ATT_1_Proposed_Resolution_to_Adopt_EIR.pdf — City Council Meeting Agenda, August 26, 2024 (part 5 of 6)

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, also known as granny flats, are small housing units built on a property.

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, with some 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.

Table 4.13-1, Housing Units 2000–2020, shows growth in housing units in Culver City and Los Angeles County from 2000 to 2020. The number of housing units in the city increased from 17,130 housing units in 2000 to 17,819 housing units in 2020, a 4.02 percent increase. The County grew from 3,270,909 housing units in 2000 to 3,591,981 housing units in 2020, a

9.82 percent increase. During the same period, the city’s number of housing units comprised, on average, approximately 0.5 percent of the county’s housing units.

TABLE 4.13-1
HOUSING UNITS 2000–2020
2000 2010 2020 2000–2020 Change
Culver City 17,130 17,491 17,819 4.02%
Los Angeles County 3,270,909 3,443,087 3,591,981 9.82%
Culver City Share of County 0.52% 0.51% 0.49% —
SOURCES: Culver City, 2022a. Housing Element. https://www.pictureculvercity.com/housing-element; California Department of Finance, 2021. E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2011–2020, with 2010 Census Benchmark.

May 2021.

Table 4.13-2, Household Size 2000–2019, compares household sizes in the Culver City and Los Angeles County from 2000 to 2019. Average household size in the city increased slightly from

2.31 persons per household in 2000 to 2.33 persons per household in 2019. Average household size in the County increased from 2.98 persons per household in 2000 to 2.99 persons per household in 2019. Overall, the city has maintained a lower average household size than the County over the last 19 years.

4. Environmental Impact Analysis

4.13. Population and Housing
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TABLE 4.13-2
HOUSEHOLD SIZE 2000–2019
2000 2010 2019
Culver City 2.31 2.30 2.31
Los Angeles County 2.98 2.98 2.99
SOURCES: California Department of Finance, 2012. E-8 Historical Population and Housing Estimates for Cities, Counties, and the State, 2000–2010. Sacramento, California, November 2012; California Department of Finance, 2021. E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2011–2020, with 2010 Census Benchmark. May 2021;Culver City, 2022a. Housing Element. https://www.pictureculvercity.com/housing-element.

As of December 2019, the city has approximately 1,550 housing units in the development pipeline. Many low density (fewer than approximately 12 units) residential projects are infill developments in existing residential neighborhoods. Higher density residential developments are largely located along major roadways, in the Downtown, and near the Metro E Line station.

Examples of significant multi-family projects include Jefferson Park (259 units), a senior housing development on Washington Boulevard (116 units), and 12717 Washington Boulevard (116 units).

These projects are in the Studio Village, Clarkdale, and Culver West neighborhoods, respectively. 3 Employment Growth Trends
Employment in Culver City has fluctuated over the past 20 years, partly due to the 2008 recession, but has generally been increasing, with an approximate 14 percent growth in jobs between 2010 and 2019.
4,5 Based on data from the U.S. Census Bureau, there were approximately 68,039 jobs in Culver City in 2019 and the percentage breakdown by industry is as follows: Office Services (60.9 percent); Retail Services (9.6 percent); Medical Services (6.7 percent); Education (3.6 percent); Manufacturing (3.5 percent); Restaurants (3.1 percent); Accommodations (3.1 percent); Wholesale (2.6 percent); Other Retail (2.6 percent); Public Administration (1.8 percent); Construction (1.1 percent); Arts & Entertainment (0.8 percent); and Transportation/ Warehouse (0.7 percent).6 Land uses within the SOI are designated as open space, comprised of the Inglewood Oil Field (IOF) and West Los Angeles College, as well as a cemetery.

Jobs to housing ratios relate the spatial match between jobs and housing and are often used as indicators of economic vitality and quality of life. A regional balance of jobs-to-housing helps ensure that the demand for housing is reasonably related to supply. A high ratio of jobs to housing indicates a housing shortage and may lead to an unbalance in the rental and for-sale housing markets, requiring households to pay a larger share of their income on housing, as well as issues of housing affordability, as there is not enough housing to accommodate all the

3 Culver City, 2020b. Culver City Land Use and Community Design Existing Conditions Report. https://www.pictureculvercity.com/resources. Accessed February 2023. 4 United States Census Bureau, 2010. OnTheMap web application, Work Area Profile Analysis by Place of Work. https://onthemap.ces.census.gov/. Accessed March 2023.
5 Raimi +Associates. 2022. Preferred Land Use Projections. November 2022. 6 Raimi +Associates. 2022. Preferred Land Use Projections. November 2022.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.13-4 SCH No. 2022030144 City of Culver City March 2024
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workers. This results in overcrowding and increases traffic congestion from longer commutes as workers seek more affordable housing in outlying areas.

