economic Development; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction; and Infrastructure.

Culver City Municipal Code
The Culver City Zoning Code (Title 17 of the Culver City Municipal Code [CCMC]) implements the policies of the General Plan by classifying and regulating the uses of land and structures within the City. The City’s Zoning Code is being updated to be consistent with the proposed General Plan and is a component of the Project being evaluated in this Program EIR.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Culver City Bicycle and Pedestrian Action Plan
The Bicycle and Pedestrian Action Plan was adopted by the City Council in June 2020. 4 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.

Recommendations are also provided for plant palettes and planting structure, places of priority, designations of trees and plants to assist with wayfinding and placemaking, and action areas and strategies to be implemented by the City in public areas. 5 Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan
Culver City and Culver City Unified School District (CCUSD) received a grant to prepare a MJHMP.

The MJHMP presents a strategy for reducing the City's and CCUSD’s vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The MJHMP is a framework that guides the City in making decisions and developing policies to reduce or eliminate risk to life and property. The plan assesses the community’s risks and vulnerabilities to natural hazard events such as earthquakes, flooding, and wildfire. The MJHMP includes a set of goals related to the overall goal of hazard mitigation planning and mitigation measures that will serve to advance the plan goals. The MJHMP was approved by Cal OES and FEMA on June 1, 2017. The MJHMP process has allowed the City to review and expand upon the policies contained in the General Plan’s Safety Element. The City views the General Plan and the MJHMP as complementary planning documents that work together to achieve the ultimate goal of the reduction of risk exposure to residents within the Planning Area. Many of the ongoing recommendations identified in the MJHMP’s mitigation strategy further the goals and policies of the General Plan and other adopted plans.
6 Pursuant to regulatory requirements, the MJHMP is
being updated concurrently with the General Plan Update.

4 Culver City. 2020b. Bicycle and Pedestrian Action Plan. June 2020. https://www.culvercity.org/files/assets/public/ documents/public-works/mobility/2021-10-cc-bikepedplan-app2020-v10-final.pdf. Accessed October 2023 5 Culver City. 2015. Culver City Urban Forest Master Plan. https://www.culvercity.org/files/sharedassets/public/ city-hall/culver_city_urban_forest_master_plan.pdf. Accessed March 2023. 6 Culver City and Culver City Unified School District, 2017. Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/files/assets/public/documents/planning-amp- development/multijurisdictionalhazardm.pdf. Accessed July 2023.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.10.4 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 land use and planning if the project would:

Threshold LU-1: Physically divide an established community; Threshold LU-2: Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Methodology
The policies of the General Plan Update, as represented in the proposed text and land use map, were compared to existing conditions to determine the level of change that would occur with development under the update. The analysis was undertaken at a program level— that is, at a general rather than a parcel-specific level of detail. This approach is consistent with CEQA Guidelines Section 15146(b), which states:

An EIR on a project such as the adoption or amendment of a comprehensive zoning ordinance or a local general plan should focus on the secondary effects that can be expected to follow from the adoption or amendment, but the EIR need not be as detailed as an EIR on the specific construction projects that might follow.

The planning horizon for the General Plan update is 2045. The following analyses generally consider the level of development that may reasonably be expected to occur as a result of the Project through 2045.

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

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The total development potential for 2045 under the General Plan Update would result in increased development of residential units as well as commercial, industrial, and institutional uses, as identified in Table 4.10-2, General Plan 2045 Projections by Land Use.

TABLE 4.10-2
GENERAL PLAN 2045 PROJECTIONS BY LAND USE
Land Use Existing (2019) New
General Plan 2045
Projections
Net Change (General Plan
2045 - Existing)
Residential 17,010 units 12,700 units 29,710 units 12,700 units Commercial 28,624,900 sf 5,968,000sf 31,956,900 sf 3,332,000 sf Industrial 1,881,100 sf 679,700 sf 2,245,900 sf 364,800 sf Institutional 3,076,600 sf 0 sf 3,076,600 sf 0 sf
sf = square feet
a Studio uses, which are a defined General Plan land use designation, are included in the commercial square footage.

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

Project Impact Analysis
Physically Divide a Community
Threshold LU-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would physically divide an established community.

Impact Statement LU-1: The Project would not physically divide an established community.

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

General Plan Update
The Planning Area is an urban environment that is established with land uses at the parcel-level and a circulation system with very limited vacant land. The city is primarily built out with residential uses, of which only 0.6 percent is vacant land. Implementation of the Project would improve connectivity and land use patterns within and between existing neighborhoods, thereby providing more linkages within the city and the region. The General Plan Update provides strategies for thoughtful infill development and redevelopment that range from additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. Infill and redevelopment of existing land uses would occur across many areas of the City, including those areas that would maintain land use designations similar to existing conditions. The General Plan Update includes policies that require new development to be compatible and well-integrated with existing residential neighborhoods, maintaining smooth transitions in scale, form, and character through building setbacks, step backs, and rear landscaping (Policies LU-11.7 and LU-12.1); encourage compatible uses like schools, parks, recreation and community centers, art studios, and childcare facilities in residential neighborhoods (Policies LU-11.8 and LU-13.5); link existing residential neighborhoods by providing pedestrian and bicycle connections (Policies LU-11.9 and LU-13.6); and encouraging coordination with neighborhood associations

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
throughout the City to facilitate community building and neighborhood identity (Policy LU-11.11). These policies would support connectivity within established communities.

The Project would also intensify and result in a mix of land uses on key segments of the commercial corridors, which would improve pedestrian experiences along the City’s commercial corridors. The Project recognizes the physical elements that help define the character of the Planning Area and the city as a whole, including existing residential neighborhoods, activity centers, parks and open space, and commercial corridors. The General Plan Update includes policies that would promote new commercial uses and revitalize existing commercial areas in locations that provide convenient access to a range of goods and services for Culver City’s residential neighborhoods (Policy LU-9.1); and encourage existing strip commercial corridors such as Washington, Sepulveda, and Jefferson Boulevards to intensify with standalone uses, concentrating neighborhood-serving commercial uses into mixed use activity centers (Policy LU-9.2). 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. As such, the Project would not physically divide an established community.

The land use patterns associated with the General Plan Update help 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 areas with mixed-use designations, increase capacity for residential development near community-serving commercial, retail, and office uses as well as schools, parks, and recreational facilities. The Project identifies planned pedestrian, multi-modal, and transit improvements for the city which would improve mobility between neighborhoods and allow residents to travel throughout the city. The General Plan Update includes policies to allow higher residential density and intensity in mixed use developments to support walkability and transit use (Policy LU-1.1); and incentivize jobs and housing growth around high-quality transit stops and along transit corridors (Policy LU-1.3). Policies aim to connect transit-oriented communities through 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 (Policy LU-1.4).Further the General Update would ensure that new project applications foster pedestrian and bicycle access by providing safe, accessible pedestrian connections and creating secure and convenient bike storage (Policy LU-9.5). The General Plan Update also includes policies to create walkable connections in multifamily development (Policy LU-2.6); encourage more variety of public- and neighborhood-serving uses and affordable housing (Policy LU-8.1); and create community gathering spaces in mixed use districts to provide publicly accessible, centrally located private open space (Policy LU-8.2). These policies would encourage connectivity within the neighborhoods as well as throughout the city.

The overall land use pattern would not change under the General Plan Update and the changes focus density in areas that would not result in a division of a community. Therefore, future development allowed under the General Plan Update would not physically divide an established community, and the impact would be less than significant.

4. Environmental Impact Analysis

4.10. Land Use and Planning
General Plan 2045 and Zoning Code Update Project 4.10-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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 permitted and conditional uses, densities and intensities, setbacks, and heights. Therefore, the Zoning Code Update would not physically divide an established community and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Land Use and Community Design Element
LU-1.1: Higher densities near transit. Allow higher residential density and intensity in mixed use developments to support walkability and transit use.

LU-1.3: Development near transit stations. Incentivize jobs and housing growth around high-quality transit stops and along transit corridors to reduce reliance on personal automobiles. Incentivize affordable housing as standalone projects and mixed-income projects within transit-oriented communities.

LU-1.4: Connected 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-2.6: Walkable connections in multifamily development. Encourage new multifamily developers to provide convenient, walkable connections to nearby trails, transit, and open space to promote active lifestyles.
• Place building lobbies adjacent to sidewalks and encourage multiple lobbies in larger projects.
• Locate required bicycle parking at the ground floor and convenient to sidewalk entrances.

LU-8.1: Mix of uses. Encourage more variety of public- and neighborhood- serving uses and affordable housing.

LU-8.2: Gathering spaces. Partner with project developers to create community gathering spaces, including plazas and pocket parks, in mixed use districts. Work with development projects to provide publicly accessible, centrally-located private open space with amenities as part of their site plans.

LU-9.5: Pedestrian and bicycle access to the corridor. Require new project applications to foster pedestrian and bicycle access by providing safe, accessible pedestrian connections and creating secure and convenient bike storage.

LU-11.8: Neighborhood compatible uses. Encourage compatible uses like schools, parks, recreation and community centers, art studios, and childcare facilities in residential neighborhoods.

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

LU-11.11: Neighborhood associations. Work with neighborhood associations throughout Culver City to facilitate community building and neighborhood identity.

LU-13.5: Neighborhood compatible uses. Encourage compatible uses like schools, parks, recreation and community centers, art studios, and childcare facilities in multifamily residential neighborhoods. Allow limited neighborhood-supportive retail and service uses in existing residential neighborhoods on collector and arterial street types to promote complete, walkable neighborhoods.

LU-13.6: Pedestrian and bicycle connectivity in residential neighborhoods. Link existing residential neighborhoods by providing pedestrian and bicycle connections.

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 physically dividing an established community.

Consistency with Applicable Land Use Plans
Threshold LU-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update caused a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

Impact Statement LU-2: The Project would not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

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

General Plan Update
The proposed General Plan Update is intended to provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its SOI, through the planning horizon year of 2045. Implementation of the Project is anticipated to result in a net increase of 12,700 residential units, 3,332,000 square feet of commercial uses, and 364,800 square feet of industrial uses within the city. Changes in buildout capacity that would result from implementation of the General Plan Update are largely due to intensification of land uses expected within the Planning Area resulting from infill development and redevelopment.

The land use pattern established in the General Plan Update through the 2045 planning horizon year aims to allow residents to live close to where they work, shop, and recreate, thereby reducing vehicle trips and associated energy consumption, pollution, noise, and greenhouse gas emissions. This land use development pattern could improve human health and increase social interaction by encouraging walking, biking, and transit use. The following provides a consistency

4. Environmental Impact Analysis

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analysis of the General Plan Update with applicable state and regional laws, regulations, plans, and guidelines.

State Planning Law
The General Plan Update is consistent with California Government Code Section 65302 as it contains the required elements including: Land Use and Community Design, Housing, Mobility (‘Circulation’ in the code), Conservation, Safety, Environmental Justice, and Noise. The 2021- 2029 Housing Element of the City's General Plan was adopted in 2022. The General Plan Update also includes six optional elements: Governance and Leadership; Arts, Culture, and Creative Economy; Economic Development; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction; and Infrastructure. The Project revises the General Plan Land Use Diagram, implements the Housing Element, and guides the overall physical development and circulation of the Planning Area through horizon year 2045. The General Plan Update contains policies to guide decision-making related to land use and community character; equity, community health and environment; public safety; housing; mobility; parks and recreation; infrastructure; greenhouse gas reduction; conservation; safety; and noise.

Land uses proposed within the Planning Area can be broken down into four main categories of development: activity centers, commercial corridors, residential neighborhoods, and parks/open space. The Land Use and Community Design Element includes goals and policies that support the City’s land use approach and vision.

Each of the specific and applicable requirements in the state planning law (Government Code § 65300) have been examined and considered to determine if there are environmental issues that the General Plan should address, such as fire hazards and flooding. The various environmental issues associated with the General Plan Update (air quality, hazards, flooding, traffic, etc.) are addressed in their respective topical sections in Chapter 4, Environmental Analysis, of this Draft PEIR. The General Plan Update would not conflict with the State Planning Law.

SCAG 2020 RTP/SCS
SCAG’s 2020 RTP/SCS contains goals that are applicable to the Project, which are discussed below. Table 4.10-3, Consistency of the Project with Applicable Goals of the 2020 RTP/SCS, provides a detailed consistency analysis of the Project with applicable 2020 RTP/SCS goals.

TABLE 4.10-3
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF THE 2020 RTP/SCS Goal Analysis of Proposed Project Consistency

1. Encourage regional economic prosperity
and global competitiveness.

Consistent. This goal pertains to SCAG funding and policies. The Project would not adversely affect the capacity to encourage regional economic prosperity and global competitiveness. The Project would support the goal as it aims to support a diversified, adaptable, and sustainable economy with a balance of small and large businesses across a range of uses that provide employment and commercial opportunities. The Project would not conflict with this goal.

4. Environmental Impact Analysis

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Goal Analysis of Proposed Project Consistency

2. Improve mobility, accessibility, reliability,
and travel safety for people and goods.

Consistent. The General Plan Update includes a Mobility Element which establishes a policy framework and proposed citywide network for all transportation modes and provides the Mobility Plan, which establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi-modal circulation.

The Project has adapted Multimodal Street Classification principles to transition from a highway-centric functional classification system to better integrate land use context and non-motorized transportation components in the transportation network. The Project includes modal priority and special roadway designation typologies that enable the reallocation of public rights-of-way to promote and encourage safe use of alternative transportation modes. The Mobility Element also designates truck routes in order to facilitate goods movements while minimizing travel through residential streets. As such, the Project would be consistent with this goal.

3. Enhance the preservation, security, and
resilience of the regional transportation
system.

Consistent. The Project includes adapted Multimodal Street Classification principles to transition from a highway-centric functional classification system to better integrate land use context and non-motorized transportation components in the transportation network. The Project includes modal priority and special roadway designation typologies that enable the reallocation of public right-of- way to promote and encourage safe use of alternative transportation modes. The Project does not include policies or goals that would adversely affect the regional transportation system.

4. Increase person and goods movement and
travel choices within the transportation
system.

Consistent. As described above, the General Plan Update includes a Mobility Element which establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi- modal circulation. The Project includes modal priority and special roadway designation typologies that enable the reallocation of public rights-of-way to promote and encourage safe use of alternative transportation modes. The Mobility Element also designates truck routes in order to facilitate goods movements while minimizing travel through residential streets.

5. Reduce greenhouse gas emissions and
improve air quality.

Consistent. The Greenhouse Gas Reduction Element includes goals and policies that address sustainability including greenhouse gas emissions, landfill disposal, water efficiency, and transportation.

This element also includes goals and policies related to adaptation and resiliency planning. As part of this element, a GHG emissions inventory was prepared in 2019 in order to track the City’s GHG emissions, set a baseline, and identify reductions needed to align with Statewide targets. The Greenhouse Gas Reduction Element of the General Plan Update includes goals designed to reach carbon neutrality, decarbonize the transportation sector, develop green buildings, develop energy efficient buildings and facilities, achieve zero waste. Specific General Plan Update policies that would be consistent with this goal include updates to the community and municipal GHG inventories every five years to track progress toward achieving the City’s GHG reduction goal (Policy GHG-1.1); GHG reduction measures (Policy GHG-1.2); evaluation of new and emerging technology changes that can help to reduce GHG emissions (Policy GHG-1.3); and initiate or support legislation and regulations designed to establish achievable targets and to fund programs that ensure that all cities can achieve their GHG reduction goals (Policy GHG-1.5).See Section 4.7, Greenhouse Gas
Emissions, for further discussion.

4. Environmental Impact Analysis

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Goal Analysis of Proposed Project Consistency

6. Support healthy and equitable
communities.

Consistent. The General Plan Update includes an update to the Mobility Element. The policies and actions in the Mobility Element prioritize improvements that seek to increase physical activity and improve access to healthcare and social services, schools, employment, and healthy foods. The Project helps to operationalize equity indicators within priority implementation and funding decisions to ensure that future investments address gaps in underinvested areas and for the most vulnerable users of the network. It also highlights targeted investments in SB 1000 Priority Neighborhoods, such as high frequency transit service and pedestrian safety projects at major intersections, to improve transit efficiency and reliability, create safer pedestrian environments to promote walking, and expand first- and last-mile
mobility options near key commercial
areas.

The General Plan Update also includes an update to the Parks, Recreation, and Public Facilities Element, which includes goals and policies related to improvements the City can undertake to improve access, amenities, and funding for the park and recreational resources within the city. The Parks and Recreation Element establishes policies to reduce inequities for residences within one half mile walking distance of a park or recreational facility, plans for parks and other outdoor recreational spaces in these neighborhoods, and establishes a performance metric to track the percent of population within walking distance of a park. The Project would provide goals and policies as well as direct resources to improve park and recreational resource quantity, quality, and access.

7. Adapt to changing climate and support an
integrated regional development pattern
and transportation network.

Consistent. The Project includes modal priority and special roadway designation typologies that enable the reallocation of public rights-of- way to promote and encourage safe use of alternative transportation modes. Accessibility to alternative transportation modes would support this goal that encourages adaptation to changing climate. In addition, the Mobility Element establishes a policy framework and proposed citywide network for all transportation modes and provides the Mobility Plan, which establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi- modal circulation.

8. Leverage new transportation technologies
and data-driven solutions that result in
more efficient travel.

Consistent. This goal pertains to SCAG leveraging new
transportation technologies and data-driven solutions that result in more efficient travel. The Project would not adversely affect SCAG’s ability to develop more efficient travel consistent with this goal.

9. Encourage development of diverse
housing types in areas that are supported
by multiple transportation options.

Consistent. The Housing Element of the City's General Plan is the primary planning tool to meet the housing needs of Culver City. It outlines goals, policies, and programs to meet these needs while balancing other community objectives and resources. While the Housing Element was adopted in 2022, the General Plan Update serves as the implementation mechanism for the Housing Element through the amendments to the Land Use Map, which would support the City’s efforts to meet the State-mandated RHNA. The RHNA allocation for the City during the 2021-2029 planning period is 3,341 units. The Project would provided for 12,700 additional housing units at buildout.

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

4. Environmental Impact Analysis

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Goal Analysis of Proposed Project Consistency
experiences along the City’s commercial corridors through parking management strategies, and public realm improvements.

The Mobility Element establishes a policy framework and proposed citywide network for all transportation modes and provides the Mobility Plan, which establishes the future mobility framework for the City including vehicular, transit, pedestrian, bicycle, and multi-modal circulation.

10. Promote conservation of natural and
agricultural lands and restoration of
habitats.

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

SOURCE: ESA, 2023.