Based on 17,004 housing units and 68,039 jobs in 2019, the jobs to housing ratio for the baseline year of 2019 is 4.00.7 Although there are 4.00 jobs per every housing unit under the 2019 baseline conditions, many people who work in Culver City live in nearby Westside cities, including Santa Monica, Beverly Hills, and West Hollywood, and commute relatively short distances. This could mean the workforce residing nearby could offset the imbalanced jobs to housing ratio. However, various studies have found that over 65 percent of the Westside cities’ workforce commutes from outside the Westside.8,9

4.13.3 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 Government Code
Housing Element Law
California planning and zoning law requires each city and county to adopt a general plan for future growth (California Government Code Section 65300). This plan must include a housing element that identifies housing needs for all economic segments and provides opportunities for housing development to meet that need. At the state level, the Housing and Community Development Department (HCD) estimates the relative share of California’s projected population growth that would occur in each county based on California Department of Finance (DOF) population projections and historical growth trends. These figures are compiled by HCD in a Regional Housing Needs Assessment (RHNA) for each region of California. Where there is a regional council of governments, HCD provides the RHNA to the council, which for the region is the Southern California Association of Governments (SCAG). SCAG then assigns a share of the regional housing need to each of its cities and counties.

State law recognizes the vital role local governments play in the supply and affordability of housing.

California Government Code requires that the housing element achieve legislative goals to:
• Identify adequate sites to facilitate and encourage the development, maintenance, and improvement of housing for households of all economic levels, including persons with disabilities.

7 Raimi + Associates, Preferred Plan Growth Projections. November 2022. 8 Southern California Association of Governments, 2009. Westside Cities Workforce Housing Study. February 2009. https://scag.ca.gov/sites/main/files/file-attachments/westsideworkforcehousingstudy_ppt.pdf?1604179191.

Accessed March 2023.
9 Los Angeles County Metropolitan Transportation Authority, 2015. Subregional Mobility Matrix Westside Cities Final Report. March 2015. https://media.metro.net/projects_studies/lrtp/images/report_mobility_westside.pdf.

Accessed March 2023.

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• Remove, as legally feasible and appropriate, governmental constraints to the production, maintenance, and improvement of housing for persons of all incomes, including those with disabilities.
• Assist in the development of adequate housing to meet the needs of low and moderate income households.
• Conserve and improve the condition of housing and neighborhoods, including existing affordable housing.
• Promote housing opportunities for all persons regardless of race, religion, sex, marital status, ancestry, national origin, color, familial status, or disability. • Preserve for lower-income households the publicly assisted multifamily housing developments in each community.

The State of California housing element laws (Sections 65580 to 65589 of the California Government Code) require that each city and county identify and analyze existing and projected housing needs within its jurisdiction and prepare goals, policies, and programs to further the development, improvement, and preservation of housing for all economic segments of the community commensurate with local housing needs.

Housing Element Law (Article 10.6)
The “No Net Loss” provisions in Section 65583.2 of the Housing Element law were established to make sure that housing elements identify sufficient sites to accommodate the jurisdiction’s RHNA or include programs to ensure that sites will be available throughout the planning period.

Under the “No Net Loss” requirements, a jurisdiction may not reduce residential density or allow development at a lower residential density unless the jurisdiction makes findings supported by substantial evidence that the reduction is consistent with the general plan and there are remaining sites identified in the housing element adequate to meet the jurisdiction’s outstanding RHNA.

Housing Crisis Act of 2019 – (Senate Bill 330, Skinner) On October 9, 2019, the Governor signed into law the Housing Crisis Act of 2019 (Senate Bill [SB] 330). SB 330 seeks to speed up housing production in the next half decade by eliminating some of the most common entitlement impediments to the creation of new housing, including delays in the local permitting process and cities enacting new requirements after an application is complete and undergoing local review— both of which can exacerbate the cost and uncertainty that sponsors of housing projects face. In addition to speeding up the timeline to obtain building permits, the bill prohibits local governments from reducing the number of homes that can be built through down-planning or down-zoning or the introduction of new discretionary design guidelines. The bill is in effect as of January 1, 2020, but is temporary in nature as the bill’s provisions expire on January 1, 2025.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-6 SCH No. 2022030144 City of Culver City March 2024
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California Relocation Law, Public Resources Code Section 7260 et seq.

The California Relocation Law requires the fair and equitable treatment of persons displaced as a direct result of programs or projects undertaken by a public entity. The law requires agencies to prepare a relocation plan, provide relocation payments, and identify substitute housing opportunities for any resident that is to be displaced by a public project.

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 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. SB 375 requires Metropolitan Planning Organizations (MPOs) to develop a Sustainable Communities Strategy (SCS)— a new 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
The Planning Area is located within the jurisdiction of SCAG, a Joint Powers Agency established under California Government Code Section 6502 et seq. Pursuant to federal and state law, SCAG serves as a Council of Governments, a Regional Transportation Planning Agency, and the MPO for Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial Counties. SCAG’s mandated responsibilities include developing plans and policies with respect to the region’s population growth, transportation programs, air quality, housing, and economic development.

Specifically, SCAG is responsible for preparing the Regional Comprehensive Plan (RCP), RTP/SCS, and RHNA, in coordination with other state and local agencies. These documents include population, employment, and housing projections for the region and its 15 subregions.

Subregions play an important role as a conduit between SCAG and cities and counties of the region by participating and providing input on SCAG’s planning activities, which helps the Regional Council and its committees make better-informed decisions. The Planning Area is located within the Westside Cities Council of Governments (WCCOG) Subregion.

SCAG is tasked with providing demographic projections for use by local agencies and public service and utility agencies in determining future service demands. Projections in the SCAG 2020 RTP/SCS serve as the bases for demographic estimates in this analysis of Project consistency with growth projections. The findings regarding growth in the region are consistent with the methodologies prescribed by SCAG and reflect SCAG goals and procedures.