As shown in Table 4.10-3, the Project would be consistent with 2020 RTP/SCS goals to encourage economic prosperity; improve mobility, accessibility, reliability, and travel safety; enhance the preservation security, and resilience of the regional transportation system; increase the productivity of the transportation system, reduce GHG emissions and improvement of air quality; support healthy and equitable communities; adapt to climate change and support an integrated regional development pattern; leverage new transportation technologies and data driven solutions that result in more efficient travel; encourage development of diverse housing types; and promote conservation of natural and agricultural lands and restoration of habitats.

Therefore, the Project would result in a less than significant impact with regard to consistency with the 2020 RTP/SCS.

Similar to supporting the goals of the 2020 RTP/SCS, the General Plan Update supports SB 743 which promotes the State’s goals of reducing greenhouse gas emissions and traffic-related air pollution, promoting the development of a multimodal transportation system, and providing clean, efficient access to destinations, by increasing connectivity within the city. The General Plan Update aims to increase sustainability through the land use development pattern. Growth would be distributed along corridors, and future development that would occur under the Project would be predominantly located on infill sites within transit priority corridors, or in areas well served by transit. Furthermore, the General Plan Update includes the Greenhouse Gas Reduction Element which includes goals and policies that address sustainability including greenhouse gas emissions, landfill disposal, water efficiency, and transportation. This element also includes goals and policies related to adaptation and resiliency planning. By designating land uses in a way that encourages higher density within transit areas, the Project would support sustainability within the City.

California Complete Streets Act Consistency
The General Plan Update includes policies that support the City’s efforts to implement the Complete Streets Act (AB 1358). (See Section 4.16, Transportation, for a discussion regarding the Complete Streets Act.) Specifically, Land Use Element Policy LU-7.2 and Mobility Element Policy

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M-2.1 include measures to prioritize walking and biking by breaking up large blocks into a finer grained network and through complete streets improvements and guide project selection and delivery based on complete streets principals. Refer to Section 4.16, Transportation, for a detailed discussion of the proposed project’s consistency with AB 1358.

Regional Housing Needs Assessment
The City recently adopted the 2021-2029 Housing Element Update, which is one of the State- mandated elements that must be included in the General Plan. State law stipulates that the Housing Element include certain items, such as a Housing Needs Assessment; goals, policies, and objectives regarding housing in City; and implementation programs to work toward achieving those goals. For the 6th Cycle Housing Element planning period of 2021 to 2029, the City received a RHNA allocation of 3,341 units. Per State mandate, the City must zone sufficient land for housing affordable to people at all income levels. The General Plan Update includes the land use and zoning amendments necessary to allow for the development of the residential units needed to meet the City’s 6
th cycle RHNA allocation. As such, the Project would designate land so as to meet the City’s RHNA housing allocation and would not conflict with the RHNA.

Culver City and Culver City Unified School District (CCUSD) Multi-Jurisdictional Hazard Mitigation Plan
The MJHMP presents a strategy for reducing the City's and CCUSD’s vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. The MJHMP is a framework that guides the City in making decisions and developing policies to reduce or eliminate risk to life and property. The plan assesses the community’s risks and vulnerabilities to natural hazard events such as earthquakes, flooding, and wildfire. The MJHMP includes a set of goals related to the overall goal of hazard mitigation planning and mitigation measures that will serve to advance the plan goals. The General Plan and the MJHMP are complementary planning documents that together achieve the goal of the reduction of risk exposure to residents within the Planning Area. Many of the ongoing recommendations identified in the MJHMP’s mitigation strategy further the goals and policies of the General Plan and other adopted plans. Pursuant to regulatory requirements, the MJHMP is being updated concurrently with the General Plan Update.

The General Plan Update contains policies that aim to update emergency-related planning documents (including the MJHMP) every five years to ensure consistency with State and federal law, best practices, local conditions, and recent science (Policy S-1.1); continuing to incorporate the hazards and mitigation measures identified in the MJHMP into City emergency planning, capital projects, and programs (Policy S-1.2); continuing to develop and maintain an evacuation plan for the City to effectively communicate protocols to residents, distribute evacuation notices, and ensure that all transportation modes can effectively execute their evacuations (Policy S-1.3); and requiring all development proposals to identify existing evacuation routes or establish new evacuation routes as needed (Policy S-7.14). As such, the General Plan Update would not conflict with the MJHMP.

4. Environmental Impact Analysis

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Culver City Bicycle & Pedestrian Action Plan
The Culver City Bicycle & Pedestrian Action Plan (BPAP) establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The BPAP aims to provide a safe, convenient, and accessible active transportation network. The BPAP 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. The General Plan Update includes policies to develop strong pedestrian and bicycle connections to and from transit stops via pedestrian-oriented building design, safe and convenient road crossings, and street furniture and amenities (Policy LU-1.4); require new project applications to foster pedestrian and bicycle access by providing safe, accessible pedestrian connections and creating secure and convenient bike storage (Policy LU-9.5); and link existing residential neighborhoods by providing pedestrian and bicycle connections (Policies LU-11.9 and LU-13.6), which would support the BPAP.

Furthermore, the General Plan Update includes Policy M-2.1 which would guide project selection and delivery based on complete streets principals and addressing the gaps identified by Bicycle Network Assessment Areas, the BPAP, and American with Disabilities (ADA) Transition Plan, and Policy M-8.5 which aims to align with the BPAP and expand the network recommendations as needed to facilitate a complete and interconnected citywide active transportation network. The Project would support and not conflict with the existing and planned bicycle and pedestrian networks identified in the BPAP.

Culver City Urban Forest Master Plan
The Culver City Urban Forest Master Plan (UFMP) is a comprehensive long-term management plan that includes designations of tree species to be planted on each street segment when an existing tree must be removed, and best management practices for tree planning, preservation, and maintenance. The UFMP includes recommendations for green connections throughout the City to encourage recreation, walking, biking and public transit use to be implemented by the City. The General Plan Update includes implementation action to develop parks that sustain and urban forest and ensure updates to the UFMP. The General Plan Update would not conflict with objectives of the UFMP.

In summary, based on the above the General Plan Update would not conflict with applicable land use plans, policies, or regulations adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the Project would result in a less than significant impact.

Zoning Code Update
The Zoning Code Update is the mechanism to implement the land use changes proposed in the City’s General Plan Update that will encourage development through the planning horizon. The proposed Zoning Code Update would provide the specific regulations, development standards, and performance criteria to govern development on individual properties as required by State law [Government Code Section 65860(a)]. Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect and impacts would be less than significant.

4. Environmental Impact Analysis

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Applicable Proposed General Plan Goals and Policies
Land Use and Community Design Element
LU-1.4: Connected 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-7.2: Walkable streets in Fox Hills. Prioritize walking and biking by breaking up large blocks into a finer grained network and through complete streets improvements.

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

LU-13.6: Pedestrian and bicycle connectivity in residential neighborhoods. Link existing residential neighborhoods by providing pedestrian and bicycle connections.

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-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.

S-7.14: Evacuation routes. Require all development proposals to identify evacuation routes or establish new evacuation routes as needed.

Mitigation Measures
No mitigation measures are required.

4. Environmental Impact Analysis

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Level of Significance After Mitigation
Not applicable. The Project would result in less than significant impacts related to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

4.10.5 Cumulative Impacts Analysis
The geographic context for the analysis of cumulative impacts associated with land use issues is the western area of Los Angeles County, which assumes full build-out of the General Plan Update, in combination with build-out of neighboring jurisdictions’ General Plans. Future development in the area, including growth anticipated under the proposed General Plan Update, would not physically divide an established community or conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, as future development in each jurisdiction would be required to be consistent with each jurisdiction’s General Plan and zoning code. In addition, future development in the western area of Los Angeles County would be required to be consistent with regional plans such as SCAG’s Connect SoCal Plan and the RHNA. Finally, future development in the area would be required to undergo planning review in the respective jurisdiction, which would ensure the future development would not divide an established community and would be consistent with applicable land use plans, policy, or regulation. For these reasons, future development in the western area of Los Angeles County, including growth anticipated under the General Plan Update, would have a less-than-significant cumulative impact with respect to land use and planning. The Project would result in less than significant cumulative impacts related to physically dividing an established community and conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.

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4.11 Mineral Resources

4.11.1 Introduction
This section of the Draft PEIR evaluates potential local and regional environmental impacts on mineral resources in the Planning Area from implementation of the Project, including potential impacts related to known mineral resources and locally important mineral resource recovery sites. The section provides context regarding the Planning Area’s existing mineral resources, including oil resources, as well as relevant federal, State, and local regulations and programs.

4.11.2 Environmental Setting
Since the California Environmental Quality Act (CEQA) does not specifically define mineral resources, the definition of mineral resource from the Department of Conservation, State Mining and Geology Board, United States Bureau of Mines, and United States Geological Survey is used for this Draft PEIR. These agencies define mineral resources as “a concentration of naturally occurring solid, liquid, or gaseous material in or on the Earth’s crust in such form and amount that economic extraction of a commodity from the concentration is currently or potentially feasible.”
1 As such, both non-fuel mineral resources (e.g., aggregate – sand or gravel) as well as petroleum resources are discussed in this section.

Existing Geologic Setting
As described in Section 4.6, Geology and Soils, the Planning Area is located within the Peninsular Ranges Geomorphic Province and Los Angeles Basin. The Los Angeles Basin is bound by the Palos Verdes fault to the south; the San Gabriel Foothill fault to the north; the Santa Ana Mountains and San Joaquin Hills to the east and southeast; and the Santa Monica Mountains to the northwest. 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 -
age marine sedimentary
rocks and younger Tertiary-a
ge rocks comprised of volcanic, marine, and non-ma
rine 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. The elevations vary from a low of 40 feet above mean sea level (amsl) in the western portion of the Planning Area, approximately 100 feet amsl in the central part, to approximately 400 feet amsl in the eastern portion in Baldwin Hills. 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

1 United States Bureau of Mines, Principles of a Resource/Reserve Classification for Minerals. Available at:
https://pubs.usgs.gov/circ/1980/0831/report.pdf. Accessed May 2023.

4. Environmental Impact Analysis

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southern portion. Lastly, landslide debris (Qls) and Inglewood Formation deposits (Qi) are also found within the northeastern portion of the city.

The Planning Area, which includes the City and the Sphere of Influence (SOI), also includes oil and gas resources within the Inglewood Oil Field (IOF), discussed in more detail below.

Aggregate Material Resources (Sand and Gravel)
Construction aggregate is California’s primary mineral resource. As required by the Surface Mining and Reclamation Act (SMARA) of 1975, the California Geological Survey (CGS) defines several geographic areas that collectively cover a single mineral classification study area as “Production- Consumption Regions” (P-C Regions). The CGS identifies Mineral Resource Zones (MRZs) for each P-C Region, mine/quarry, or other geographic area included in a mineral classification study. MRZs are areas classified by the presence or absence of significant sand, gravel, or stone deposits that are suitable as sources of aggregate, as described in greater detail below:
• MRZ-1: Areas where available geologic information indicates there is little or no likelihood for presence of significant mineral resources.
• MRZ-2: Areas where available geologic information indicates that significant measured or indicated resources are present or where adequate information indicates that significant mineral deposits are present or where it is judged that a high likelihood for their presence exists.
• MRZ-3: Areas where available geologic information indicates known or inferred mineral occurrences of undetermined mineral resource significance. • MRZ-4: Areas of no known mineral occurrences where geologic information does not rule out the presence or absence of significant mineral resources.

As shown on Figure 4.11-1, Mineral Resources Zones (MRZs) within the Planning Area, the majority of the Planning Area is identified as MRZ-3 due to areas containing known or inferred Portland cement concrete aggregate resource of undetermined mineral resource significance. 2 In addition, areas of MRZ-1 have been identified in parts of the northern, southern, and western portions of the Planning Area, where available geologic information indicates that little likelihood exists for the presence of significant Portland cement concrete aggregate resources. 3

2 California Geological Survey (CGS), 2021. Updated Mineral Resource Zones for Portland Cement Concrete Aggregate in the San Fernando Valley and Saugus-Newhall Production-Consumption Regions. Available at:
https://www.conservation.ca.gov/cgs/Documents/Publications/Special-Reports/SR_254-MLC- SanFernandoValleySaugusNewhallPCR-2021-Plate01-MRZs-a11y.pdf. Accessed May 2023. 3 CGS, 2021. Updated Mineral Resource Zones for Portland Cement Concrete Aggregate in the San Fernando Valley and Saugus-Newhall Production-Consumption Regions. Available at:
https://www.conservation.ca.gov/cgs/Documents/Publications/Special-Reports/SR_254-MLC- SanFernandoValleySaugusNewhallPCR-2021-Plate01-MRZs-a11y.pdf. Accessed May 2023 °0 1 20.5
Miles
Sources: City of Culver City (2021); CGS(2021); ESRI (2021).

City Limits
Sphere of Influence
City, Incorporated
!( City
Mineral Resource Zone
MRZ-1
MRZ-3
#
°0 1 20.5
Miles
Sources: City of Culver City (2021); CGS(2021); ESRI (2021).

City Limits
Sphere of Influence
City, Incorporated
!( City
Mineral Resource Zone
MRZ-1
MRZ-3
#
Culver City General Plan 2045
Figure 4.11-1
Mineral Resources Zones (MRZs) 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

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Based on a review of the information contained in the California Department of Conservation (CDC), Office of Mine Reclamation (OMR) database, there are no aggregate mines or other identified mineral resources (e.g., shale, diatomite, clay or gypsum) mines within the Planning Area.
4 Oil and Gas Resources
The Inglewood Oil Field (IOF), which is one of the largest urban oil fields in the nation and has been in continuous operation since 1924, straddles Culver City and the unincorporated area of Los Angeles County known as Baldwin Hills. Figure 4.11-2, Inglewood Oil Field Context Map, shows the general location of IOF, with the surface field and mineral rights boundaries as defined by the Oil Field Operator, and the productive field limits and field boundary as defined by the California Energy Management Division (CalGEM).
5 Based on the Surface Field
Boundaries, the IOF encompasses approximately 1,000 acres, with roughly 80 acres within the limits of Culver City and the remaining 920 acres within unincorporated Los Angeles County, of which approximately 400 acres are located within the SOI.6 The IOF is located within the eastern portion of the Planning Area and is currently designated as open space in the Culver City General Plan, as shown on Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description. In 2008, the Los Angeles County Board of Supervisors adopted the Baldwin Hills Community Standards District (BHCSD), which established the oil and gas regulations for operation of the County’s portion of the IOF within the unincorporated area just easterly of and adjacent to Culver City.

According to the California State Oil and Gas Supervisor 2020 Annual Report, the entire IOF produced approximately 1,530,112 barrels of oil and condensate and 791,995,000 cubic feet of gross gas in 2020.
7 No new wells have been drilled within the IOF since 2014 and current operations consist of oil and gas extraction, produced water injection, routine well and facility maintenance, and periodic well plugging and abandonment. 8 4 California Department of Conservation, Office of Mine Reclamation (OMR), 2016. Mines Online Database – Culver City. Available at: https://maps.conservation.ca.gov/mol/index.html. Accessed May 2023. 5 Culver City, 2017a. Inglewood Oil Field Specific Plan. Available at:
https://www.culvercity.org/files/assets/public/v/1/documents/city-manager/inglewood-oil-field/environmental- review-process/b1specificplan.pdf. Accessed December 2023. 6 R eferences to the portion of the IOF in the Planning Area includes the combined portions of the IOF in the City and SOI. Otherwise, specific portions of the IOF will be identified as necessary to provide clarity to the reader. 7 California Geologic Energy Management Division (CalGEM), 2020. California State Oil and Gas Supervisor 2020 Annual Report. Available at: CALIFORNIA STATE OIL AND GAS SUPERVISOR ANNUAL REPORT 2020. Accessed December 2023.
8 Culver City, 2017b. Inglewood Oil Field Specific Plan Project Draft Environmental Impact Report. Available at:
https://www.culvercity.org/files/assets/public/v/1/documents/city-manager/inglewood-oil-field/environmental- review-process/toc091117.pdf. Accessed December 2023.

County of Los Angeles
City of Culver City
City of Culver City
City of Los Angeles
County of
Los Angeles
City of
Los Angeles
County of
Los Angeles
City of Los Angeles
City of Culver City County of
Los Angeles
City of Los Angeles
City of
Los Angeles
FIGURE
Source(s): Google Earth Aerial (02-2016); DOGGR (2016); City of Culver City (2016); Planning PLUS/P+ (2017). 0 0.5 1 Miles
Inglewood Oil Field Specific Plan
o 3
Inglewood Oil Field
Context Map
Field Boundary (DOGGR)
Productive Field Limit Boundary (DOGGR)
Inglewood Oil Field Limit Component
NOTE:

County CSD EIR = Los Angeles County Baldwin Hills Community Standards District, Environmental Impact Report (2008).

DOGGR = California Division of Oil, Gas and Geothermal Resources. All Inglewood Oil Field limit boundaries are approximate and subject to change.

Surface Field Boundary (County CSD EIR)
City/County Limit
Mineral Lease Boundary (DOGGR)
Specific Plan Area Boundary
Culver City Sphere of Influence (SOI) Boundary
Culver City General Plan 2045
Figure 4.11-2
Inglewood Oil Field Context Map
SOURCE: Google Earth Aerial, 02-2016; DOGGR, 2016;
City of Culver City, 2016; Planning PLUS/P+, 2017D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 0 0.5
MilesN

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Ongoing Inglewood Oil Field Closure Settlement
The City Council initiated preparation of an amortization study in 2017 to evaluate and financially and factually support ending oil and gas extraction activities within the approximately 80-acre portion of the IOF within the City. As a result of the information learned through the completed amortization study, in concert with other community safety considerations, in October 2021, the City adopted an Oil Termination Ordinance (Zoning Code amendment P2021- 0036-ZCA) to implement an amortization program that would terminate and phase out nonconforming oil and gas activities within the Culver City portion of the IOF by November 24, 2026. On November 14, 2022, the City Council approved a settlement framework with the operator of the Culver City portion of the IOF that requires the operator to plug and abandon all wells and complete the overall closure of the City’s portion of the IOF by December 31, 2029, with the potential for an extension to December 21, 2032 under special circumstances.

Similar to the City, the County adopted an Oil Well Ordinance for unincorporated areas of the County on June 8, 2022, which amended Title 22, Planning and Zoning of the Los Angeles County Code, to prohibit new oil wells and production facilities in all zones, designates existing oil wells and production facilities as nonconforming uses in all zones, and establishes regulations for existing oil wells and production facilities. While the County’s Oil Well Ordinance originally did not apply to the BHCSD, specific plans, or uses operating under a valid discretionary permit 9, in
July 2023, the County released draft language for a proposed amendment to the BHCSD that would effectively prohibit any new drilling, redrilling or deepening within the County’s portion of the IOF and establish oil and gas activities as a nonconforming use. 10 4.11.3 Regulatory Framework
This section provides the relevant State, regional, and local regulations applicable to the Project.

There are no federal regulations which apply to the Project.

State
California Department of Conservation Geologic Energy Management Division Effective January 1, 2020, the California Department of Conservation's Division of Oil, Gas, and Geothermal Resources (DOGGR) was renamed to the Geologic Energy Management Division (also known as CalGEM) along with a new focus at assisting the State’s goal of becoming carbon- neutral by 2045 by managing the decline of oil production and consumption within the state. To support this goal, CalGEM has established a series of initiatives to safeguard public health, emphasize environmental protection, and reduce climate impacts associated with oil production.

9 Los Angeles County, Department of Regional Planning, 2023b. Oil Well Ordinance. Available at:
https://planning.lacounty.gov/long-range-planning/oil-well-ordinance/. Accessed May 2023. 10 Los Angeles County, Department of Regional Planning. 2023a. Baldwin Hills Community Standards District.

Available at: Baldwin Hills CSD - LA County Planning. Accessed December 2023.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Surface Mining and Reclamation Act
The Surface Mining and Reclamation Act (SMARA) of 1975 provides comprehensive surface mining and reclamation policy with the regulation of surface mining operations to assure adverse environmental impacts are minimized and mined lands are reclaimed to a usable condition. SMARA also encourages the production, conservation, and protection of the state’s mineral resources. As required by SMARA, the State Geologist is to classify land into MRZs according to its known or inferred mineral potential. One of the goals of mineral land classification is to ensure that mineral potential of land is identified and considered before local government decision makers make land use decisions that could limit the ability to mine resources.

Mineral Resources and Mineral Hazard Mapping Program
CGS provides geologic expertise and information about California’s diverse non-fuel mineral resources. As required by the SMARA of 1975, the State Geologist classifies these resources in an effort to locate economically significant mineral deposits and potential areas of deposits based upon scientific data. Information relating to California’s non-fuel resources, naturally occurring mineral hazards, and active and historic mining activities are collected to classify land under the Mineral Resources and Mineral Hazards Mapping Program. As described above, CGS defines several geographic areas that collectively cover a single mineral classification study as P- C Regions. CGS identifies MRZs for each P-C Region, mine/quarry, or other geographic area included in a mineral classification study. MRZs are areas classified by the presence or absence of significant sand, gravel, or stone deposits which are suitable as sources of aggregate.

Regional
Los Angeles County General Plan
Provisions of the Los Angeles County General Plan apply to unincorporated areas of Los Angeles County, including the SOI for Culver City analyzed in this PEIR.

Los Angeles County – Baldwin Hills Community Standards District On October 28, 2008, the County’s Board of Supervisors adopted the Baldwin Hills Community Standards District (BHCSD) and certified the associated Environmental Impact Report. The BHCSD establishes development standards and operating procedures for oil and gas operations in the unincorporated County portion of the IOF, which includes approximately 900 acres and over 700 wells. The BHCSD ensures that oil field operations are conducted in a safe manner and are compatible with the surrounding uses, including uses within Culver City and the City’s portion of the IOF. The County is currently in the process of amending the BHCSD to effectively prohibit any new drilling, redrilling or deepening within the County’s portion of the IOF and establish oil and gas activities as a nonconforming use.11

11 Los Angeles County, Long Range Planning Department, 2023a. Baldwin Hills Community Standards District Amendment Website. Available at: Baldwin Hills CSD - LA County Planning. Accessed December 2023.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Los Angeles County Municipal Code
Chapter 23.310, Baldwin Hills Community Standards District, of the Los Angeles County Municipal Code (LACMC) contains the regulations, safeguards, and controls for activities related to drilling for and production of oil and gas within the oil field located in the Baldwin Hills area of the unincorporated County, including that portion of the IOF that is within the City SOI. The LACMC establishes these supplemental regulations to ensure that oil field operations are conducted in a manner compatible with surrounding land uses, to minimize the potential adverse impacts of such operations, and to enhance the appearance of the site with landscaping and other property maintenance requirements.

Local
Culver City Municipal Code
Chapter 11.12, Oil, Gas, and Hydrocarbons, of the Culver City Municipal Code (CCMC) establishes the permit, operations, and other requirements related to oil, natural gas, and hydrocarbons production within the City. . As discussed above, the Oil Termination Ordinance (CCMC Section 17.610.D) requires that all nonconforming oil uses, regardless of the applicable zoning district or whether an oil use was previously lawfully established or permitted, shall be terminated and be discontinued. In addition, the Oil Termination Ordinance prohibits establishing any new or expanded oil and gas activities after November 24, 2021.

4.11.4 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 mineral resources if the project would:

Threshold MIN-1: Result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.

Threshold MIN-2: Result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

Methodology
This evaluation of mineral resources, including oil and gas, within the Planning Area that could potentially be impacted by the Project was completed using published geologic and soils maps and information from CGS and Los Angeles County. Using these resources, potential impacts were analyzed according to the Project’s potential to result in the loss of available known mineral resources.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Project Impact Analysis
Known Mineral Resource, Locally Important Mineral Resource Recovery Site Threshold MIN-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would result in the loss of availability of a known mineral resource that would be of value to the region and the residents of the state.

Threshold MIN-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would result in the loss of availability of a locally important mineral resource recovery site delineated on a local general plan, specific plan or other land use plan.

Impact Statement MIN-1 and MIN-2: Since the Planning Area is not within an identified MRZ for significant mineral resources, future growth resulting from implementation of the Project would not impact regionally important aggregate material resources. In addition, the Project would not change the land use designation resulting in future development within the City’s portion of the IOF and thus, would not result in the loss of the regionally or locally important oil and gas resources. Therefore, impacts to mineral resources would be less than significant.

General Plan Update
Aggregate Material Resources
As discussed under Section 4.11.2, Environmental Setting, the Planning Area contains areas designated MRZ-1 and MRZ-3. MRZ-1 indicates that no significant mineral resources are present or it is judged that little likelihood exists for their presence and MRZ-3 indicates a mineral resource zone where the significance of mineral deposits cannot be determined from the available data. In addition, the Planning Area is not known to contain sand or gravel deposits of any economic importance or any otherwise “classified” non-fuel mineral deposits under SMARA.

Based on information contained in the OMR database, there are no aggregate or other mineral resource (shale, diatomite, clay or gypsum) mines within the Planning Area12. Therefore, implementation of the General Plan Update would not result in the loss of availability of a known non-fuel mineral resource that would be of value to the region and residents of the State, nor would it create the loss of availability of a locally important mineral resource recovery site. No impact to aggregate mineral resources would occur with implementation of the General Plan Update.

Oil and Gas Resources
The currently adopted Culver City General Plan does not identify any local mineral resource recovery sites within the City but does identify the ongoing production of oil and gas associated with the City’s portion of the IOF.13 While there is ongoing oil and gas production within the City’s portion of the IOF, the City adopted the Oil Termination Ordinance, which requires the closure of the City’s portion of the IOF. The closure of the City’s portion of the IOF is an existing,

12 California Department of Conservation, Office of Mine Reclamation (OMR), 2016. Mines Online Database – Culver City. Available at: https://maps.conservation.ca.gov/mol/index.html. Accessed May 2023. 13 Culver City, 1973. Culver City General Plan – Conservation Element. Available at: conservationelement.pdf (culvercity.org). Accessed May 2023.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
ongoing process initiated by the City, independent from the Project and is therefore, considered to be a part of the environmental baseline for the analysis within this PEIR.

While the General Plan Update proposes a range of land use changes throughout the Planning Area, the proposed land use designations, as shown on Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description, would not change the existing open space land use designation for the IOF that lies within the Planning Area. This designation would allow future open space, recreational, and/or park development on the City’s portion of the IOF and on the portion of the IOF in the SOI if annexed into the City in the future. Since the City’s portion of the IOF would remain open space, implementation of the General Plan Update would not remove the existing oil and gas deposits nor preclude access to the oil and gas through development of this area in accordance with the General Plan. Furthermore, if the SOI is annexed by the City in the future, the open space designation would also ensure the presence and access to the existing oil and gas deposits would remain for this portion of the IOF in accordance with the City’s General Plan. Therefore, the General Plan Update would not result in the loss of the availability of the existing oil and gas resources. The Conservation Element of the General Plan Update includes goals and policies, as listed below, that support the closure of the City’s portion of the IOF, which includes implementation of the IOF Amortization Plan, which has already been initiated by the City as discussed above.

Therefore, implementation of the General Plan Update would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation in a manner that would render the resources unavailable. As such, the General Plan Update would not result in the loss of a regionally and locally important mineral resource. Impacts related to oil and gas resources would be considered 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 within the City’s portion of the IOF would be required to comply with the requirements of the open space district in the Zoning Code Update. Therefore, future development within the City under the Project would result in a less-than-significant impact related to mineral resources.

Applicable Proposed General Plan Goals and Policies
Conservation Element
Goal C-5: Mineral and Natural Resources. Mineral and natural resources within the IOF are produced while balancing social values, such as safety and the environment.

C-5.1: IOF Amortization Plan. Implement an amortization plan to terminate and phase- out all nonconforming oil and gas activities within the Culver City portion of the IOF and encourage transition to alternate uses for portions of the IOF outside of, but adjacent to, Culver City.

C-5.2: IOF Coordination. Coordinate with the County and City of Los Angeles and other agencies to promote compatibility between activities conducted at or planned within the IOF area and other surrounding community uses.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
C-5.3: Future Land Use Considerations for the IOF. Prioritize the public health, safety, and welfare of the community and develop a strategy for future land use considerations for the IOF.

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 mineral resources.

4.11.5 Cumulative Impacts Analysis
The geographic context for the analysis of impacts related to mineral resources is Los Angeles County. As discussed above, the General Plan Update would have no impact related to non-fuel mineral resources. Since the Project would not change the existing land use designation of the IOF and would not preclude access to oil and gas resources within the IOF, the Project would not result in the loss of a regionally or locally important mineral resources. Therefore, since the Project would preserve the existing oil and gas resources on the City’s portion of the IOF, the Project would not contribute to a cumulatively considerable impact related to the loss of availability of mineral resources.

4. Environmental Impact Analysis

4.11. Mineral Resources
General Plan 2045 and Zoning Code Update Project 4.11-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.12-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.12 Noise

4.12.1 I ntroduction
This section provides an analysis of the potential local and regional environmental noise impacts from future development allowed under the Project, including potential impacts related to ambient noise levels, groundborne vibration and noise, and exposing workers and residents to excessive noise levels. The section provides context regarding characteristics and physiological effects of noise; characteristics of groundborne vibration; and the Planning Area’s noise and vibration sources, as well as relevant federal, State, and local regulations and programs.

4.12.2 Environmental Setting
Noise Basics
Key Terms and Concepts
Sound can be described as the mechanical energy of a vibrating object transmitted by pressure waves through a liquid or gaseous medium (e.g., air). Noise is generally defined as unwanted sound (i.e., loud, unexpected, or annoying sound). Acoustics is defined as the physics of sound.

In acoustics, the fundamental scientific model consists of a sound (or noise) source, a receiver, and the propagation path between the two. The loudness of the noise source and obstructions or atmospheric factors affecting the propagation path to the receiver determines the sound level and characteristics of the noise perceived by the receiver. Acoustics addresses the propagation and control of sound primarily.
1 Sound, traveling in the form of waves from a source, exerts a sound pressure level (referred to as sound level) that is measured in decibels (dB), which is the standard unit of sound amplitude measurement. The dB scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound, with 0 dB corresponding roughly to the theoretical threshold of human hearing and 120 to 140 dB corresponding to the threshold of feeling and pain, respectively. Pressure waves traveling through air exert a force registered by the human ear as sound.
2 Sound pressure fluctuations can be measured in units of hertz (Hz), which correspond to the frequency of a particular sound. Typically, sound does not consist of a single frequency, but rather a broad band of frequencies varying in levels of magnitude. When all the audible frequencies of a sound are measured, a sound spectrum is plotted consisting of a range of frequency spanning 20 to 20,000 Hz. The typical human ear is not equally sensitive to sound within this frequency range. Therefore, when assessing potential noise impacts, sound is measured using an electronic filter that deemphasizes the frequencies below 1,000 Hz and above 5,000 Hz in a manner corresponding to the human ear’s decreased sensitivity to these extremely low and extremely high frequencies. This method of frequency filtering or weighting

1 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 2 M. David Egan, Architectural Acoustics, Chapter 1, March 1988.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
is referred to as A-weighting, expressed in units of A-weighted decibels (dBA), which is typically applied to community noise measurements.3
An individual’s noise exposure is a measure of noise over a period of time; a noise level is a measure of noise at a given instant in time, as presented in Figure 4.12-1, Decibel Scale and Common Noise Sources. However, noise levels rarely persist at that level over a long period of time. Rather, community noise varies continuously over a period of time with respect to the sound sources contributing to the community noise environment. Community noise is primarily the product of many distant noise sources, which constitute a relatively stable background noise exposure, with many of the individual contributors unidentifiable. The background noise level changes throughout a typical day, but does so gradually, corresponding with the addition and subtraction of distant noise sources, such as changes in traffic volume. What makes community noise variable throughout a day, besides the slowly changing background noise, is the addition of short-duration, single-event noise sources (e.g., aircraft flyovers, motor vehicles, sirens), which are readily identifiable to the individual.
4 These successive additions of sound to the community noise environment change the community noise level from instant to instant, requiring the noise exposure to be measured over periods of time to legitimately characterize a community noise environment and evaluate cumulative noise impacts. The following noise descriptors are used to characterize environmental noise levels over time, which are applicable to the Project.
5 Leq: The equivalent sound level over a specified period of time, typically, 1 hour (Leq). The Leq may also be referred to as the average sound level.

Lmax: The maximum, instantaneous noise level experienced during a given period of time.

Lmin: The minimum, instantaneous noise level experienced during a given period of time.

Lx: The noise level exceeded a percentage of a specified time period. For instance, L50 and L90 represent the noise levels that are exceeded 50 percent and 90 percent of the time, respectively.

L
dn: The average A-weighted noise level during a 24-hour day, obtained after an addition of 10 dB to measured noise levels between the hours of 10:00 p.m. to 7:00 a.m. to account nighttime noise sensitivity. The L
dn is also termed the day-night average noise level (DNL).

CNEL: The Community Noise Equivalent Level (CNEL) is the average A-weighted noise level during a 24-hour day that includes an addition of 5 dB to measured noise levels between the hours of 7:00 p.m. to 10:00 p.m. and an addition of 10 dB to noise levels between the hours of 10:00 p.m. to 7:00 a.m. to account for noise sensitivity in the evening and nighttime, respectively.

3 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 4 California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.2.1, 2013.
5 California Department of Transportation, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.2.1, 2013.

Culver City General Plan 2045
Figure 4.12-1
Decibel Scale and Common Noise Sources
SOURCE: State of California, Department of Transportation (Caltrans), Technical Noise Supplement (TeNS). October 1998. Available:
http://www.dot.ca.gov/hq/env/noise/pub/Technical Noise Supplement.pdfD180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 110
100
90 80
70 60
50 40
30 20
10 0
Rock Band
Inside Subway Train (New York)
Food Blender at 3 Ft.

Garbage Disposal at 3 Ft.

Shouting at 3 Ft.

Vacuum Cleaner at 10 Ft.

Large Business Ofﬁce
Concert Hall (Background)
Broadcast and Recording Studio
Threshold of Hearing
Jet Flyover at 1000 Ft.

COMMON INDOOR

NOISE LEVELS

COMMON OUTDOOR

NOISE LEVELS
NOISE
LEVEL
(dBA, Leq)
Gas Lawn Mower at 3 Ft.

Diesel Truck at 50 Ft.

Noisy Urban Daytime
Gas Lawn Mower at 100 Ft.

Commercial Area
Heavy Trafﬁc at 300 Ft.

Quiet Urban Nighttime
Quiet Suburban Nighttime
Quiet Rural Nighttime
Small Theater, Large
Conference Room (Background)
Library
Dishwasher Next Room Quiet Urban Daytime

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Effects of Noise on People
Although exposure to high noise levels has been demonstrated to cause physical and physiological effects, the principal human responses to typical environmental noise exposure are related to subjective effects and interference with activities. Activities most affected by noise include rest, relaxation, recreation, study, and communications. 6 Concerning the subjective effects, the responses of individuals to similar noise events are diverse and influenced by many factors, including the type of noise, the perceived importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of day and the type of activity during which the noise occurs, and individual noise sensitivity.

Overall, there is no completely satisfactory way to measure the subjective effects of noise or the corresponding reactions of annoyance and dissatisfaction on people. A wide variation in individual thresholds of annoyance exists, and different tolerances to noise tend to develop based on an individual’s past experiences with noise. Thus, an important way of predicting a human reaction to a new noise environment is the way it compares to the existing environment to which one has adapted (i.e., comparison to the ambient noise environment). In general, the more a new noise level exceeds the previously existing ambient noise level, the less acceptable the new noise level will be judged by those hearing it. Regarding increases in A-weighted noise level, the following relationships generally occur:
7 • Except in carefully controlled laboratory experiments, a change of 1 dBA in ambient noise levels cannot be perceived;
• Outside of the laboratory, a three dBA change in ambient noise levels is considered to be a barely perceivable difference;
• A change in ambient noise levels of five dBA is considered to be a readily perceivable difference; and
• A change in ambient noise levels of 10 dBA is subjectively heard as a doubling of the perceived loudness.

These relationships occur in part because of the logarithmic nature of sound and the decibel scale. The human ear perceives sound in a non-linear fashion, which is why the dBA scale was developed. Because the dBA scale is based on logarithms, two noise sources do not combine in a simple additive fashion. Under the dBA scale, a doubling of sound energy corresponds to a three dBA increase. In other words, when two sources are each producing sound of the same loudness, the resulting sound level at a given distance would be approximately three dBA higher than one of the sources under the same conditions. For example, if two identical noise sources produce noise levels of 50 dBA, the combined sound level would be 53 dBA, not 100 dBA. Under the dB scale, three sources of equal loudness together produce a sound level of approximately five dBA louder than one source, and ten sources of equal loudness together produce a sound level of approximately 10 dBA louder than the single source. 8 6 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 7 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 8 M. David Egan, Architectural Acoustics, Chapter 1, March 1988.