SCAG data is periodically updated to reflect changes in development activity and provisions of local jurisdictions (e.g., zoning changes). Through these updates, public agencies have advance information regarding changes in growth that must be addressed in planning for their provision of services. Changes in the growth rates are reflected in the new projections for service and utilities planning through the long-term time horizon.

4. Environmental Impact Analysis

4.13. Population and Housing
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SCAG Connect SoCal (2020 RTP/SCS)
The 2020 RTP/SCS, known as Connect SoCal, was developed through a four-year planning process that involved rigorous technical analysis, extensive stakeholder engagement and robust policy discussions with local elected leaders, who make up SCAG’s policy committees and Regional Council. The 2020 RTP/SCS charts a path toward a more mobile, sustainable and prosperous region by making key connections: between transportation networks, between planning strategies and between the people whose collaboration can make plans a reality. The 2020 RTP/SCS was completed in May 2020 and approved and adopted by the Regional Council on September 3, 2020.

The 2020 RTP/SCS embodies a collective vision for the region’s future, through the horizon year of 2045. It is developed with input from a wide range of constituents and stakeholders within the Counties of Imperial, Los Angeles, Orange, Riverside, San Bernardino and Ventura, including public agencies, community organizations, elected officials, tribal governments, the business community and the general public. The 2020 RTP/SCS is an important planning document for the region, allowing public agencies who implement transportation projects to do so in a coordinated manner, while qualifying for federal and state funding. The plan includes robust financial analysis that considers operations and maintenance costs to ensure the existing transportation system’s reliability, longevity, resilience and cost effectiveness. In addition, the 2020 RTP/SCS is supported by a combination of transportation and land use strategies that outline how the region can achieve California’s greenhouse gas emission reduction goals and federal Clean Air Act requirements. The plan also strives to achieve broader regional objectives, such as the preservation of natural lands, improvement of public health, increased roadway safety, support for the region’s vital goods movement industries and more efficient use of resources.
10 In addition, the 2020 RTP/SCS establishes policies pertaining to regional growth and efficient development patterns to reduce development impacts on traffic congestion and related increases in air quality emissions.

SCAG Regional Housing Needs Assessment
The 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 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. 11 Therefore,

10 Southern California Association of Governments, 2020a. Connect SoCal (2020 RTP/SCS), page 8. Adopted September 3, 2020.
11 Southern California Association of Governments, 2020b. Final RHNA Allocation Methodology, page 5. Adopted March 5, 2020.

4. Environmental Impact Analysis

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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.

On October 15, 2019, SCAG received the Final Regional Determination from HCD. On November 7, 2019, SCAG Regional Council approved a Draft RHNA Allocation Methodology for HCD’s review. The Regional Council approved the Final RHNA Methodology on March 5, 2020, and released the Draft RHNA Allocation by jurisdictions. 12 The RHNA underwent Appeals Board
Hearings throughout January 2021. In February 2021, the RHNA Appeals Board concluded its determination of appeals and issued the proposed final RHNA Allocation Plan and recommended the Plan for approval by SCAG’s Community, Economic & Human Development (CEHD) Committee and Regional Council.
13 The final 6th Cycle RHNA methodology and
allocations were adopted by the Regional Council on March 4, 2021, and approved by HCD on March 22, 2021. As part of the RHNA draft allocations, the city’s allocation of housing between October 2021 and October 2029 is 3,341 units.14
Consistent with the state housing law, the primary objectives the 6th Cycle RHNA allocation plan are:
• 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,

12 Southern California Association of Governments, 2023. Regional Housing Needs Assessment. https://scag.ca.gov/rhna. Accessed April 2023.
13 Southern California Association of Governments, 2021a. 6th Cycle RHNA Appeals Timeline, posted online on February 9, 2021. https://scag.ca.gov/sites/main/files/file-attachments/anticipated-scag-6th-cycle-rhna-appeals- timeline.pdf?1612908970. Accessed April 2023.
14 Southern California Association of Governments, 2021b. SCAG 6th Cycle Final RHNA Allocation Plan. Approved on March 22, 2021, and modified on July 7, 2021.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-9 SCH No. 2022030144 City of Culver City March 2024
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improve access to jobs, promotes transportation mobility, addresses social equity, and fair share housing needs.

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.

Local
Culver City Zoning Code
Title 17, Zoning Code, of the City’s Municipal Code contains development standards that regulate the type, location, density, and scale of residential development. The Zoning Code serves to implement the General Plan and the development standards are designed to protect and promote the public health, safety, comfort, convenience, and general welfare of residents.

The Zoning Code also helps to preserve the character and integrity of existing neighborhoods.

4.13.4 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 population and housing if the project would:

Threshold POP-1: Induce substantial unplanned population growth in an area, either directly (for example by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

Threshold POP-2: Displace substantial numbers of existing people or housing, necessitating the construction of replacement housing
elsewhere.

Methodology
The population growth projections provided in this section use the year 2020 as the baseline, while the housing and employment growth projections use the year 2019. Therefore, 2019 serves as the baseline year for housing and employment growth, and 2020 serves as the baseline year for population growth. Although the Housing Element determined that, as of 2020, the number of housing units in the City was 17,819 units, the 2019 baseline year projection for housing units used throughout the analysis is 17,000 units. While less than the number used in the Housing Element, this provides a worst case scenario to analyze growth and is a more conservative analysis.

The General Plan Update has a year 2045 horizon; however, the General Plan Update does not speculate when the development projections would occur, as long-range demographic and

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.13-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
economic trends are difficult to predict. The designation within the General Plan Update of a site for certain use (as depicted in Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description) does not necessarily mean that the site will be developed or redeveloped with that use during the planning period, as most development will depend on property owner initiative. For the purposes of this PEIR, the environmental analysis assumes that sites would be developed or redeveloped with the designated land use by the 2045 horizon year.

With much of the city currently “built out,” or developed, undeveloped land available for development is limited in Culver City. The General Plan Update includes updated land use designations, as described in Section 4.10, Land Use and Planning, of this PEIR, which would be implemented by the Zoning Code Update as part of a strategy to enable development of walkable mixed-use activity centers and corridors. Major land use changes are planned to take place as opportunities for infill development result in provision of a wider range of housing, employment, and recreational uses to meet the needs of families, young people, senior citizens, and residents of all incomes. 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.

Project Impact Analysis
Induce Unplanned Population Growth
Threshold POP-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would induce substantial unplanned population growth in an area, either directly (for example, by proposing new homes and businesses) or indirectly (for example, through extension of roads or other infrastructure).

Impact Statement POP-1: The Project would accommodate regional growth in an orderly manner for the next 25 years and would result in a less significant impact related to inducing unplanned population growth.

General Plan Update
According to SCAG projections, which do not account for the anticipated growth in the General Plan 2045, by 2045, the population in Culver City is anticipated to increase to 41,600 residents, the number of housing will increase to 18,000 units, and employment will increase to 64,100 jobs.15 As shown in Table 2-3, General Plan 2045 Population, Household, and Job Growth Projections, in Chapter 2, Project Description, the existing population in Culver City would increase from 40,800 to 62,400, the existing housing units would increase from 17,000 to 28,310, and the existing jobs would increase from 68,040 to 84,300 in 2045. This would translate to a 52.9 percent increase in residents, 66.5 percent increase in housing units, and a

15 Southern California Association of Governments, 2020c. Final Connect SoCal Demographics and Growth Forecast.

Adopted September 3, 2020.

4. Environmental Impact Analysis

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23.9 percent increase in jobs over the next 25 years. The population, housing, and employment projections assumed for the General Plan Update are higher than SCAG’s 2045 estimates since the Project provides for additional population, housing, and employment capacity not anticipated by SCAG. However, since SCAG projections are based on the existing General Plan land uses, future SCAG planning documents would be updated to reflect General Plan Update projections, if the General Plan 2045 is approved, provided in this PEIR.

As mentioned above in Section 4.13.3, Regulatory Framework, Culver City has a RHNA allocation of 3,341 new units, which is a 17-fold increase from the 5th housing element cycle (185 units for 2014–2021 and 3,341 units for 2021–2029).16 Recognizing that market trends are difficult to predict, RHNA numbers, which are allocated every eight years and are subject to change in the future, and growth is not a linear process, the General Plan Update anticipates the development of 12,700 units between 2019 and 2045. New residential opportunities would be a result of targeted residential and mixed-use development in activity centers and along commercial corridors to provide housing near jobs, neighborhood amenities, and health care facilities. This type of infill development would focus on redevelopment and revitalization of areas already served by infrastructure and would not require extensions of roads or other infrastructure.

Additionally, the General Plan 2045 policies seek to provide housing that meets the diverse needs of Culver City’s growing population while preserving existing neighborhoods (Policy LU-1.2, Goal LU-2 and associated policies, Policies LU-11.2, LU-11.7, LU-13.4), as well as ensure that public facilities, services, and infrastructure maintain a level of service that supports a high quality of life for all residents (Policy LU-18.1).

As discussed in Section 4.13.2, Environmental Setting, existing land uses within the SOI are designated as open space, comprised of the IOF and West Los Angeles College, as well as a cemetery, and do not include any housing. Under the General Plan Update, no significant land use changes would occur in the SOI and thus, would not generate any additional population or housing within the Planning Area.

Table 4.13-3, Culver City Jobs-Housing Ratio, shows the jobs to housing ratio for the baseline year of 2019 and the planning horizon year of 2045.

TABLE 4.13-3

CULVER CITY JOBS-HOUSING RATIO
2019 2045 Percent Change
Housing Units 17,000 29,710 75%
Jobs 68,040 84,300 24%
Jobs to Housing Ratio 4.00 2.84 -29%
SOURCE: Raimi + Associates, Preferred Plan Growth Projections. November 2022.

16 Culver City, 2022b. Housing Element. Appendix B: Residential Sites Inventory. https://www.pictureculvercity.com/housing-element. Accessed March 2023.

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As stated in Section 4.13.2, Environmental Setting, a high ratio of jobs to housing indicates a housing shortage as there is not enough housing to accommodate all workers, resulting in overcrowding and increased traffic congestion from longer commutes. Based on the SCAG housing and employment growth estimates, the jobs to housing ratio is predicted to decrease over the next 25 years to 2.99, which indicates improved housing conditions in the city. While an increase in employment opportunities within the Planning Area is expected during the 2045 planning horizon, the city has adequate capacity to meet the current RHNA allocation for housing in all household income categories. In addition, policies and programs in the General Plan Update would ensure that housing needs, including future housing needs for the projected increase in employment, would be met.