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Sources of Noise
Sources of noise in Culver City include vehicular traffic on local streets, major arterial, freeways/highways, passenger and freight trains on railroad tracks, and aircraft overflight from neighboring airports, which include Los Angeles International Airport (LAX) located approximately two miles to the southwest and Santa Monica Airport located approximately two miles north of the western part of Culver City. In addition, noise sources include exterior operations associated with commercial and industrial land uses, such as loading/unloading activity, trash compactors, heavy-duty truck movement, trash collection, barking dogs, and amplified sound. Some representative common outdoor and indoor noise sources and their corresponding A-weighted noise levels are shown in Figure 4.12-1. All noise levels presented are A-weighted unless otherwise stated. A more detailed discussion on the noise sources and their potential impacts to the existing environment is provided in Section 4.12-4, Existing Noise Environment, below.

Noise Attenuation
When noise spreads over a distance, the noise level reduces with distance depending on the type of noise source and the propagation path. Noise from a localized source (i.e., point source) propagates uniformly outward in a spherical pattern, referred to as “spherical spreading.” Stationary point sources of noise, including stationary mobile sources such as idling vehicles, attenuate (i.e., reduce) at a rate between 6 dBA for acoustically “hard” sites and 7.5 dBA for “soft” sites for each doubling of distance from the reference measurement, as their energy is continuously spread out over a spherical surface (e.g., for hard surfaces, 80 dBA at 50 feet attenuates to 74 at 100 feet, 68 dBA at 200 feet, etc.). Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete surfaces or smooth bodies of water. No excess ground attenuation is assumed for hard sites and the reduction in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source. Soft sites have an absorptive ground surface, such as soft dirt, grass, or scattered bushes and trees, which in addition to geometric spreading, provides an excess ground attenuation value of 1.5 dBA (per doubling distance).
9 Roadways and highways consist of several localized noise sources on a defined path, and hence are treated as “line” sources, which approximate the effect of several point sources. Noise from a line source propagates over a cylindrical surface, often referred to as “cylindrical spreading.” 10 Line sources (e.g., traffic noise from vehicles) attenuate at a rate between 3 dBA for hard sites and 4.5 dBA for soft sites for each doubling of distance from the reference measurement. 11 Therefore, noise due to a line source attenuates less with distance than that of a point source with increased distance.

Additionally, receptors located downwind from a noise source can be exposed to increased noise levels relative to calm conditions, whereas locations upwind can have lowered noise levels. Atmospheric temperature inversion (i.e., increasing temperature with elevation) can

9 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 10 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 11 M. David Egan, Architectural Acoustics, Chapter 1, March 1988.

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increase sound levels at long distances (e.g., more than 500 feet). Other factors, such as air temperature, humidity, and turbulence can also have significant effects on noise levels. 12 Vibration
Fundamentals of Vibration
As described in the Federal Transit Administration’s (FTA’s) Transit Noise and Vibration Impact Assessment Manual,
13 groundborne vibration can be a serious concern for nearby neighbors of a transit system route or maintenance facility, causing buildings to shake and rumbling sounds to be heard. In contrast to airborne noise, groundborne vibration is not a common environmental problem. It is unusual for vibration from sources such as buses and trucks to be perceptible, even in locations close to major roads.

Several different methods are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal. PPV is most frequently used to describe vibration impacts to buildings. The root mean square (RMS) amplitude is most frequently used to describe the effect of vibration on the human body. The RMS amplitude is defined as the average of the squared amplitude of the signal. Decibel notation (VdB) is commonly used to measure RMS. The decibel notation acts to compress the range of numbers required to describe vibration. The relationship of PPV to RMS velocity is expressed in terms of the “crest factor,” defined as the ratio of the PPV amplitude to the RMS amplitude. PPV is typically a factor of 1.7 to six times greater than RMS vibration velocity. 14 Typically,
groundborne vibration generated by human-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receptors for vibration include structures (especially older masonry structures), people (especially residents, students, the elderly, and the sick), and vibration-sensitive equipment.
15 In residential areas, the background vibration velocity level is usually around 50 VdB (approximately 0.0013 in/sec PPV). This level is well below the vibration velocity level threshold of perception for humans, which is approximately 65 VdB. A vibration velocity level of 75 VdB is the approximate dividing line between barely perceptible and distinctly perceptible levels for many people.
16 Effects of Vibration
Building vibration may be perceived by the occupants as the motion of building surfaces, the rattling of items moving on shelves or hanging on walls, or as a low-frequency rumbling noise.

The rumbling noise is caused by the vibrating walls, floors, and ceilings that are radiating sound waves. The effects of groundborne vibration include movement of building floors, rattling of windows, shaking of items on shelves or hanging on walls, and rumbling sounds. In extreme cases, the vibration can cause damage to buildings. However, building damage is not a factor for

12 M. David Egan, Architectural Acoustics, Chapter 1, March 1988. 13 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018. 14 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018. 15 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018. 16 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018.

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most projects, except for occasional blasting and pile driving during construction. Annoyance from vibration often occurs when the vibration exceeds the threshold of perception by only a small margin. A vibration level that causes annoyance will be well below the damage threshold for normal buildings. The FTA measure of the threshold of architectural damage for conventional sensitive structures is 0.2 inches per second (in/sec) PPV. 17 Sources of Vibration
Typical sources of groundborne vibration are construction activities (e.g., blasting, pile driving, and operating heavy-duty earth-moving equipment), steel-wheeled trains, and occasional traffic on rough roads. Problems with groundborne vibration and noise from these sources are usually localized to areas within approximately 100 feet of the vibration source, although there are examples of groundborne vibration causing interference out to distances greater than 200 feet.
18 When roadways are smooth, vibration from traffic, even heavy trucks, is rarely perceptible.

Vibration Attenuation
Vibration attenuates by 9 VdB with the doubling of distance. For example, a vibration level at 50 feet from the source is 9 VdB lower than the vibration level at 25 feet. Vibration at 100 feet from the source is 18 VdB lower than the vibration level at 25 feet. Therefore, for a large bulldozer with a reference groundborne vibration level of 87 VdB at 25 feet, receptors at 50 feet from the construction activity may be exposed to groundborne vibration up to 78 VdB (or

0.030 inch/sec PPV or lower). Receptors at 100 feet from the source may be exposed to groundborne vibration up to 69 VdB.

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

Federal
The United States Noise Control Act of 1972
The Noise Control Act recognized the role of the federal government in dealing with major commercial noise sources in order to provide for uniform treatment of such sources. As Congress has the authority to regulate interstate and foreign commerce, regulation of noise generated by such commerce also falls under congressional authority. The federal government specifically preempts local control of noise emissions from aircraft, railroad and interstate highways.

The United States Environmental Protection Agency (USEPA) has identified acceptable noise levels for various land uses, in order to protect public welfare, allowing for an adequate margin of safety, in addition to establishing noise emission standards for interstate commerce activities.

17 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018. 18 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018.

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The U.S. Department of Housing and Urban Development (HUD) has established policies for granting financial support for the construction of dwelling units in noise impacted areas.

Table 4.12-1, HUD External Noise Exposure Standards for New Residential Construction, shows noise exposure levels used by HUD to determine eligibility for financial backing for new or rehabilitative residential construction in noise impacted areas, in addition to providing special requirements. As indicated in Table 4.12-1, financial assistance from HUD would still be possible when noise exposure is between 65 dBA and 75 dBA, if adequate sound attenuation is provided to achieve appropriate noise reduction.

TABLE 4.12-1

HUD EXTERNAL NOISE EXPOSURE STANDARDS FOR NEW RESIDENTIAL CONSTRUCTION HUD Approval Site Noise Exposure Noise Level (L dn) Special Approval/Requirement Standard Acceptable Not exceeding 65 dB None
Discouraged Normally Acceptable 65 dB to 75 dB
Building sound attenuation of 5 dB for 65-70 dB noise
level and 10 dB for 70-75 dB noise level
Special Environmental Clearance
Approval of Regional Administration
Prohibited Unacceptable 75+ dB Approval of Assistant Secretary of Community Planning EIS required
SOURCE: United States Department of Housing and Urban Development, 1979. External Noise Exposure Standards for New Residential Construction July 12, 1979, as amended at 50 FR 9268, March 7, 1985.

Federal Transportation Administration Vibration Standards There are no federal vibration standards or regulations adopted by any agency specifically for evaluating vibration impacts from land use development projects such as those that would be allowed under the Project. However, FTA has adopted vibration criteria that are commonly used to evaluate potential structural damage to buildings by building category from construction activities. The vibration damage criteria adopted by FTA are shown in Table 4.12-2, Construction Vibration Damage Criteria.

TABLE 4.12-2

C ONSTRUCTION VIBRATION DAMAGE CRITERIA
Building Category
PPV
(in/sec)
I. Reinforced-concrete, steel, or timber (no plaster) 0.5 II. Engineered concrete and masonry (no plaster) 0.3
III. Non-engineered timber and masonry buildings 0.2
IV. Buildings extremely susceptible to vibration damage 0.12 NOTES: PPV = peak particle velocity; in/sec = inches per second SOURCE: Federal Transit Administration, 2018. Transit Noise and Vibration Impact Assessment Manual. https://www.transit.dot.gov/sites/fta.dot.gov/files/docs/research- innovation/118131/transit-noise-and-vibration-impact-assessment-manual-fta-report- no-0123_0.pdf. Accessed March 2023.

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FTA has also adopted vibration criteria associated with the potential for human annoyance from groundborne vibration for the following three land use categories: Category 1 – High Sensitivity, Category 2 – Residential, and Category 3 – Institutional. FTA defines Category 1 as buildings where vibration would interfere with operations within the building, including vibration- sensitive research and manufacturing facilities, historic buildings, hospitals with vibration- sensitive equipment, and university research operations. Vibration sensitive equipment includes, but is not limited to, electron microscopes, high-resolution lithographic equipment, and normal optical microscopes. Category 2 refers to all residential land uses and any buildings where people sleep, such as hotels and hospitals. Category 3 refers to institutional land uses such as schools, libraries, theaters, churches, cemeteries, monuments, museums, campgrounds, and recreational facilities that do not have vibration-sensitive equipment but still have the potential for activity interference. The FTA uses a screening distance of 100 feet for highly vibration-sensitive buildings (e.g., historic buildings, hospital with vibration sensitive equipment, Category 1) and 50 feet for residential uses (Category 2) and institutional land uses with primarily daytime use (Category 3). The vibration criteria associated with human annoyance for these three land-use categories are shown in Table 4.12-3, Indoor Groundborne Vibration Impact Criteria for General Assessment. No vibration criteria have been adopted or recommended by FTA for commercial and office uses.

TABLE 4.12-3

INDOOR GROUNDBORNE VIBRATION IMPACT CRITERIA FOR GENERAL ASSESSMENT Land Use Category
Frequent
Events1
Occasional
Events2
Infrequent
Events3
Category 1: Buildings where vibration would interfere with interior operations 65 VdB4 65 VdB4 65 VdB4 Category 2: Residences and buildings where people normally sleep. 72 VdB 75 VdB 80 VdB Category 3: Institutional land uses with primarily daytime uses. 75 VdB 78 VdB 83 VdB NOTES: VdB = vibration velocity decibels
1 “Frequent Events” is defined as more than 70 vibration events of the same source per day. 2 “Occasional Events” is defined as between 30 and 70 vibration events of the same source per day. 3 “Infrequent Events” is defined as fewer than 30 vibration events of the same source per day. 4 This criterion is based on levels that are acceptable for most moderately sensitive equipment such as optical microscopes.

SOURCE: FTA, Transit Noise and Vibration Impact Assessment Manual, 2018.

Occupational Safety and Health Act of 1970
Under the Occupational Safety and Health Act of 1970 (29 United States Code [USC] Sections 1919 et seq.), the Occupational Safety and Health Administration (OSHA) adopted regulations designed to protect workers against the effects of occupational noise exposure. These regulations list permissible noise level exposure as a function of the amount of time during which the worker is exposed. The regulations further specify a hearing conservation program that involves monitoring noise to which workers are exposed, ensuring that workers are made aware of overexposure to noise, and periodically testing the workers’ hearing to detect any degradation. 19 19 United States Department of Labor, 1970. Occupational Safety and Health (OSH) Act of 1970, https://www.osha.gov/laws-regs/oshact/completeoshact. Accessed March 2023.

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State
State of California Noise Standards
The Office of Noise Control in the State Department of Health Services developed criteria and guidelines for local governments to use when setting standards for human exposure to noise and preparing noise elements for General Plans. These guidelines include noise exposure levels for both exterior and interior environments. In addition, Title 25, Section 1092 of the California Code of Regulations sets forth requirements for the insulation of multiple-family residential dwelling units from excessive and potentially harmful noise. The State indicates that locating residential units in areas where exterior ambient noise levels exceed 65 CNEL is undesirable.

Whenever such units are to be located in such areas, the developer must incorporate construction features into the building design that would reduce interior noise levels to 45 dBA CNEL. Table 4.12-4, Noise and Land Use Compatibility Matrix, and Table 4.12-5, State Interior and Exterior Noise Standards, summarize standards adopted by State agencies. Table 4.12-4 presents criteria used to assess the compatibility of proposed land uses with the noise environment. These standards and criteria have been incorporated into the land use planning process, including the proposed General Plan Update Noise Element, to reduce future noise and land use incompatibilities. These tables are the primary tools that allow Culver City to ensure integrated planning for compatibility between land uses and outdoor noise.

TABLE 4.12-4

N OISE AND LAND USE COMPATIBILITY MATRIX

Community Noise Exposure
Ldn or CNEL, dBA
Land Use
Normally
Acceptable
Conditionally
Acceptable
Normally
Unacceptable
Clearly
Unacceptable
Residential – Low Density 50 to 60 60 to 70 70 to 75 75 to 85 Residential – Multiple Family 50 to 65 65 to 70 70 to 75 75 to 85 Transient Lodging—Motels, Hotels 50 to 65 65 to 70 70 to 80 80 to 85 Schools, Libraries, Churches, Hospitals, Nursing Homes 50 to 60 60 to 65 65 to 80 80 to 85 Auditoriums, Concert Halls, Amphitheaters NA 50 to 70 NA 70 to 85 Sports Arena, Outdoor Spectator Sports NA 50 to 75 NA 75 to 85 Playgrounds, Neighborhood Parks 50 to 67.5 NA 70 to 80 75 to 85 Golf Courses, Riding Stables, Water Recreation, Cemeteries 50 to 75 NA 70 to 80 80 to 85 Office Buildings, Business and Professional Commercial 50 to 67.5 67.5 to 77.5 77.5 to 85 NA Industrial, Manufacturing, Utilities, Agriculture 50 to 70 70 to 80 80 to 85 NA Normally Acceptable: Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction without any special noise insulation requirements.

Conditionally Acceptable: New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is conducted and necessary noise insulation features are included in the design. Conventional construction, but with closed windows and fresh air supply systems or air conditioning will normally suffice.

Normally Unacceptable: New construction or development should generally be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirements must be conducted and necessary noise insulation features included in the design.

Clearly Unacceptable: New construction or development should generally not be undertaken.

NA: Not Applicable
SOURCE: Modified from California Office of Planning and Research, n.d. Guidelines for the Preparation and Content of the Noise Element of the General Plan.

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TABLE 4.12-5

S TATE INTERIOR AND EXTERIOR NOISE STANDARDS
Land Use Categories CNEL dBA
Categories Uses Interior1 Exterior 2
Residential Single-Family, Duplex, Multiple-Family
Mobile Home
453
--
65 654
Commercial Hotel, Motel, Transient Lodging 45 --
Industrial Commercial Retail, Bank, Restaurant 55 --
Institutional
Office Building, Research and Development,
Professional Offices, City Office Building 50 --
Amphitheater, Concert Hall, Auditorium, Meeting Hall 45 -- Gymnasium (Multipurpose) 50 --
Sports Club 55 --
Manufacturing, Warehousing, Wholesale, Utilities 65 --
Movie Theaters 45 --
Hospital, Schools’ Classrooms/Playgrounds 45 65
Church, Library 45 --
Open Space Parks -- 65
1 Indoor environmental including: Bathrooms, closets, and corridors. 2 Outdoor environment limited to
• Private yard of single family, multi-family private patio or balcony which is served by a means of exit from inside the dwelling
• Balconies 6 feet deep or less are exempt
• Mobile home park
• Park’s picnic area
• School’s playground
3 Noise level requirement with closed windows. Mechanical ventilating system or other means of natural ventilation shall be provided as of Chapter 23, Section 1206 of UBC.
4 Exterior noise levels should be such that interior noise levels will not exceed 45 dBA CNEL.

SOURCE: Modified from California Department of Health Services, Office of Noise Control.

In addition, new or renovated residential and business buildings in California are required to comply with the California Code of Regulations, Title 24, Part 2 – California Building Code, Chapter 12 – Interior Environment, which requires that interior noise levels attributable to exterior sources must not exceed 45 dB CNEL in any habitable room.

Assembly Bill 1307
On September 7, 2023, the Governor signed Assembly Bill (AB) 1307, which provides that noise generated by occupants of residential projects is not a significant effect on the environment under the California Environmental Quality Act (CEQA). AB 1307 also eliminates the requirement that public universities consider alternatives to the location of housing projects when the project is located on a site no bigger than five acres in an urban use setting, and has already been evaluated in an environmental impact report for the university’s long-range development plan. The State Legislature unanimously passed the bill, which takes immediate effect as an urgency statute to address California’s housing crisis. Under AB 1307, the effects of noise generated by project occupants and their guests on human beings shall not be considered a

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significant effect on the environment under CEQA if a project is categorized within one of the following definitions as outlined in Section 21085.2 of AB 1307:20 1) “Long-range development plan” means a physical development and land use plan to meet the academic and institutional objectives for a particular campus or medical center of public higher education.
2) “Public higher education” means the institutions described in subdivision (a) of Section 66010 of the Education Code.
3) “Residential or mixed-use housing project” means a project consisting of residential uses only or a mix of residential and nonresidential uses, with at least two-thirds of the square footage of the development designated for residential uses. 4) “Substantially surrounded” means at least 75 percent of the perimeter of the project site adjoins, or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses.
5) Notwithstanding any other law or regulation, institutions of public higher education shall not be required, in an environmental impact report prepared for a residential or mixed-use housing project, to consider alternatives to the location of the residential or mixed-use housing project if both of the following requirements are met:
a) The residential or mixed-use housing project is located on a site that is no more than five acres and is substantially surrounded by qualified urban uses. b) The residential or mixed-use housing project has already been evaluated in the environmental impact report for the most recent long-range development plan for the applicable campus.