The IOF is planned to be phased out. However, due to decommissioning activities, no impacts to employment are anticipated.

By virtue of the fact that the General Plan Update is the long-range blueprint for growth and development in the city, the population growth (both in housing and employment) anticipated to occur as a result of the Project would be considered planned growth. The General Plan Update is intended to accommodate planned regional growth requirements for the next 25 years with the densities allowed for across various land uses and with the provision of infrastructure and public services to accommodate such growth (see also Section 4.9, Hydrology and Water Quality; Section 4.14, Public Services; Section 4.15, Recreation; Section 4.16, Transportation; and Section 4.18, Utilities and Service Systems). Moreover, because the city has supported urban growth and development for more than 100 years and is served with infrastructure (e.g., roads, freeways, railroads, transit, water, sewer, storm drainage, electricity, natural gas, etc.) implementation of the Project would not result in indirect growth. Impacts would be less than significant. As such, the Project would not induce substantial unplanned population growth, either directly or indirectly. Impacts would be less than significant.

Zoning Code Update
Title 17, Zoning Code, of the City’s Municipal Code implements the City’s General Plan and provides a precise guide for the physical development of the city, consistent with the goals and policies of the General Plan. As such, the Zoning Code Update would not result in unplanned direct or indirect population growth and impacts would be less than significant.

Future expansion of City services has been planned for in the General Plan Update to accommodate expected growth and therefore would not be expected to allow for indirect unplanned growth. Future development would be reviewed by the City for compliance with the policies and actions of the General Plan Update, the Zoning Code Update, and the mitigation measures referenced in other sections of this PEIR and project-specific environmental documentation, further ensuring that unplanned direct or indirect population growth would not occur and impacts would be less than significant.

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

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

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

Goal LU-2: Housing opportunity and equality. A diverse range of housing options create equitable opportunities for people of all ages, races/ethnicities, abilities, socio-economic status, genders, and family types to live in Culver City.

LU-2.1: Inclusionary housing provisions. Expand the City’s Mixed Use Ordinance incentive program to all mixed use and multifamily residential General Plan Land Use Designations and Zoning Districts.

LU-2.2: Special needs and supportive housing. Support special needs and supportive housing through development incentives and development fee deferrals.

LU-2.3: Workforce housing program. Partner with large employers, residential developers, and/or the Culver City Unified School District to create housing opportunities via the development of housing units, contribution of land, or provision of funding for workforce housing.

LU-2.4: Equity homeownership models. Explore expanded use of shared equity homeownership models, including a community land trust, to increase home ownership.

LU-2.5: Amenity space for physical activity/healthy living in multifamily development.

Encourage new multifamily housing development to provide amenity spaces (e.g., gyms, active spaces, outdoor open space, flex working spaces, etc.) which promote physical and healthy living options. Create incentives for developments to make such amenities available to the public so that they can benefit the neighborhood.

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-11.7: Neighborhood compatibility. 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.

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General Plan 2045 and Zoning Code Update Project 4.13-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
LU-13.4: Housing for all needs. Facilitate housing for seniors, special needs groups, including the developmentally disabled, and non-traditional family groups by requiring a diverse range of housing configurations that are Americans with Disabilities Act compliant and flexible.

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

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 inducing unplanned population growth.

Require Construction of New Housing
Threshold POP-2: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere.

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

General Plan Update
The Project would provide infill development opportunities in vacant and underutilized areas in the city, while seeking to preserve existing neighborhoods. A substantial portion (approximately

22.9 percent) of developed land in the Planning Area consists of single-family residential uses, which are not anticipated to undergo significant land use changes under the Project. Proposed land use designations, as described and discussed in Chapter 2, Project Description, of this Draft PEIR, would introduce greater flexibility of uses, such as mixed-use, and allow residential uses in more areas of the city, including within industrial areas of the city. New mixed-use designations in activity centers and along commercial corridors would also enable greater opportunities for future residential development. As such, the Project is projected to increase the overall number of dwelling units and provide additional housing opportunities to serve the diverse needs of the community at various socioeconomic levels.

California Government Code Article 10.6 outlines the state’s Housing Element requirements. A housing element must analyze existing and projected housing needs, examine special housing needs within the population, evaluate the effectiveness of current goals and policies, identify governmental and other constraints, determine compliance with other housing laws, and

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
identify opportunities to incorporate energy conservation into the housing stock. The element must also establish goals, policies, and programs to maintain, enhance, and develop housing.

The City Council adopted the Culver City Housing Element 2021-2029 on August 8, 2022, and the Housing Element 2021-2029 was certified by HCD on October 10, 2022.17 The Land Use Element reflects the new land use designations that allow greater residential densities as described above in order to meet the RHNA obligation for the 2021–2029 housing element cycle. In addition, the Housing Element includes an in-depth analysis of the city’s housing stock, past and anticipated trends, and housing needs that inform the element’s goals, policies, and programs, which include provisions to conserve and improve the existing housing stock, provide housing for special needs populations, supply enough new housing to meet the city’s fair share of the region’s housing need, preserve at-risk affordable housing units, and affirmatively further fair housing opportunities. The General Plan Update includes policies that support these objectives, including those that seek to ensure equity and protect diversity in Culver City’s communities.

For these reasons, growth anticipated under the General Plan Update would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. 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 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 displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. Furthermore, as the City receives development applications for subsequent development under the Project, those applications will be reviewed by the City for compliance with the policies and actions of the General Plan Update and the Zoning Code Update to ensure the displacement of housing or significant need for new housing does not occur. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Community Health and Environmental Justice
Goal CHEJ-5: Quality housing. Culver City maintains a supply of safe and quality housing.

CHEJ-5.1: Housing rehabilitation. Expand maintenance and abatement assistance programs for single (including mobile homes) and multi-family properties of low-income households. Support programs designed to rehabilitate deteriorated units through weatherization, modernization, and elimination of common home pollutants.

CHEJ-5.2: Rehabilitation without displacement. Enforce applicable provisions of the housing and building codes to ensure deteriorated housing units are rehabilitated. If implementing applicable provisions results in housing displacement, then identify opportunities to ensure residents remain housed.

17 Culver City, 2023. Housing Element Update Timeline. https://www.pictureculvercity.com/housing- element/#updatetimeline.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Goal CHEJ-6: Housing and economic uncertainty. Culver City identifies and addresses the root causes of housing and economic injustices and inequities disproportionately experienced by low-income households and residents.

CHEJ-6.1: Equitable housing and economic strategies. Prioritize solutions that directly address the concerns of low-income households and residents.

CHEJ-6.2: Services for unhoused residents. Promote shelter and supportive services for people experiencing homelessness.

CHEJ-6.3: Limited-equity housing. Encourage resident controlled limited-equity ownership, such as limited-equity condominiums, limited-equity cooperatives, and community land trusts.

Land Use and Community Design
Goal LU-2: Housing opportunity and equality. A diverse range of housing options create equitable opportunity for people of all ages, races/ethnicities, abilities, socio-economic status, genders, and family types to live in Culver City.

LU-2.2: Special needs and supportive housing. Support special needs and supportive housing through development incentives and development fee deferrals.

LU-2.4: Equity homeownership models. Explore expanded use of shared equity homeownership models, including a community land trust, to increase home ownership.

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

LU-11.2: Diversity of housing types. Encourage a variety of housing types to equitably serve varying household types, including, but not limited to, single-family attached and detached units, accessory dwelling units, duplexes, and triplexes.

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 requiring construction of new housing.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.13.5 Cumulative Impacts Analysis
The Project would result in less than significant cumulative impacts related to population and housing. The geographic context for the cumulative impacts associated with population and housing is the Westside region of Los Angeles County, which is comprised of the cities of Beverly Hills, Culver City, Malibu, Santa Monica, and West Hollywood as well as the communities of Bel Air, Brentwood, Century City, Hollywood, Marina Del Rey, the Miracle Mile, Pacific Palisades, Playa Vista, Venice, and Westwood.
18 Future development in this portion of the county,
including growth anticipated under the Project, would not induce substantial unplanned population growth in the area as future development would have to be consistent the general plans and zoning codes of local jurisdictions in the area, and therefore would not be unplanned.

In addition, future development in the Westside region of Los Angeles County, including growth anticipated under the Project, would not result in the displacement of substantial numbers of existing people or housing as future development would be required to follow existing state law governing relocation of residents. Therefore, the Project would not contribute to cumulative impacts related to population and housing, and cumulative impacts would be less than significant.

18 Los Angeles County Economic Development Corporation, 2023. Westside. https://laedc.org/thrive-in-la/regions- cities/westside/. Accessed March 2023.

4. Environmental Impact Analysis

4.13. Population and Housing
General Plan 2045 and Zoning Code Update Project 4.13-18 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 4.14-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.14 Public Services

4.14.1 Introduction
This section provides an analysis of the potential environmental impacts on public services associated with implementation of the Project, including potential impacts related to fire protection, police protection, schools, parks, and other public facilities (i.e., City Hall, Transportation Facility, Public Works/Parks Maintenance Yard, Transfer and Recycling Station, and Libraries). The section provides context regarding the existing fire protection services, police protection services, schools, and government facilities in the Planning Area, as well as relevant federal, state, and local regulations and programs.

Parks and recreational facilities are discussed in Section 4.15, Recreation, and fire hazards are discussed in Section 4.19, Wildfire, of this Draft PEIR.

4.14.2 Environmental Setting
Culver City Fire Department
Stations, Facilities, Staffing, and Equipment
The Culver City Fire Department (CCFD) provides fire protection and emergency services to the entirety of the city. CCFD was founded in 1922 and has since received an Insurance Services Office Class 1 rating and achieved accredited agency status from the Commission on Fire Accreditation International. CCFD provides Paramedic Advanced Life Support Services, Fire Suppression Community Risk Reduction and Education programs to the residents and businesses of the city. As of 2019, CCFD is made up of a total of 79 employees who are housed at three fire stations and three support facilities.
1 Fire Station #1 serves as the CCFD headquarters. Each fire station is equipped with unique equipment and personnel needed to serve the community, with at least 18 sworn personnel on duty at all times.
2 Table 4.14-1, Culver City Fire Department
Station Equipment and Personnel, provides a summary of on-site equipment and accompanying personnel at each station.