Local
Culver City Municipal Code
Chapter 9.07 of the City of Culver City Municipal Code (CCMC) provides specific noise restrictions and exemptions for noise sources within the City. Section 9.07.035 of the CCMC noise regulations state that construction activity shall be prohibited, except between the hours of 8:00 a.m. and 8:00 p.m. Mondays through Fridays; 9:00 a.m. and 7:00 p.m. Saturdays; 10:00 a.m. and 7:00 p.m. Sundays. There are no established noise limits for noise associated with construction activity when construction occurs within the permitted hours. This section also prohibits any person to operate any radio, disc player or cassette player or similar device at a construction site in a manner that results in noise levels that are audible beyond the construction site property line. Construction activity of a specific nature (such as the pouring of concrete) may be authorized during the prohibited times, provided such exception has been determined to be in the public interest and a land use permit or a temporary use permit has been issued in accordance with the requirements.

Section 9.07.055(B) of the CCMC prohibits the operation of a loud speaker or sound amplifying equipment for the purposes of transmitting messages, giving instructions, or providing

20 California Legislative Information, Assembly Bill No. 1307. September 7, 2023. Available at:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB1307. Accessed October 2023.

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entertainment on an ongoing basis which is audible at the subject property line. This section is applicable only to uses that would include regular and ongoing amplification, such as outdoor speakers used for a drive-through restaurant.

Section 9.07.060 of the CCMC provides certain exemptions from Chapter 9.07 including noise for the purpose of alerting persons to the existence of an emergency or performance of emergency work, noise from warning devices necessary for the protection of public safety, permitted activities conducted on public playgrounds and public or private school grounds including but not limited to school athletic and entertainment events, trash collection activities in residential areas after 7:00 a.m., public utilities operating under the authority of the Public Utilities Commission when specifically authorized through the City's permit system, and filming activity conducted in accordance with the provisions of Chapter 11.14, which provides specific requirements for filming activity.

4.12.4 Existing Noise Environment
Ambient Noise
Culver City is in an area of southern California that is characterized by several types of regional noise sources, such as freeways and airports. These sources generate noise that can be heard in noise-sensitive areas throughout many areas of the City. Three major freeways border the city.

The Marina (SR-90) Freeway is in the southwest area of the city and ends at Slauson Avenue.

The San Diego (I-405) Freeway runs through the western half of the city. The Santa Monica (I-10) Freeway runs adjacent to the northern city limits. Unlike the other two freeways, the I-10 does
not enter the City. However, 1-10 noise does affect Culver City because of its proximity to the northern city limits.

The City is located within a few miles of two busy southland airports. LAX, the busiest airport in southern California, is located approximately two miles to the southwest. Santa Monica Airport, a municipal general aviation airport, is located approximately two miles north of the western part of Culver City. As a result, the City is subject to a variety of aircraft and helicopter noise events. Aircraft operations, though infrequent, may generate high noise levels that can be disruptive to human activity. The city is not within the aircraft noise exposure area or 65 dBA CNEL noise contour of LAX. However, Culver City is in the flight path for landings at LAX, when planes are coming from the north and the west, crossing over certain parts of Santa Monica and other areas of the Westside, flying through Culver City, as the planes head further east before turning around to make their final descent into LAX. Therefore, aircraft overflight from LAX operations contributes to the ambient noise level in the city.

In addition, the Los Angeles Metro Rail E Line (Expo) passes through the city in an east-west orientation. The Metro E Line’s Culver City Station is located just east of the intersection of Venice Boulevard and S. Robertson Boulevard.

Noise that falls into the stationary source category typically includes industrial and commercial, entertainment, sporting or other outdoor events including those at educational institutions, construction and maintenance, machinery, and passenger and delivery vehicle noise. Passenger

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and delivery vehicle noise is included with the stationary sources because the noise occurs at certain sites where the activity is generated. In Culver City, these sources include business centers, such as Fox Hills Mall and Studio Village Shopping Center; employment centers that range in size from major movie studios, such as Sony Pictures Studios; small industrial operations, such as Westside Business Park; and institutional sources, such as West Los Angeles Community College and Culver City High School. The types of noise disturbance from stationary source activities can range from short-duration events, such as trucks accessing a facility, to continuous noise from mechanical sources, such as refrigeration units or compressors. Many of the smaller operations are located in strip-commercial zones along Washington and Sepulveda Boulevards adjacent to residential land use. The types of noise disturbance from stationary source activities can range from short-duration, loud events, such as trucks accessing a facility, to continuous noise from mechanical sources, such as refrigeration units or compressors.

To understand the existing ambient or background noise levels throughout the city, long-term (24-hour) and short-term (15-minute) field measurements were conducted in October 2019. The noise measurements consider mobile noise sources and stationary noise sources. Field monitoring consisted of 32 noise measurements recorded at various locations throughout the city. The noise measurements were conducted using a Larson Davis LxT Type 1 sound-level meter (SLM). All instruments were calibrated and operated according to the applicable manufacturer specification. A summary of long-term noise measurements is shown in Table 4.12-6, Summary of Short-Term Noise Measurements. The results of the short-term noise measurements are shown in Table 4.12-7, Summary of Long-Term Noise Measurements. The measurement locations are identified in Figure 4.12-2, Noise Measurement Locations.

Traffic Noise
Transportation-related noise sources include freeways, aircraft overflights, major and minor arterial roadways, and rail lines. These include noise from automobiles, trucks, motorcycles, trains, and aircraft. Motor vehicle noise is of concern because it is characterized by a high number of individual events that often combine to create a sustained noise level, and because of its proximity to areas sensitive to noise exposure.

Culver City is located in an area of southern California that is saturated by regional noise sources, such as freeways and airports. These sources generate noise that can be heard in noise sensitive areas throughout many areas of the city. As discussed previously, The Marina (SR-90) Freeway is located in the southwest area of the city, The San Diego (I-405) Freeway runs through the western half of the city, and the Santa Monica (I-10) Freeway runs adjacent to the northern city limits.

The following major roadways pass through the city’s boundary and constitute major arterials within the city limits: Venice Boulevard, Washington Boulevard, Culver Boulevard, Jefferson Boulevard, National Boulevard, Slauson Avenue, Duquesne Avenue, Short Avenue, Centinela Avenue, Sawtelle Boulevard, Overland Avenue, La Cienega Boulevard, Sepulveda Boulevard, Inglewood Boulevard, and Barrington Avenue.

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TABLE 4.12-6

S UMMARY OF SHORT-TERM NOISE MEASUREMENTS
Site General Location of Noise Measurement dBA Leqa Orientation/Type of Sensitive Receptor R1 Grand View Boulevard between Washington Place and Herbert Street 58.6 Multi-family residential to the east, single-family residential to the southeast, and commercial to the west
R2 Emporia Place at junction of Emporia Avenue and Selmaraine Drive 58.8 Single-family to the north, west, and northwest. I-405 and SR-90 interchange to the east R3 Midway Avenue between Venice Boulevard and Washington Boulevard 62.2 Single-family residential to the west and south. Commercial center to the north and east R4 Near the corner of Drakewood Avenue and Flaxton Street 46.2 Surrounded by single-family residential R5 Braddock Drive just north of Sepulveda Boulevard 63.4 Single-family residential to the north, commercial uses to the south, east, and west R6 Along Watseka Avenue near alleyway connectiong Watseka Avenue and Cardiff Avenue 62.4 Multi-family residential to the west and commercial uses to the north, south, and east R7 Higuera Street between Krueger Street and Hubbard Street 67.0 Surrounded by single-family residential R8 Lincoln Avenue near cul-de-sac above Ballona Creek 51.9 Single-family residential to the north, west, and south R9 Roberts Avenue across from Washington School 65.0 Single-family residential, open space, and Washington School R10 Near corner of Elenda Street and Marietta Avenue 66.0 Surrounded by single-family residential R11 Coombs Avenue across from Veterans Memorial Park 63.9 Veterans memorial Park to the north. Single-family residential to the south, east, and west R12 Blackwelder Street west of La Cienega Boulevard 65.4 Light Industrial and commercial uses R13 Near corner of Orville Street and McDonald Street 45.6 Single-family residential to the south, east, and west. Ballona Creek to the north R14 Near corner of McDonald Street and Purdue Avenue 56.9 Single-family residences to the east, north, and south. Freeway overpass to the west R15 Near corner of Buckingham Parkway and Windsor Way 61.9 Multi-family residences to the north, east, and south. Commercial center to the west R16 At the terminus of Jasmine Avenue west of Le Bourget Avenue 49.9 Single-family residences to the north, east, and south. Multi-family residences to the west R17 Walgrove Avenue between Zanja Street and Washington Boulevard 60.4 Surrounded by single-family residential. One block from Costco R18 Globe Avenue near vacant lot west of I-405 61.1 Single-family residences to the west and northwest. I-405 overpass to the east.

R19 Near corner of Hannum Avenue and Bush Way 55.8 Surrounded by single-family residential. Commercial corridor on Sepulveda Boulevard to the west
R20 Near Corner of Huron Avenue and Matteson Avenue 59.8 Surrounded by single-family residential R21 Jasmine Avenue near Culver Boulevard 58.5 Single- and multi-family residences to the south and east. Commercial uses to the north and east
R22 Near corner of Washington Boulevard and Mildred Avenue 65.1 Single-family residences to the south. Commercial uses to the east, west, and north R29 Hannum Avenue near entrance to Playa Pacific community 70.2 Multi-family residences to the north, east, and south. Commercial center to the west

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Site General Location of Noise Measurement dBA Leqa Orientation/Type of Sensitive Receptor R30 Van Buren Place across from Linwood E. Howe Elementary School 56.4 Linwood E. Howe Elementary School to the west and single-/multi-family residences to the northwest, south, and east
R31 Near corner of Washington Boulevard and National Boulevard 70.1 Multi-family residences to the east and light industrial/commercial uses to the north, south, and west
R32 Near corner of Hayden Avenue and Warner Drive 61.0 Light industrial/commercial uses a Detailed measured noise data, including hourly Leq levels, are included in Appendix E.

SOURCE: ESA, 2019.

TABLE 4.12-7

S UMMARY OF LONG-TERM NOISE MEASUREMENTS
Site General Location of Noise Measurement
Leq dBA a
CNEL
dBA Orientation/Type of Sensitive Receptor
Daytime
(7 A.M. to 10 P.M.)
Hourly Leq
Daytime
Average
Hourly Leq
Nighttime
(10 P.M. to 7 A.M.)
Hourly Leq
Nighttime
Average
Hourly Leq
R23 Near northeast corner of Tellefson Road
and Cranks Road 46.2 - 60.9 53.8 43.6 - 64.3 56.0 62.2 Single-family residential uses in every direction
R24 Near northeast corner of Port Road and
Emporia Avenue 56.7 - 61.5 59.9 56.9 - 64.1 60.4 66.9 Single-family residential uses in every direction
R25 Near southeast corner of Pickford Way and
Kinston Avenue 52.8 - 68.1 60.3 47.0 - 57.9 52.6 61.6
Single-family residential uses in every
direction. Shopping center across Jefferson
Boulevard to the east
R26 Near southeast corner of Mildred Avenue
and Louise Avenue 54.2 - 69.3 62.3 43.2 - 65.5 56.8 64.7 Single-family residential uses in every direction
R27 Halfway down Fay Avenue south of Jacob
Street 55.3 - 61.7 58.5 49.7 - 61.3 56.6 63.6 Single-family residential uses in every direction. Syd Kronenthal Park to the east.

R28 Near southwest corner of Wrightcrest Drive
and Lenawee Avenue 55.7 - 63.3 59.7 50.4 - 65.0 57.7 64.7 Single- and multi-family residential uses in every direction
a Detailed measured noise data, including hourly Leq levels, are included in Appendix E.

SOURCE: ESA, 2019.

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

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

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

City of Los Angeles
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R2
R3
R4
R5
R6
R7
R8
R9
R10 R11
R12
R13
R14
R15
R16
R17
R18
R19
R20
R21
R22
R23
R24
R25
R26
R27
R28
R29
R30
R31
R32
°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
Noise Measurement Locations
!( Short Term Measurement Locations
!( Long Term Measurement Locations
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
Noise Measurement Locations
!( Short T erm Measurement Locations
!( Long T erm Measurement Locations
Culver City General Plan 2045
Figure 4.12-2
Noise Measurement Locations
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Existing roadway noise levels were calculated for 62 roadway segments located in the city, using the Federal Highway Administration (FHWA) Highway Traffic Noise Model (TNM) methodology and data for existing vehicle miles traveled (VMT) and traffic volumes for non-truck vehicles and light-duty, medium-duty, and heavy-duty trucks on study roadway segments from the Culver City Citywide Travel Demand Forecasting Model (see Appendix F2 of this Draft PEIR for traffic data). The FHWA TNM methodology calculates the average noise level at specified locations based on traffic volumes, average speeds, and site environmental conditions.

The model assumed “hard surface” site propagation conditions. As previously discussed, sound levels caused by line sources, such as roadway segment traffic, decrease at a rate of 3.0 to 4.5 dBA when the distance from the centerline of the road is doubled, depending on the surface hardness between the source and the receiving property. The actual sound level at any receptor location is dependent upon such factors as the source-to-receptor distance and the presence of intervening structures, barriers, and topography. Attenuation due to intervening structures, topography, atmospheric absorption, etc. is not included in the generalized model; therefore, the model analysis assumes a conservative worst-case scenario for traffic noise (i.e., actual site attenuation would potentially result in reduced traffic noise levels at receptors, where intervening structures and topography occur).

The average daily noise levels along these roadway segments at 50 feet from the roadway centerline, and the line-of-sight distance from the roadway segment to the noise contours of 70, 65, and 60 dBA CNEL are presented in Table 4.12-8, Existing Roadway Noise Levels. Existing roadway noise contours are shown in Figure 4.12-3, Existing Roadway Noise Contour Map. A noise contour is a line behind which the noise level does not exceed a certain value. For instance, the 60 dBA CNEL contour indicates that the CNEL between the roadway centerline and the contour line is equal to, or greater than 60 dBA; the CNEL beyond the contour line – away from the street – is less than 60 dBA CNEL.

TABLE 4.12-8

E XISTING ROADWAY NOISE LEVELS
dBA CNEL
at 50 Feet from
Centerline1
Approximate Distance to
CNEL Contour (feet)2
Roadway Segment 60 65 70
Adams Blvd between Washington Blvd & Fairfax Ave 64.8 150 45 15 Culver Blvd between Overland Ave & Sepulveda Blvd 72.7 935 295 95 Culver Blvd between Sepulveda & Sawtelle Blvd 72.5 895 280 90 Culver Blvd between Washington Blvd & Duquesne Ave 69.1 405 130 40 Culver Blvd between Washington Blvd & Washington Blvd 70.9 620 195 60 Culver Blvd between Duquesne Ave & Overland Ave 72.6 905 285 90 Fairfax Ave between Washington Blvd & La Cienega Blvd 72.6 910 290 90 Jefferson Blvd between Slauson Ave & Inglewood Blvd 71.4 690 220 70 Jefferson Blvd between Sepulveda Blvd & Slauson Ave 69.5 450 140 45 Jefferson Blvd between Overland Ave & Sepulveda Blvd 70.8 605 190 60 Jefferson Blvd between Duquesne Ave & Overland Ave 73.4 1,095 345 110 Jefferson Blvd between Overland Ave & Sawtelle Blvd 66.3 215 70 20

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
dBA CNEL
at 50 Feet from
Centerline1
Approximate Distance to
CNEL Contour (feet)2
Roadway Segment 60 65 70
Jefferson Blvd between Obama Blvd & Duquesne Ave 73.4 1,105 350 110 Machado Rd between Jefferson Blvd & Sepulveda Blvd 62.9 95 30 10 Overland Ave between Venice Blvd & Washington Blvd 69.5 445 140 45 Overland Ave between Washington Blvd & Culver Blvd 69.8 475 150 45 Overland Ave between Culver Blvd & Jefferson Blvd 69.4 430 135 45 Overland Ave between Jefferson Blvd & Sawtelle Blvd 69.7 465 150 45 S Centinela Ave between Washington Blvd & Culver Blvd 69.2 415 130 40 S Centinela Ave between Venice Blvd & Washington Pl 72.7 930 295 95 S Centinela Ave between Washington Pl & W Washington Blvd 71.1 650 205 65 S Fairfax Ave between Venice Blvd & Washington Blvd 70.0 500 160 50 S La Cienega Blvd between Fairfax Ave & W Jefferson Blvd 72.6 905 285 90 S La Cienega Blvd between Venice Blvd & Washington Blvd 70.9 610 195 60 S La Cienega Blvd between Washington Blvd & Fairfax Ave 72.7 935 295 95 Sepulveda Blvd between Slauson Ave & W Centinela Ave 72.0 795 250 80 Sepulveda Blvd between Culver Blvd & Jefferson Blvd 72.0 785 250 80 Sepulveda Blvd between Washington Blvd & Culver Blvd 70.0 500 160 50 Sepulveda Blvd between Venice Blvd & Washington Pl 71.4 695 220 70 Sepulveda Blvd between Washington Pl & Washington Blvd 70.9 615 195 60 Sepulveda Blvd between Jefferson Blvd & Slauson Ave 73.1 1,020 325 100 Sepulveda Blvd between Sawtelle Blvd & Jefferson Blvd 75.5 1,770 560 175 Sepulveda Blvd between Jefferson Blvd & Sawtelle Blvd 71.8 765 240 75 Slauson Ave between Jefferson Blvd & Sepulveda Blvd 68.8 380 120 40 Slauson Ave between W Jefferson Blvd & Washington Blvd 62.6 90 30 10 Venice Blvd between Sepulveda Blvd and Sawtelle Blvd 69.8 480 150 50 Venice Blvd between Overland Ave and Sepulveda Blvd 70.1 515 160 50 W Centinela Ave between Sepulveda Blvd & Green Valley Cir 72.3 840 265 85 W Centinela Ave between Jefferson Blvd & Sepulveda Blvd 76.1 2,045 645 205 W Jefferson Blvd between National Blvd & Obama Blvd 70.8 605 190 60 W Jefferson Blvd between Obama Blvd & Duquesne Ave 73.4 1,105 350 110 Washington Blvd between Overland Ave & Washington Pl 70.9 610 190 60 Washington Blvd between Duquesne Ave & Overland Ave 69.2 410 130 40 Washington Blvd between Washington Pl & Sepulveda Blvd 66.5 225 70 20 Washington Blvd between Culver Blvd & Duquesne Ave 67.6 285 90 30 Washington Blvd between Washington Pl & Lincoln Blvd 68.3 340 110 35 Washington Blvd between Inglewood Blvd & S Centinela Ave 69.0 395 125 40 Washington Blvd between Sawtelle Blvd & Inglewood Blvd 68.8 380 120 40 Washington Blvd between S Centinela Ave & W Washington Blvd 67.4 280 90 30 Washington Blvd between Sepulveda Blvd & Sawtelle Blvd 68.4 345 110 35 Washington Blvd between La Cienega Blvd & National Blvd 71.6 715 225 70 Washington Blvd between National Blvd & Culver Blvd 70.7 585 185 60 Washington Blvd between Fairfax Ave & La Cienega Blvd 71.3 670 210 65

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
dBA CNEL
at 50 Feet from
Centerline1
Approximate Distance to
CNEL Contour (feet)2
Roadway Segment 60 65 70
Washington Blvd between S Centinela Ave & Washington Pl 68.5 355 115 35 Washington Blvd between Duquesne Ave & Overland Dr 69.1 405 130 40 Washington Blvd between National Blvd & Overland Ave 70.6 575 180 55 Washington Blvd between Overland Ave & Sepulveda Blvd 70.7 590 185 60 Washington Pl between Washington Blvd & Sepulveda Blvd 69.2 415 130 40 Washington Pl between Inglewood Blvd & S Centinela Ave 70.4 550 175 55 Washington Pl between S Centinela Ave & W Washington Blvd 70.2 530 165 55 Washington Pl between Washington Blvd & Washington Blvd 70.8 605 190 60 Washington Pl between Sepulveda Blvd & Sawtelle Blvd 69.7 465 150 45 1 CNEL values are calculated at 50 feet from the roadway centerline. 2 All distances are measured from the centerline.

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

60 dBA CNEL Contour
The 60 dBA CNEL contour defines the noise study zone. The noise environment for any proposed noise-sensitive land use (for example, single- or multi-family residences, hospitals, schools, or churches) within this zone should be evaluated on a project-specific basis. The project may require mitigation to meet city and/or state (Title 24) standards. A site- and project-specific study will be necessary to determine mitigation measures that will help make the interior building environment acceptable for the given type of land use. Some sites may already be sufficiently protected by existing walls or berms so that no further mitigation measures are required. 65 dBA CNEL Contour
The 65 dBA CNEL contour defines the noise mitigation zone. Within this contour, new or expanded noise-sensitive developments should be permitted only if appropriate mitigation measures, such as barriers or additional sound insulation, are included and City and/or state noise standards are achieved. In some instances, it may be possible to show that existing walls, berms, or screening may exist such that required noise reduction is already in place. The inclusion of an area within a 60 or 65 dBA CNEL contour as shown on Figure 4.12-3 indicates that noise levels are high enough to be of potential concern, but does not imply that excessive noise levels are uniformly present on all sites within the area. Buildings, walls, berms, and changes in topography affect noise levels at the receiver site. Some locations may be screened from roadway noise by the presence of one or more of these features.

As indicated in Table 4.12-8, the existing roadway noise levels at 50 feet along studied roadways vary from a minimum of 62.6 dBA CNEL to a maximum of 76.1 dBA CNEL. The 65 dBA CNEL contour locations vary from 30 feet (along Machado Rd between Jefferson Blvd & Sepulveda Blvd, and Slauson Ave between W Jefferson Blvd & Washington Blvd) to 645 feet (along W Centinela Ave between Jefferson Blvd & Sepulveda Blvd) from the roadway centerline. For nearly all of these roadway links, the 65 dBA CNEL contours extend beyond the edge of right-of-way (ROW).

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).

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
Existing Noise Levels
70 dB Contour
65 dB Contour
60 dB Contour
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
Existing Noise Levels
70 dB Contour
65 dB Contour
60 dB Contour
Culver City General Plan 2045
Figure 4.12-3
Existing Roadway Noise Contour Map
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
70 dBA CNEL Contour
The 70 dBA CNEL contour defines the noise impact zone. Within this contour, new or expanded noise-sensitive developments are usually not permitted. The development of an area within a 70 dBA CNEL contour (as shown on Figure 4.12-3) indicates that noise levels are high enough to be of potential concern.

As indicated in Table 4.12-8, the existing roadway noise levels at 50 feet along studied roadways vary from a minimum of 62.6 dBA CNEL to a maximum of 76.1 dBA CNEL. The 70 dBA CNEL contour locations vary from 10 feet (along Machado Rd between Jefferson Blvd & Sepulveda Blvd, and Slauson Ave between W Jefferson Blvd & Washington Blvd) to 205 feet (along W Centinela Ave between Jefferson Blvd & Sepulveda Blvd) from the roadway centerline. For the majority of these roadway links, the 70 dBA CNEL contours extend beyond the edge of ROW.

Sensitive Receptors
A noise-sensitive receptor would be any location where excessive noise levels would interfere with an individual’s normal sleeping activities, normal conversation, or ability to work. Some land uses are more sensitive to high noise levels than others, due to the usage of the occupants at these land uses. Such land uses include residential neighborhoods, hotels and motels, trailer parks, schools, churches and other places of worships, hospitals, long-term medical or mental care facilities, libraries, concert halls, and other land uses that include outdoor active uses with people spending a good amount of time periods in their outdoor areas.

4.12.5 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 noise if the project would result in:

Threshold NOI-1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

Threshold NOI-2: Generation of excessive groundborne vibration or groundborne noise levels.

Threshold NOI-3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.

The Initial Study (Appendix A) found no potentially significant impacts related to airport land use plans (Threshold NOI-3); therefore, this issue is not evaluated in this section. Please see Appendix A for further discussion.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Methodology
Construction Noise and Vibration
For construction-related noise from development of future projects under the General Plan and Zoning Code Update, typical construction equipment noise levels recommended for noise impact assessments, based on a distance of 50 feet between the equipment and a noise receptor, are taken from the FHWA Roadway Construction Noise Model (RCNM).21 Construction vibration impacts were evaluated using FTA methodology from the FTA Transit Noise and Vibration Impact Assessment Manual.
22 Building or structure setback distances for
preventing vibration damage were evaluated using reference vibration levels for specific construction equipment.

Traffic Noise
During operation of future projects under the General Plan and Zoning Code Update, noise generated from mobile noise sources such as vehicular traffic is assessed with the FHWA- approved traffic noise source noise modeling guidelines. For stationary sources, equipment source noise levels included in the FHWA RCNM are used for the impact analysis. 23 Railway Noise
Specific details on future railway expansions or improvements are unknown at this time, neither are the specific noise sources that might occur in conjunction with development of land uses near the railway under the Project. Therefore, railway noise and vibration impacts are discussed on a qualitative basis.

Stationary Noise
Specific details on future mechanical equipment or HVAC equipment and layout are unknown at this time, neither are the specific noise sources that might occur in conjunction with development of land uses allowable under the Project. Therefore, stationary and other noise source impacts are discussed on a qualitative basis.

Project Impacts Analysis
Temporary or Permanent Increase in Ambient Noise Levels Threshold NOI-1: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code Update would generate a substantial temporary or permanent increase in ambient noise levels in the vicinity of the Project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies.

21 FHWA, Roadway Construction Noise Model User’s Guide, 2006. 22 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018. 23 FHWA, Roadway Construction Noise Model User’s Guide, 2006.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Statement NOI-1: The Project would result in a potentially significant impact during construction and operation of future development projects that could exceed the significance thresholds. Implementation of mitigation would help to reduce the severity of the impacts; however, impacts could still exceed the significance thresholds and impacts would be significant and unavoidable.

Construction Noise
Construction of future development under the General Plan Update would require the use of heavy equipment during the demolition, grading, excavation, and other construction activities within the Planning Area. During each stage of development for any given construction project, a different mix of equipment would be used. As such, construction activity noise levels would fluctuate depending on the particular type, number, and duration of use of the various pieces of construction equipment.

Individual pieces of representative construction equipment types that could be expected to be used during construction activities of future projects could produce maximum noise levels of 75 dBA to 101 dBA Lmax at a reference distance of 50 feet from the noise source, as shown in Table 4.12-9, Construction Equipment Noise Levels. These maximum noise levels would occur when equipment is operating at full power. The estimated usage factor for the equipment is also shown in Table 4.12-9. The usage factors are based on FHWA’s RCNM User’s Guide. 24 The exact locations of future projects and construction that would occur under the proposed General Plan Update are not known at this time, though it is assumed that some of the activities would take place in close proximity to sensitive receptors given that the City is generally built out. The severity of construction-related noise impacts depends on the proximity of construction activities to sensitive receptors, the presence of intervening barriers, the number and types of equipment used, and the duration and intensity of the activity. While the details of these factors are not available for future projects, it is assumed that individual projects would be implemented in compliance with the restrictions of the CCMC. Proposed General Plan Update Policies N-4.1, N-4.2, and N-4.4 are related to minimizing noise generated from construction activities.

In addition, for future development projects requiring discretionary approval, a project-specific noise analysis would be prepared to determine significance in accordance with CEQA. Through each environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual projects that exceed the thresholds would normally result in a potentially significant impact and require the implementation of mitigation measure(s).

Even with mandatory compliance with Municipal Code requirements, it is possible that some future development projects requiring discretionary approval could be large in construction intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period noise levels could exceed the significance thresholds. Therefore, project-related construction activities could result in a significant impact and mitigation measure(s) would be required.

24 FHWA, Roadway Construction Noise Model User’s Guide, 2006.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-25 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.12-9

C ONSTRUCTION EQUIPMENT NOISE LEVELS
Construction Equipment Estimated Usage Factor
Noise Level at 50 Feet
(dBA Lmax)
Air Compressors 40% 78
Bore/Drill Rig 20% 79
Cement and Mortar Mixer 40% 79
Compactor 20% 83
Concrete Saw 20% 90
Crane 16% 81
Dumpers/Tenders 40% 76
Excavator 40% 81
Forklift 10% 75
Generator Sets 50% 81
Jackhammers 20% 89
Off-Highway Trucks 20% 76
Other Equipment 50% 85
Paver 50% 77
Paving Equipment 20% 90
Roller 20% 80
Rough Terrain Forklift 10% 75
Rubber Tired Loader 50% 79
Surfacing Equipment 50% 85
Tractor/Loader/Backhoe 25% 80
Vacuum Street Sweeper 10% 82
Vibratory Pile Driver 20% 101
SOURCE: FHWA, Roadway Construction Noise Model User’s Guide, 2006.

Traffic Noise
Future development under the General Plan Update would generate traffic that would increase noise levels along existing and future roadways. Proposed General Plan Update Policies N-3.1, N-

3.2, N-3.3, N-3.4, N-3.5, N-3.6, and N-3.7 are related to minimizing noise generated from roadway mobile sources. The FHWA TNM methodology was used to evaluate future (204 5) traffic-related noise conditions in the C ity for 62 roadway segments located in the city, using data for future (2045) VMT and traffic volumes for non-truck vehicles and light-duty, medium-duty, and heavy- duty trucks on study roadway segments from the Culver City Citywide Travel Demand Forecasting Model (see Appendix F2 of this Draft EIR for traffic data). The FHWA TNM methodology calculates the average noise level at specific locations based on traffic volumes, average speeds, and site environmental conditions.

Table 4.12-10, Future Roadway Noise Levels, provides the future buildout noise levels at 50 feet from the centerline of these roadway segments and the distances to the 60, 65, and 70 dBA

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-26 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CNEL future roadway noise contours shown in Figure 4.12-4, Future Roadway Noise Contour Map. As shown in Table 4.12-10, traffic noise along the analyzed roadway segments would not be discernably different for the majority of the segments when future no project levels are compared to future roadway noise levels with implementation of the General Plan Update. The maximum increase would be 4.2 dBA (from 66.0 to 70.2 dBA CNEL) along Washington Boulevard between Inglewood Boulevard and S Centinela Avenue, which is characterized by a mix of commercial and multi-family residential uses. All other modeled segments would increase by less than 3 dBA CNEL. An increase in traffic noise levels measured at the property line of affected uses of 3 dBA CNEL or more, to or within the “normally unacceptable” or “clearly unacceptable” categories, or an increase of 5 dBA CNEL or more, within the “normally acceptable” or “conditionally acceptable,” categories is considered a significant impact.

Therefore, as the traffic noise increase along Washington Boulevard between Inglewood Boulevard and S Centinela Avenue could exceed 3 dBA CNEL, to or within the “normally unacceptable” or “clearly unacceptable” categories, the impact from traffic noise would potentially significant and unavoidable.

TABLE 4.12-10

F UTURE ROADWAY NOISE LEVELS

Future Plus Project Distance
(feet) to Centerline to
Future No
Project
Noise
Levels
Future Plus
Project
Noise
Levels Increase
Roadway Segment
60 dBA
CNEL
Contour
65 dBA
CNEL
Contour
70 dBA
CNEL
Contour
dBA CNEL at 50 Feet from
Centerline
Adams Blvd between Washington Blvd & Fairfax Ave 130 40 15 63.9 64.2 0.3 Culver Blvd between Overland Ave & Sepulveda Blvd 1,225 390 125 73.5 73.9 0.4 Culver Blvd between Sepulveda & Sawtelle Blvd 1,210 380 120 73.5 73.8 0.3 Culver Blvd between Washington Blvd & Duquesne Ave 575 180 60 70.3 70.6 0.3 Culver Blvd between Washington Blvd & Washington Blvd 625 195 60 70.7 71.0 0.3 Culver Blvd between Duquesne Ave & Overland Ave 1,545 490 155 74.4 74.9 0.5 Fairfax Ave between Washington Blvd & La Cienega Blvd 770 245 75 71.8 71.9 0.1 Jefferson Blvd between Slauson Ave & Inglewood Blvd 895 280 90 72.2 72.5 0.3 Jefferson Blvd between Sepulveda Blvd & Slauson Ave 195 60 20 68.4 65.9 -2.5 Jefferson Blvd between Overland Ave & Sepulveda Blvd 600 190 60 72.4 70.8 -1.6 Jefferson Blvd between Duquesne Ave & Overland Ave 790 250 80 72.9 72.0 -0.9 Jefferson Blvd between Overland Ave & Sawtelle Blvd 285 90 30 69.4 67.6 -1.8 Jefferson Blvd between Obama Blvd & Duquesne Ave 935 295 95 73.5 72.7 -0.8 Machado Rd between Jefferson Blvd & Sepulveda Blvd 90 30 10 61.6 62.5 0.9 Overland Ave between Venice Blvd & Washington Blvd 500 160 50 69.9 70.0 0.1 Overland Ave between Washington Blvd & Culver Blvd 750 235 75 71.5 71.8 0.3 Overland Ave between Culver Blvd & Jefferson Blvd 815 260 80 71.6 72.1 0.5 Overland Ave between Jefferson Blvd & Sawtelle Blvd 640 205 65 68.6 71.1 2.5 S Centinela Ave between Washington Blvd & Culver Blvd 380 120 40 70.4 68.8 -1.6

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-27 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

Future Plus Project Distance
(feet) to Centerline to
Future No
Project
Noise
Levels
Future Plus
Project
Noise
Levels Increase
Roadway Segment
60 dBA
CNEL
Contour
65 dBA
CNEL
Contour
70 dBA
CNEL
Contour
dBA CNEL at 50 Feet from
Centerline
S Centinela Ave between Venice Blvd & Washington Pl 1,020 325 100 72.9 73.1 0.2 S Centinela Ave between Washington Pl & W Washington Blvd 710 225 70 71.4 71.5 0.1 S Fairfax Ave between Venice Blvd & Washington Blvd 755 240 75 71.8 71.8 0.0 S La Cienega Blvd between Fairfax Ave & W Jefferson Blvd 1,330 420 135 74.1 74.3 0.2 S La Cienega Blvd between Venice Blvd & Washington Blvd 940 300 95 72.6 72.8 0.2 S La Cienega Blvd between Washington Blvd & Fairfax Ave 1,370 435 135 74.2 74.4 0.2 Sepulveda Blvd between Slauson Ave & W Centinela Ave 1,140 360 115 73.6 73.6 0.0 Sepulveda Blvd between Culver Blvd & Jefferson Blvd 550 175 55 71.2 70.4 -0.8 Sepulveda Blvd between Washington Blvd & Culver Blvd 305 95 30 68.6 67.9 -0.7 Sepulveda Blvd between Venice Blvd & Washington Pl 495 155 50 70.1 70.0 -0.1 Sepulveda Blvd between Washington Pl & Washington Blvd 355 110 35 69.0 68.5 -0.5 Sepulveda Blvd between Jefferson Blvd & Slauson Ave 1,275 405 125 75.5 74.1 -1.4 Sepulveda Blvd between Sawtelle Blvd & Jefferson Blvd 1,245 395 125 76.1 74.0 -2.1 Sepulveda Blvd between Jefferson Blvd & Sawtelle Blvd 975 310 100 73.9 72.9 -1.0 Slauson Ave between Jefferson Blvd & Sepulveda Blvd 925 290 90 71.6 72.7 1.1 Slauson Ave between W Jefferson Blvd & Washington Blvd 1,205 380 120 73.1 73.8 0.7 Venice Blvd between Sepulveda Blvd and Sawtelle Blvd 640 200 65 71.0 71.1 0.1 Venice Blvd between Overland Ave and Sepulveda Blvd 615 195 60 70.8 70.9 0.1 W Centinela Ave between Sepulveda Blvd & Green Valley Cir 1,405 445 140 74.6 74.5 -0.1 W Centinela Ave between Jefferson Blvd & Sepulveda Blvd 3,660 1,155 365 78.2 78.6 0.4 W Jefferson Blvd between National Blvd & Obama Blvd 555 175 55 69.9 70.4 0.5 W Jefferson Blvd between Obama Blvd & Duquesne Ave 940 300 95 73.5 72.8 -0.7 Washington Blvd between Overland Ave & Washington Pl 560 175 55 70.3 70.5 0.2 Washington Blvd between Duquesne Ave & Overland Ave 440 140 45 69.3 69.4 0.1 Washington Blvd between Washington Pl & Sepulveda Blvd 255 80 25 66.3 67.1 0.8 Washington Blvd between Culver Blvd & Duquesne Ave 215 70 20 66.4 66.4 0.0 Washington Blvd between Washington Pl & Lincoln Blvd 265 85 25 66.7 67.2 0.5 Washington Blvd between Inglewood Blvd & S Centinela Ave 525 165 55 66.0 70.2 4.2 Washington Blvd between Sawtelle Blvd & Inglewood Blvd 305 95 30 67.3 67.9 0.6 Washington Blvd between S Centinela Ave & W Washington Blvd 280 90 30 66.9 67.5 0.6 Washington Blvd between Sepulveda Blvd & Sawtelle Blvd 290 90 30 66.8 67.7 0.9 Washington Blvd between La Cienega Blvd & National Blvd 565 180 55 70.2 70.5 0.3 Washington Blvd between National Blvd & Culver Blvd 415 130 40 68.8 69.2 0.4 Washington Blvd between Fairfax Ave & La Cienega Blvd 565 180 55 70.2 70.5 0.3 Washington Blvd between S Centinela Ave & Washington Pl 345 110 35 67.9 68.4 0.5

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-28 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

SOURCE: ESA, 2024; Fehr & Peers, 2024 (VMT and traffic volume data). Refer to noise modeling provided in Appendix F.