Other facilities that serve CCFD are the Community Risk Reduction and Fire Administration offices in City Hall, as well as a 4,965-square-foot Fire Drill Training Facility used for teaching firefighting techniques.
3 Figure 4.14-1, Culver City Fire Department Fire Stations, Facilities, and Service Areas, shows all the CCFD stations, support facilities, and service areas within city boundaries.

1 City of Culver City, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 22.
2 Culver City Fire Department, 2019b. Community Risk Assessment, Standards of Cover. https://www.culvercity.org/home/showdocument?id=17458. Accessed March 2023. 3 Culver City Fire Department, 2023. Stations and Facilities. https://www.culvercityfd.org/About-the- Department/Stations-and-Facilities. Accessed March 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.14-1

CULVER CITY FIRE DEPARTMENT STATION EQUIPMENT AND PERSONNEL Location Apparatus Staff Equipment
Station 1
(Headquarters)
Engine
Company
Captain,
engineer,
firefighter
Engine, life support medical equipment, emergency scene lighting, defensive hazardous materials mitigation tools, water rescue equipment, rehab supplies, 50 ft of ground ladders, wildland firefighting equipment, forcible entry tools, automobile extraction equipment, and thermal imaging camera
Paramedic
Resources
2 firefighter/
paramedics with
ALS certification
Advanced life support equipment, basic life support equipment, airway/ventilation equipment, vascular therapy supplies, monitor/defibrillators
Battalion Chief
Command
Vehicle
Battalion chief Communication equipment, mobile data computer, command desk
Station 2 Engine
Company
Captain,
engineer,
firefighter
Engine, life support medical equipment, emergency scene lighting, defensive hazardous materials mitigation tools, water rescue equipment, rehab supplies, 50 ft of ground ladders, wildland firefighting equipment, forcible entry tools, automobile extraction equipment, and thermal imaging camera
Ambulance 2 EMTs Basic life support equipment
Station 3 Engine
Company
Captain,
engineer,
firefighter
Engine, life support medical equipment, emergency scene lighting, defensive hazardous materials mitigation tools, water rescue equipment, rehab supplies, 50 ft of ground ladders, wildland firefighting equipment, forcible entry tools, automobile extraction equipment, and thermal imaging camera
Paramedic
Resources
2 firefighter/
paramedics with
ALS certification
Advanced life support equipment, basic life support equipment, airway/ventilation equipment, vascular therapy supplies, monitor/defibrillators
Engine
Company
Captain,
engineer,
2 firefighters
Aerial ladder truck, 100 ft mounted extension ladder, 200 ft of ground ladders, rescue, and automobile extraction equipment SOURCE: Culver City Fire Department. Stations and Facilities. https://www.culvercityfd.org/About-the-Department/Stations-and- Facilities. Accessed March 2023.

CCFD is supported, when needed, through mutual aid agreements with the fire departments in the City of Los Angeles and Los Angeles County, with further assistance from the cities of Beverly Hills, Santa Monica, and West Hollywood.
4 CCFD in combination with these other supporting fire
departments provide fire protection services for the entire Planning Area.

Fire Hazards
The Planning Area is classified as a Local Responsibility Area (LRA) for fire hazards, meaning that a City or County is financially responsible for wildfire suppression. CCFD would provide fire protection services related to wildfires. An analysis of potential impacts related to wildfires is provided in Section 4.19, Wildfire, of this Draft PEIR.

4 City of Culver City, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 26.

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

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

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

City of Los Angeles
#
GreenValleyCir
1 2
3 °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
!! Fire Station
!! Community Risk Reduction office and Fire Administration !! Fire Drill Training Facility
Fire District 1
Fire District 2
Fire District 3
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
!! Fire Station
!! Community Risk Reduction office and Fire Administration !! Fire Drill Training Facility
Fire District 1
Fire District 2
Fire District 3
Culver City General Plan 2045
Figure 4.14-1
Culver City Fire Department Fire Stations,
Facilities, and Service Areas
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

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CCFD Emergency Response Time
For each type of emergency response call, including fire suppression, wildland fire, emergency medical services (EMS), technical rescue, and hazardous materials emergency response calls, CCFD has established response time performance standards for high risk, moderate risk, and low risk incidents. These standards are described as benchmark performance objectives. Aggregate response times for CCFD are reported using the 90th percentile of the total response time performance per National Fire Protection Association and Commission on Fire Accreditation International standards.

Total response time is comprised of three components including alarm handling time, the amount of time between a dispatcher receiving a 911 call and alerting fire station staff; turnout time, the amount of time between a station receiving an alert and being en route to an incident; and travel time, the amount of time it takes to drive from the fire station to the incident location.

The first-arriving unit is the first unit to arrive at the incident and generally has the responsibility of establishing command at the scene, evaluating the need for additional resources, and providing initial emergency response services. The effective response force (ERF) includes the total number of personnel necessary to address an emergency and/or terminate an incident.

CCFD has differing staffing and capability requirements for the first-arriving unit and ERF dependent on incident type.

Table 4.14-2, CCFD Response Times, shows CCFD response time goals for 90 percent of the time and the five-year aggregate response times from 2014 to 2018.