Railway Noise
As previously discussed, the Metro E Line passes through the northeast portion of the City along National Boulevard and crosses Washington, Robertson, and Venice Boulevards. The Culver City Station is located just east of the intersection of Venice Boulevard and S. Robertson Boulevard.

Proposed General Plan Update Policies N-3.3, N-3.5, and N-3.8 are related to minimizing noise generated from mass transit railway sources. New or renovated noise-sensitive uses proposed along the Metro E Line route in Culver City and requiring discretionary approval would be required to evaluate potential train noise levels at the individual site and, if required, incorporate building designs or mitigation measures to meet applicable exterior and/or interior noise standards. Therefore, the impact from railway noise would be less than significant.

Stationary Noise
Future development under the General Plan Update could expose existing and new sensitive receptors to stationary noise sources, such as, rooftop heating, ventilation, and air conditioning units. In addition, growth anticipated under the General Plan Update could expose existing and new sensitive receptors to stationary noise sources, particularly those associated with industrial uses. Any new development under the General Plan Update would be subject to the Culver City Municipal Code noise control ordinance. In addition, future projects would need to demonstrate consistency with the proposed General Plan policies aimed at reducing noise levels from adjacent properties. Proposed General Plan Update Policies N-5.1 and N-5.2 are related to minimizing noise generated from stationary sources. Through compliance with the Culver City Municipal Code noise control ordinance and General Plan policies, the impact from stationary noise would be less than significant.

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).

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
Future Noise Levels
70 dB Contour
65 dB Contour
60 dB Contour
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
Future Noise Levels
70 dB Contour
65 dB Contour
60 dB Contour
Culver City General Plan 2045
Figure 4.12-4
Future Roadway Noise Contour Map
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-30 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Zoning Code Update
The Zoning Code Update would establish new zoning districts and associated development standards to correspond with and implement the General Plan Update within the city. Future development would be required to comply with applicable noise control ordinances and standards as discussed above. Nonetheless, it is possible that some future development projects requiring discretionary approval could be large in construction intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period noise could exceed project-level significance thresholds. It is also possible that some future development projects could be large enough in size and/or intensity such that operational roadway traffic noise could exceed project-level significance thresholds. Therefore, future development within the City under the Project would result significant impact related to a substantial temporary or permanent increase in ambient noise levels and mitigation measures would be required.

Applicable Proposed General Plan Goals and Policies
Noise Element
Goal N-1: A peaceful community. A community with a peaceful noise environment that reduces or prohibits new sources of intrusive noise and effectively enforces noise standards.

N-1.1: Interior and exterior noise restrictions. Enforce the City’s interior and exterior noise restrictions.

N-1.2: Land use decisions. Consistently apply noise standards and criteria in all land use decisions.

N-1.3: Noise evaluation. For proposed development in areas louder than 60 dBA CNEL, require noise evaluation for compliance with the State’s 45 dBA CNEL interior noise levels standards.

N-1.4: Noise reduction measures. If new development does not meet the City’s interior and exterior noise standards, require that noise reduction features are implemented in the development.

N-1.5: Noise reduction strategies. Implement noise reduction strategies in new developments that would generate noise that could impact nearby sensitive land uses.

N-1.6: Noise reduction strategies. Implement noise reduction strategies in new developments that would generate noise that could impact nearby sensitive land uses.

N-1.7: Noise regulation enforcement coordination. Ensure the Code Enforcement Division continues to coordinate with the Culver City Police Department on enforcing noise regulations set forth in the Culver City Municipal Code.

Goal N-2: Adjacent uses. A City review and approval process for new development that ensures projects are compatible with adjacent land uses.

N-2.1: Noise compatibility. In the land use planning process, consider noise compatibility with existing and proposed land uses, along with the anticipated increase in development needed to accommodate growth.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-31 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
N-2.2: Land Use and Noise Compatibility Matrix. Use the “Land Use and Noise Compatibility Matrix” to assess the compatibility of proposed land uses with the noise environment.

N-2.3: Noise analysis and implementation methods. As appropriate, require a noise analysis and implementation of methods to minimize noise for land uses that are not “clearly compatible” as indicated by the Land Use and Noise Compatibility Matrix.

N-2.4: Land use incompatibility. Evaluate and identify ways to avoid locating incompatible land uses adjacent to freeways, and noisy industrial or recreational activities in the land use planning and development/environmental review process.

Goal N-3: Mobile sources of noise. A community that experiences minimal noise disturbance from transportation sources.

N-3.1: Roadway noise. Minimize noise impacts to noise-sensitive land uses from vehicles traveling on major and minor arterial roadways within the city.

N-3.2: Noise exposure from future planning. Coordinate land use and circulation plans to protect against noise exposure from future projects.

N-3.3: Coordination with regional transportation agencies for noise abatement measures. Coordinate with regional transportation agencies in the planning and development, maintenance, or redevelopment of existing and future transportation corridors, including mass transportation, to include noise abatement measures that comply with the City’s standards.

N-3.4: Truck movements. Evaluate truck movements and routes within the city to provide effective separation from residential or other noise-sensitive land uses. Review the City’s Municipal Code Traffic Regulations to ensure that designated truck routes do not negatively impact residential areas or other noise-sensitive land uses. Limit truck movements to those arterials designed to handle the traffic and those located further from the noise-sensitive areas.

N-3.5: Noise reduction technology. Mitigate City-controlled transportation-related noise sources through a program of technological improvements, like converting to electric vehicles.

N-3.6: Noise reduction measures from roadway projects. Consider noise reduction measures when designing roadway projects that may adversely affect sensitive land uses. Noise control measures may include increased vegetation, improving and maintaining roadway pavement, those related to site and building design features, and adding sound wall barriers.

N-3.7: Freeway noise impact coordination. Consult with the California Department of Transportation to minimize noise impacts from major freeways adjacent to residential or other sensitive land uses like SR-90, I-405, and I-10. Noise attenuation measures may include using alternative paving materials that can reduce traffic noise depending on roadway conditions and cost-efficiency, or constructing noise barriers, that break the “line of sight” between the noise source and potential receptors.

N-3.8: Noise from Metro transportation system. Minimize noise impacts from the Metro transportation system on residential and other sensitive land uses. For example,

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-32 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
coordinate with Metro to install noise attenuation features if the system negatively affects residential and other sensitive land uses.

N-3.9: Aircraft noise. Minimize noise impacts from aircraft flyovers through ground based mitigation strategies such as enhanced building shell noise reduction to comply with interior noise standard of 45 dBA CNEL.

N-3.10: Coordination with the Los Angeles World Airports and Federal Aviation Administration. Monitor LAX development process for potential impacts on Culver City, including the expansion of terminals and gates that may be used to accommodate increased operations, and make recommendations for mitigation.

N-3.11: LAX/Community Noise Roundtable. Continue to participate in the LAX/Community Noise Roundtable.

N-3.12: Monitor changes to aircraft operations implemented by the Federal Aviation Administration. Continue to work with Los Angeles International Airport and the Federal Aviation Administration to ensure that all applicable mitigation, both operational and construction, is provided.

Goal N-4: Construction noise. Minimized noise and vibration generated from construction activities.

N-4.1: Limit disturbance from new construction. Minimize construction noise and vibration impacts to reduce the disturbance from new development.

N-4.2: Construction hour enforcement. Enforce limits on construction hours as included in the City’s Municipal Code.

N-4.4: Noise-sensitive construction techniques. Encourage using construction techniques that minimize noise and vibration levels.

Goal N-5: Stationary sources of noise. Minimize noise generated from operational stationary sources, including industrial and commercial activity, entertainment, sporting and other outdoor events, maintenance activity, and machinery.

N-5.1: Event noise. Minimize noise impacts from major outdoor events at educational institutions, parks, and other locations within the city.

N-5.2: Machinery noise. Minimize noise impacts from machinery, including pool and spa pumps, power tools in garages, gardening tools, and gasoline-powered leaf blowers.

Enforce restrictions included in the Noise Ordinance limiting noise generated from these sources. Require screening or other noise reducing methods in the Building Permit process.

Mitigation Measures
As discussed above, it is possible that some future development projects under the General Plan and Zoning Code Update requiring discretionary approval could generate construction-period or operational-period roadway traffic noise levels that exceed the significance thresholds and result in a significant impact. Therefore, the following mitigation measure would be required.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
MM NOI-1: Construction Noise. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) shall submit a noise study to the City Planning Department for review and approval prior to issuance of a grading or building permit. The study shall include noise-reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards as applicable to construction (i.e., CCMC Chapter 9.07). All noise-reduction measures approved by City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during construction activities. Potential noise-reduction measures may include, but are not limited to, one or more of the following, as applicable to the project:
• Install temporary sound barriers for construction activities that occur adjacent to occupied noise-sensitive receptors.
• Equip construction equipment with effective mufflers, sound-insulating hoods or enclosures, vibration dampers, and other Best Available Control Technology (BACT). • Limit non-essential idling of construction equipment to no more than five minutes per hour.

This mitigation measure shall not apply and is superseded once a Citywide noise ordinance goes into effect that establishes construction noise standards for noise- reduction measures that ensures project construction noise compliance with the Culver City Noise Ordinance standards for development projects within the City.

Level of Significance After Mitigation
Implementation of Mitigation Measure MM NOI-1 would help to reduce the potentially significant construction-related impacts resulting from a substantial temporary increase in ambient noise levels in the vicinity of future development projects in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies. However, even with implementation of Mitigation Measure MM NOI-1, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

There are no feasible mitigation measures to reduce traffic noise levels. While General Plan Update policies would serve to limit traffic noise exposure to sensitive receptors, these policies cannot ensure that noise levels would be reduced to levels within the City’s noise standards at all sensitive receptors. The ability to reduce impacts along roadways with measures such as sound walls or berms may not be feasible. The installation of traffic noise barriers along Washington Boulevard between Inglewood B oulevard and S Centinela Avenue, which is characterized by a mix of commercial and multi -family residential uses, is not possible as such barrier would prohibit the ability for pedestrians, visitors, and occupants to access the commercial and multi-family residential buildings. Barriers with breaks or gaps for standards and emergency access would negate intended noise reduction benefits. No additional feasible mitigation measures are available beyond consistency with proposed General Plan Update policies. Therefore, traffic noise impacts would be significant and unavoidable.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Excessive Groundborne Vibration or Groundborne Noise
Threshold NOI-2: The Project would have a significant impact if future development allowed by the General Plan and Zoning Code updates w ould generate excessive groundborne vibration or groundborne noise.

Impact Statement NOI-2: The Project would result in a potentially significant impact during construction of future development projects that could exceed the significance thresholds.

While implementation of mitigation measures would reduce the severity of the impacts, impacts could still exceed the significance thresholds. Thus, groundborne vibration or groundborne noise during construction would be significant and unavoidable. The Project would result in a less than significant impact related to excessive groundborne vibration or groundborne noise during operation of future development projects.

The General Plan Update would allow for the construction of new developments or renovations to existing developments to achieve the objectives of the Project as outlined in Chapter 2, Project Description. The exact locations of future projects and construction methods for the future projects are not known at this time, However, it is assumed that some of the activities would take place in close proximity to sensitive receptors given that the City is generally built out.

Proposed General Plan Update Policies N-4.1, N-4.2, N-4.3, and N-4.4 are related to minimizing groundborne noise and groundborne vibration generated from construction activities. The severity of construction-related vibration impacts depends on the proximity of construction activities to sensitive receptors, the types of equipment used, and the duration and intensity of the activity.

Vibration levels measured in RMS are best for characterizing human response to vibration and vibration levels measured in PPV are best for characterizing the potential for building or structure damage. Therefore, vibration impact analyses describe the potential for human annoyance impacts using vibration levels in VdB and the potential for building damages using vibration levels in PPV (inch/sec).

Groundborne vibration and groundborne noise impacts occur normally within building interiors or at a physical structure. Therefore, groundborne vibration and groundborne noise impacts are normally assessed based on the distance from the source of the vibration, which is typically vibration-generating equipment used within the construction area boundary, to the nearest building or structure. Reference vibration levels in PPV (inch/sec) and VdB for construction equipment at a reference distance of 25 feet are provided in Table 4.12-11, Vibration Source Amplitudes for Construction Equipment.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.12-11

VIBRATION SOURCE AMPLITUDES FOR CONSTRUCTION EQUIPMENT
Equipment
Reference PPV/LV at 25 Feet
PPV (inch/sec) LV (VdB)
Pile Driver (impact), upper range 1.518 112
Pile Driver (impact), typical 0.644 104
Pile Driver (sonic), upper range 0.734 105
Pile Driver (sonic), typical 0.170 93
Clam shovel drop (slurry wall) 0.202 94
Hydromill (slurry wall), in soil 0.008 66
Hydromill (slurry wall), in rock 0.017 75
Vibratory Roller 0.210 94
Hoe Ram 0.089 87
Large Bulldozer 0.089 87
Caisson Drilling 0.089 87
Loaded Trucks 0.076 86
Jackhammer 0.035 79
Small Bulldozer 0.003 58
NOTES: PPV = peak particle velocity; LV = velocity in decibels; inch/sec = inches per second; VdB = vibration velocity decibels
SOURCE: FTA 2018, Table 7-4.

Structural Damage During Construction
Based on Table 4.12-2, a vibration level of more than 0.12 inch/sec PPV, 0.2 inch/sec PPV, 0.3 inch/sec PPV, or 0.5 PPV inch/sec would potentially result in building or structure damage, depending on the building or structure category, with fragile buildings or structures at the lowest end of the range and reinforced buildings or structures at the higher end of the range.

Table 4.12-11 shows that most construction equipment would not result in a vibration level that would exceed 0.12 inch/sec PPV measured at a distance of 25 feet with the exception of certain types of pile driving and clam shovel equipment. However, if equipment were to operate closer than 25 feet to a building or structure, groundborne vibration levels would be higher than shown in Table 4.12-11 and may exceed the threshold levels, depending on the actual distance.

Depending on the proximity of the future developments to vibration-sensitive buildings or structures, construction activities could generate excessive ground vibration and potentially exceed damage criteria for surrounding existing structures. Construction-generated groundborne vibration may exceed the criteria for structural damage at structures near future projects, which would result in a significant impact. The intensity of construction activities and locations of the future projects would dictate whether the level of groundborne vibration and groundborne noise during construction would be above or below the significance thresholds.

For future development requiring discretionary approval, a project-specific groundborne vibration and groundborne noise analysis would be prepared to determine significance in accordance with

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-36 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CEQA. Through each environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual projects that exceed the thresholds would normally result in a potentially significant impact and require the implementation of mitigation measure(s). It is possible that some future projects facilitated by the General Plan Update would be large in construction intensity or located near vibration-sensitive buildings or structures, such that multiple pieces of equipment or other sources of groundborne vibration and/or groundborne noise would cause levels to exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual. Therefore, construction activities for future projects facilitated by the General Plan Update could result in significant construction groundborne vibration and groundborne noise levels in excess of standards and result in a significant impact and mitigation measure(s) would be required.

Human Annoyance During Construction
Based on the reference vibration levels from construction equipment shown in Table 4.12-11, some equipment could exceed groundborne vibration human annoyance criteria. As previously discussed, Table 8-3 in the FTA’s Transit Noise and Vibration Impact Assessment Manual states that the vibration criteria for analysis is typically 78 VdB for residential uses during daytime hours.

During nighttime hours, the vibration criterion is 72 VdB. For office and commercial buildings, the FTA guidelines suggest that a vibration level of 84 VdB should be used for detailed analysis. Table

4.12-11 shows that some equipment would exceed these values at a reference distance of 25 feet.

Depending on the proximity of the future developments to vibration-sensitive receptors, construction activities could generate excessive ground vibration and potentially exceed the human annoyance criteria for surrounding receptors. The construction intensity and locations of the future projects would dictate whether the level of groundborne vibration and groundborne noise during construction would be above or below the significance thresholds. For future development requiring discretionary approval, a project-specific groundborne vibration and groundborne noise analysis would be prepared to determine significance in accordance with CEQA.

Through each environmental review process, potential impacts would be identified and compared against relevant thresholds. Individual projects that exceed the thresholds would normally result in a potentially significant impact and require the implementation of mitigation measure(s). It is possible that some future projects facilitated by the General Plan Update would be large in construction intensity or located near vibration-sensitive receptors, such that multiple pieces of equipment or other sources of groundborne vibration and/or groundborne noise would cause levels to exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual.

Therefore, construction activities for future projects facilitated by the General Plan Update could result in significant construction groundborne vibration and groundborne noise levels in excess of standards and result in a significant impact and mitigation measure(s) would be required.

Structural Damage and Human Annoyance During Operation
The operation of future development requiring discretionary approval facilitated by adoption of the General Plan Update could generate groundborne vibration and groundborne noise from

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-37 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
vehicle and truck traffic on roadways and from stationary mechanical equipment such as pumps and compressors.

With respect to groundborne vibration and groundborne noise from vehicle and truck traffic, Caltrans has studied the impacts of propagation of vehicle vibration on sensitive land uses and notes that “heavy trucks, and quite frequently buses, generate the highest earthborne vibrations of normal traffic”.
25 Caltrans further notes that the highest traffic-generated vibrations are along freeways and state routes. Their study finds that “vibrations measured on freeway shoulders (5 m [meters] from the centerline of the nearest lane) have never exceeded 2 mm/s [millimeters per second], with the worst combinations of heavy trucks” and that “[t]his amplitude coincides with the maximum recommended ‘safe level’ for ruins and ancient monuments (and historic buildings)”.
26 A vibration level of 2 millimeters per second is approximately 0.08 in/sec. Typically, groundborne vibration generated by human-made activities attenuates rapidly with distance from the source of the vibration. Vehicles traveling along freeways and state routes would cause infrequent and inconsistent vibration events that would attenuate quickly after onset. Sensitive receptors would likely be located further away than 15 meters from a freeway or highway and would therefore experience levels lower than 0.08 in/sec. Further, the FTA guidelines state that buildings that are extremely susceptible to building damage (e.g., historic buildings) could experience structural damage at 0.12 in/sec. Thus, roadway traffic is not expected to generate excessive vibration in excess of the FTA’s threshold of 0.12 in/sec for extremely susceptible buildings and associated impacts would be less than significant. Similarly, the infrequent and inconsistent vibration events combined with typical distances of buildings from freeways and highways would ensure impacts related to human annoyance would be less than significant and no mitigation is required.

With respect to groundborne vibration and groundborne noise from stationary mechanical equipment, according to the American Society of Heating, Refrigerating and Air-Conditioning Engineers (ASHRAE), stationary equipment such as pumps and compressors generate groundborne vibration levels of 0.5 in/sec PPV at 1 foot (ASHRAE 1999). At 25 feet, this vibration level drops to approximately 0.004 in/sec PPV at 25 feet (approximately 60 VdB). Any future project that includes stationary equipment would locate such equipment on building rooftops or within or near buildings such that the equipment would not generate groundborne vibration off the project site. Therefore, groundborne vibration from the operation of such mechanical equipment is not expected to generate excessive vibration. Groundborne vibration and groundborne noise impacts during operation would be less than significant and no mitigation is required.

25 Caltrans, Transportation and Construction Vibration Guidance Manual, April 2020. 26 Caltrans, Transportation and Construction Vibration Guidance Manual, April 2020.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-38 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
in construction intensity or located near vibration-sensitive receptors, such that multiple pieces of equipment or other sources of groundborne vibration and/or groundborne noise would cause levels to exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance. Therefore, construction of future development within the City under the Project would result significant impact related to excessive groundborne vibration or groundborne noise and mitigation measures would be required. Operation of future development projects requiring discretionary approval within the City under the Project could generate groundborne vibration and groundborne noise from vehicle and truck traffic on roadways and from stationary mechanical equipment such as pumps and compressors. As discussed above, groundborne vibration and groundborne noise from operational sources would be characterized as typically low and would be expected to exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance. Groundborne vibration and groundborne noise impacts during operation would be less than significant and no mitigation is required.

Applicable Proposed General Plan Goals and Policies
Noise Element
Goal N-4: Construction noise. Minimized noise and vibration generated from construction activities.

N-4.1: Limit disturbance from new construction. Minimize construction noise and vibration impacts to reduce the disturbance from new development.

N-4.2: Construction hour enforcement. Enforce limits on construction hours as included in the City’s Municipal Code.

N-4.3: Construction vibration analysis. Require analysis of construction vibration in accordance with established construction vibration guidelines.

N-4.4: Noise-sensitive construction techniques. Encourage using construction techniques that minimize noise and vibration levels.

Mitigation Measures
As discussed above, it is possible that some future development projects under the General Plan and Zoning Code Update requiring discretionary approval could generate construction-period groundborne vibration and groundborne noise levels that exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance and result in a significant impact. Therefore, the following mitigation measure would be required.

MM NOI-4.12-2: Construction Vibration. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that are located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) shall submit a vibration impact evaluation to the City Planning Department for review and approval prior to issuance of

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-39 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
a grading or building permit. The evaluation shall include a list of project construction equipment and the associated vibration levels and a predictive analysis of potential project vibration impacts. If construction-related vibration is determined to exceed applicable standards, project-specific measures shall be required to ensure project compliance with vibration standards. All project-specific measures approved by the City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during project construction.

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

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

Level of Significance After Mitigation
Implementation of Mitigation Measure MM NOI-2 stated above would reduce the severity of the impacts to excessive groundborne vibration or groundborne noise. However, even with implementation of Mitigation Measure MM NOI-2, impacts during construction could exceed the significance thresholds and construction impacts would be significant and unavoidable.

Groundborne vibration and groundborne noise impacts during operation would be less than significant and no mitigation is required.

4.12.6 Cumulative Impacts Analysis
The geographic context for the analysis of cumulative noise and vibration impacts depends on the impact being analyzed. For construction and operational stationary source impacts, only the immediate area around an individual development site would be included in the cumulative context. For operational roadway related impacts, the context is existing and future development in Culver City, in conjunction with ambient growth and other development within the vicinity of the City.

Noise
Construction
An increase in noise at sensitive uses would occur as a result of the construction of multiple development projects allowed under the Project. Where projects in the vicinity are adjacent to

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-40 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
the construction of development projects allowed under the General Plan and Zoning Code Update, the combined construction noise levels would have a cumulative effect on nearby sensitive uses. Noise is not strictly additive, and a doubling of noise sources would not cause a doubling of noise levels, but would result in a 3 dBA increase over a single source. However, cumulative construction noise levels could be in excess of the noise standards established in the CCMC Noise Ordinance standards, thus resulting in a cumulative construction noise impact.

Determining the exact location and potential noise levels of future construction activities would be considered speculative at this time. Further, construction noise levels would be considered a temporary nuisance, as the increase in noise levels would only occur during the use of construction equipment associated with each development project. As discussed earlier, construction at each site within the City would be required to comply with the CCMC Noise Ordinance. Noise is a localized phenomenon, and because the City is predominately developed with urban uses, it is possible that multiple construction projects could occur simultaneously and in close enough proximity to each other to create a significant combined noise impact.

Therefore, the contribution of the Project to any potential cumulative construction noise impact would be cumulatively considerable.

Stationary
Future development that would occur as a result of the Project would include stationary noise sources such as, rooftop heating, ventilation, and air conditioning units. Any new development would be subject to the CCMC noise control ordinance and to General Plan and Zoning Code Update policies aimed at reducing noise levels from adjacent properties. The City is predominately developed with urban uses; thus, periodic infill development or redevelopment of existing uses in various areas of the City would be expected to occur. Through compliance with the CCMC noise control ordinance , the impact from stationary noise would not be cumulatively considerable.

Traffic
Permanent increases in noise would occur primarily as a result of increased traffic on local roadways due to development that would occur under the Project and ambient growth through 2045 throughout the region. Related development in adjacent jurisdictions may contribute traffic to the city roadway network. Cumulative traffic-generated noise impacts have been assessed based on the contribution of the Project to the future cumulative base traffic volumes in the project vicinity. Table 4.12-12, Cumulative Traffic Noise Impacts, shows the impact of cumulative traffic noise at General Plan buildout on existing sensitive receptors, such as the residences near the roadway segments. The 2045 General Plan Buildout traffic volumes, which includes increases in traffic due to ambient growth in surrounding areas, is compared to existing traffic volumes. As shown, existing sensitive receptors located near roadway segments would experience cumulative noise level increases greater than 3.0 dBA CNEL for two roadway segments. More specifically, an increase of 3.8 dBA CNEL would occur along the segment of Slauson Avenue between Jefferson Boulevard and Sepulveda Boulevard and 11.2 dBA CNEL increase along the segment of Slauson Avenue between W Jefferson Boulevard and Washington Boulevard. Therefore, the increase in traffic noise from the Project in conjunction with ambient growth and other development within the vicinity of Culver City would result in a significant

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-41 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
cumulative impact. As shown in Table 4.12-10, future project increases in future traffic noise levels compared to future no project would reach 4.2 dBA CNEL along one roadway segment (Washington Boulevard between Inglewood Boulevard and S Centinela Avenue). Therefore, the contribution of the Project to this cumulative traffic noise impact would be cumulatively considerable and impacts would be potentially significant.

TABLE 4.12-12

C UMULATIVE TRAFFIC NOISE IMPACTS

Existing Noise
Levels
Future Plus
Project Noise
Levels Increase
Roadway Segment dBA CNEL at 50 Feet from Centerline
Adams Blvd between Washington Blvd & Fairfax Ave 64.8 64.2 -0.5 Culver Blvd between Overland Ave & Sepulveda Blvd 72.7 73.9 1.2 Culver Blvd between Sepulveda & Sawtelle Blvd 72.5 73.8 1.3 Culver Blvd between Washington Blvd & Duquesne Ave 69.1 70.6 1.6 Culver Blvd between Washington Blvd & Washington Blvd 70.9 71.0 0.0 Culver Blvd between Duquesne Ave & Overland Ave 72.6 74.9 2.3 Fairfax Ave between Washington Blvd & La Cienega Blvd 72.6 71.9 -0.7 Jefferson Blvd between Slauson Ave & Inglewood Blvd 71.4 72.5 1.1 Jefferson Blvd between Sepulveda Blvd & Slauson Ave 69.5 65.9 -3.6 Jefferson Blvd between Overland Ave & Sepulveda Blvd 70.8 70.8 0.0 Jefferson Blvd between Duquesne Ave & Overland Ave 73.4 72.0 -1.4 Jefferson Blvd between Overland Ave & Sawtelle Blvd 66.3 67.6 1.2 Jefferson Blvd between Obama Blvd & Duquesne Ave 73.4 72.7 -0.7 Machado Rd between Jefferson Blvd & Sepulveda Blvd 62.9 62.5 -0.4 Overland Ave between Venice Blvd & Washington Blvd 69.5 70.0 0.5 Overland Ave between Washington Blvd & Culver Blvd 69.8 71.8 2.0 Overland Ave between Culver Blvd & Jefferson Blvd 69.4 72.1 2.8 Overland Ave between Jefferson Blvd & Sawtelle Blvd 69.7 71.1 1.4 S Centinela Ave between Washington Blvd & Culver Blvd 69.2 68.8 -0.4 S Centinela Ave between Venice Blvd & Washington Pl 72.7 73.1 0.4 S Centinela Ave between Washington Pl & W Washington Blvd 71.1 71.5 0.4 S Fairfax Ave between Venice Blvd & Washington Blvd 70.0 71.8 1.8 S La Cienega Blvd between Fairfax Ave & W Jefferson Blvd 72.6 74.3 1.7 S La Cienega Blvd between Venice Blvd & Washington Blvd 70.9 72.8 1.9 S La Cienega Blvd between Washington Blvd & Fairfax Ave 72.7 74.4 1.6 Sepulveda Blvd between Slauson Ave & W Centinela Ave 72.0 73.6 1.6 Sepulveda Blvd between Culver Blvd & Jefferson Blvd 72.0 70.4 -1.5 Sepulveda Blvd between Washington Blvd & Culver Blvd 70.0 67.9 -2.1 Sepulveda Blvd between Venice Blvd & Washington Pl 71.4 70.0 -1.5 Sepulveda Blvd between Washington Pl & Washington Blvd 70.9 68.5 -2.4

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-42 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

Existing Noise
Levels
Future Plus
Project Noise
Levels Increase
Roadway Segment dBA CNEL at 50 Feet from Centerline
Sepulveda Blvd between Jefferson Blvd & Slauson Ave 73.1 74.1 1.0 Sepulveda Blvd between Sawtelle Blvd & Jefferson Blvd 75.5 74.0 -1.5 Sepulveda Blvd between Jefferson Blvd & Sawtelle Blvd 71.8 72.9 1.1 Slauson Ave between Jefferson Blvd & Sepulveda Blvd 68.8 72.7 3.8 Slauson Ave between W Jefferson Blvd & Washington Blvd 62.6 73.8 11.2 Venice Blvd between Sepulveda Blvd and Sawtelle Blvd 69.8 71.1 1.2 Venice Blvd between Overland Ave and Sepulveda Blvd 70.1 70.9 0.8 W Centinela Ave between Sepulveda Blvd & Green Valley Cir 72.3 74.5 2.2 W Centinela Ave between Jefferson Blvd & Sepulveda Blvd 76.1 78.6 2.5 W Jefferson Blvd between National Blvd & Obama Blvd 70.8 70.4 -0.4 W Jefferson Blvd between Obama Blvd & Duquesne Ave 73.4 72.8 -0.7 Washington Blvd between Overland Ave & Washington Pl 70.9 70.5 -0.4 Washington Blvd between Duquesne Ave & Overland Ave 69.2 69.4 0.3 Washington Blvd between Washington Pl & Sepulveda Blvd 66.5 67.1 0.6 Washington Blvd between Culver Blvd & Duquesne Ave 67.6 66.4 -1.2 Washington Blvd between Washington Pl & Lincoln Blvd 68.3 67.2 -1.1 Washington Blvd between Inglewood Blvd & S Centinela Ave 69.0 70.2 1.2 Washington Blvd between Sawtelle Blvd & Inglewood Blvd 68.8 67.9 -1.0 Washington Blvd between S Centinela Ave & W Washington Blvd 67.4 67.5 0.0 Washington Blvd between Sepulveda Blvd & Sawtelle Blvd 68.4 67.7 -0.7 Washington Blvd between La Cienega Blvd & National Blvd 71.6 70.5 -1.0 Washington Blvd between National Blvd & Culver Blvd 70.7 69.2 -1.5 Washington Blvd between Fairfax Ave & La Cienega Blvd 71.3 70.5 -0.7 Washington Blvd between S Centinela Ave & Washington Pl 68.5 68.4 -0.1 Washington Blvd between Duquesne Ave & Overland Dr 69.1 69.4 0.3 Washington Blvd between National Blvd & Overland Ave 70.6 69.7 -0.9 Washington Blvd between Overland Ave & Sepulveda Blvd 70.7 70.3 -0.4 Washington Pl between Washington Blvd & Sepulveda Blvd 69.2 68.2 -1.0 Washington Pl between Inglewood Blvd & S Centinela Ave 70.4 68.1 -2.3 Washington Pl between S Centinela Ave & W Washington Blvd 70.2 68.1 -2.2 Washington Pl between Washington Blvd & Washington Blvd 70.8 68.1 -2.7 Washington Pl between Sepulveda Blvd & Sawtelle Blvd 69.7 68.3 -1.4 NOTE: Bold value indicates significant impact.

SOURCE: ESA, 2024; Fehr & Peers, 2024 (VMT and traffic volume data). Refer to noise modeling provided in Appendix E.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-43 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Groundborne Vibration or Groundborne Noise
Construction
Vibration generated by the construction of multiple development projects allowed under the Project could combine if located in proximity to each other and could exceed vibration thresholds at sensitive receptors, thus resulting in a potential cumulative construction vibration impact.

Determining the exact location and potential vibration levels of future construction activities would be considered speculative at this time. Further, construction vibration levels would be considered a temporary nuisance, as the increase in noise levels would only occur during the use of construction equipment associated with each specific development project. As discussed earlier, construction of future development projects requiring discretionary approval within the city would be required to undergo site specific environmental review as required by CEQA.

Vibration is a localized phenomenon. Since the City is predominately an urban landscape and primarily built out, future development would be periodic infill development in various areas of the city. It is possible that multiple construction projects would occur simultaneously and in close enough proximity to each other to create a significant combined vibration impact.

Therefore, the contribution of the Project to potential cumulative construction vibration impact would be cumulatively considerable.

Traffic
Permanent increases in vibration would occur primarily as a result of increased traffic on local roadways due to future development under the Project and ambient growth through 2045 throughout the region. Vibration from these sources, while remote, could combine and exceed vibration thresholds at sensitive receptors, thus resulting in a potential cumulative operational (traffic) vibration impact.

As discussed above, vibration from vehicles is temporary and intermittent and generates up to 61 Vdb or 0.005 in/sec PPV.
27 As a result, vibration levels from traffic generated by growth anticipated by the Project would be well below the thresholds for human annoyance and structural damage. Therefore, the contribution of the Project to any potential cumulative operational (traffic) vibration impact would not be cumulatively considerable.

27 FTA, Transit Noise and Vibration Impact Assessment Manual, 2018.

4. Environmental Impact Analysis

4.12. Noise
General Plan 2045 and Zoning Code Update Project 4.12-44 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.13-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.13 Population and Housing

4.13.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts related to the population, employment, and housing associated with the implementation of the Project. The analysis includes a review of the potential to induce population growth and subsequently require additional housing from future development allowed under the Project, as well as the potential displacement of people or housing. The section provides context regarding the current population, housing, and employment, growth trends and projections in the Planning Area, and relevant federal, state, and local regulations and programs. Future discretionary projects facilitated by the Project would be evaluated for project-specific impacts related to population and housing at the time they are proposed. Potential growth-inducing impacts from future development allowed under the Project are further addressed in Chapter 6, Other CEQA Considerations, of this Draft PEIR.

4.13.2 Environmental Setting
Population Growth Trends
Culver City is located within Los Angeles County, which is the most populous county in both California and the United States. As of 2020, Culver City accounted for approximately

0.4 percent of over 10 million residents in the county, and the city has added approximately 1,983 residents (approximately 5.1 percent growth) since 2000.1 The city’s overall population growth has kept pace with the county’s growth of approximately 5.2 percent over the same period.

Following its incorporation in 1917, Culver City’s population grew rapidly. Culver City had its most dramatic population increase in the decade after incorporation when the city’s population grew from 503 residents to 5,669 residents (1,072 percent increase). From 1930 to 1960, the city’s population continued to grow rapidly to 32,163 residents. However, the population growth rate began declining after 1960. Between 1970 and 1980, the population growth rate decreased to 7.1 percent and remained below 2 percent over the decade from 1990 to 2000. As noted in Chapter 2, Project Description, Culver City’s population was 40,800 residents in 2020, representing a 5.1 percent growth since 2000.
2 Housing Growth Trends
As described in Section 4.10, Land Use and Planning, of this PEIR, 39.6 percent of land in Culver City is currently made up of residential uses, the majority of which is single-family residential.

Single-family residential uses are mostly situated on gridded neighborhood streets. Some

1 Culver City, 2020a. Culver City General Plan Update: Housing Element Existing Conditions Report. Table 1: Population Trends in Culver City and LA County. https://www.pictureculvercity.com/resources. Accessed February 2023. 2 Culver City, 2020a. Culver City General Plan Update: Housing Element Existing Conditions Report. Table 1: Population Trends in Culver City and LA County. https://www.pictureculvercity.com/resources. Accessed February 2023.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
neighborhoods, including Park West and Sunkist Park, are almost entirely comprised of single- family uses. Other neighborhoods, including Park East, Studio Village, Clarkdale, and Washington Culver, have a mix of single-family and multi-family housing. Multi-family housing in these neighborhoods is generally low density (fewer than approximately 20 dwelling units per acre).

City Council Meeting AgendaAugust 26, 2024

City Council Meeting Agenda
August 26, 2024