TABLE 4.14-2

CCFD RESPONSE TIMES
Incident Type CCFD Goala Aggregate 2014–2018 Response Timeb High Risk Fire Incident
First Due-In Unit 7:00 10:16
ERF 14:00 N/A
Moderate Risk EMS Incident
First Due-In Unit 6:20 8:10
ERF 9:50 10:26
Moderate Risk Technical Rescue Incidents
First Due-In Unit 7:30 9:40
ERF 12:00 N/A
Moderate Risk Hazardous Materials Incident
First Due-In Unit 8:00 10:02
ERF 9:00 N/A
NOTES: N/A = not applicable.

SOURCES:
a Commission on Fire Accreditation International, 2019. Accreditation Report, Culver City Fire Department, pages 25 to 31. https://www.culvercityfd.org/files/sharedassets/fire/culvercityfdaccreditationr.pdf. Accessed April 2023. b Culver City Fire Department, 2019b. Community Risk Assessment: Standards of Cover, pages 88 to 97. https://www.culvercity.org/home/showdocument?id=17458. Accessed March 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Though CCFD was able to meet certain response time goals for particular call response types in some years, as shown in Table 4.14-2, their 90th percentile aggregate response time performance for the years 2014–2018 did not meet its overall benchmark response time goals for any emergency response call type.

Mutual Aid Agreements
As described above, CCFD has established mutual aid agreements with the City of Los Angeles, Los Angeles County, and other local municipalities, to increase response levels of service to residents of the city as well as surrounding areas, if aid were needed. CCFD and these neighboring agencies have shared standard operating procedures and regularly participate in joint training programs.
5 Also, the Planning Area is located within the Los Angeles County Operational Area, which is located within mutual aid Region I of the Emergency Mutual Aid Regions established by the California Office of Emergency Services (OES) and is part of the OES Southern Administrative Region. Mutual aid in Los Angeles County is divided into mutual aid assistance "areas," of which the city is a part of Area A. Other jurisdictions that are included within Area A for mutual aid assistance are Beverly Hills, Santa Monica, and West Hollywood. 6 Existing Deficiencies
CCFD faces several challenges related to growth in the city. These challenges relate to increased hazards within the city, resource limitations, meeting response time goals, as well as increased calls for service due to population growth.

Eastern portions of the city including the Blair Hills neighborhood and the northeastern section of the Blanco/Culver Crest neighborhood, as well as larger portions of the city's Sphere of Influence (SOI), are classified as Very High Fire Severity Zones. 7 These areas are known as a
wildland-urban interface (WUI). WUIs are areas where fires that start are dominated by brush or wildland vegetation and have the potential to spread to nearby homes and developments, threatening public safety and property.8
It is anticipated that changing climate patterns will result in increased severity and frequency of fires in the California region. This change could pose a threat to some residents, which may in turn increase demand on CCFD services to respond to these types of incidents.

Another area of concern for CCFD relates to "concurrent runs," which occur when emergency equipment is not available because it is deployed and in use for a prior call for service. Though CCFD attempts to reduce resource consumption by having the first responders cancel unneeded

5 City of Culver City, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 26.
6 City of Culver City, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 26.
7 California Department of Forestry and Fire Protection, 2011. Very High Fire Hazard Severity Zones in Local Responsibility Areas (Culver City). September 2011.
8 City of Culver City, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020, page 27.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
resources, increased calls for service due to population growth increases the likelihood of concurrent runs and consequent resource limitations. Another aspect that depletes available emergency response resources is transportation to hospitals outside of city limits, and subsequent travel back. According to CCFD, approximately 70 percent of transports are taken outside the city and require travel on major arterials and freeways. Traffic congestion along these routes increases travel times and reduces emergency equipment available in the event of a subsequent emergency.9
CCFD’s ability to meet response time standards is reduced as a result of increased emergency call volumes, increased traffic and congestion, and accessibility difficulties related to topographic conditions in certain areas of the city. Baldwin Hills is an area of concern for CCFD due to its topography and the IOF, which make it difficult to access, slowing response times.10 CCFD recognizes that as population increases, the number of emergency incidents, especially EMS calls, will also increase. The city's population has a greater percentage of residents over the age of 55 as compared to Los Angeles County as whole, which could also be a contributing factor to increases in emergency incidents. This increase in service demand may require additional emergency personnel staffing in the future.

Finally, CCFD makes use of Opticom systems to control traffic and provide green lights to emergency vehicles; however, this traffic control technology is outdated. If upgrades were made to the system, CCFD would increase their response time performance.11 Los Angeles County Fire Department
The Los Angeles County Fire Department (LACFD) provides fire protection and emergency medical services to the city’s SOI. LACFD services about 2,300 square miles, including 60 cities and unincorporated communities, and serves approximately 4.1 million residents. There are 4,700 total personnel working within the Fire Department’s emergency and business operations bureaus, including firefighters, dispatchers, lifeguards, nurses, and administrative support. In 2020, LACFD responded to approximately 379,500 emergency dispatch calls, of which over 9,800 (2.6 percent) were fire incidents. A vast majority (about 307,000 calls, or 80.9 percent) were for emergency medical services (EMS).
12 According to the 2021 Department Overview Booklet, LACFD’s fire and rescue resources include 177 fire stations, 228 engine companies, 112 paramedic units, and 34 truck companies.

Specialized resources include three hazardous materials squads, six swift water rescue units, two urban search and rescue squads, two fire boats, and additional specialized equipment. The Air and Wildland Division also maintains a fleet of ten helicopters for paramedic transport, hoist rescues, and wildland firefighting, and contract aircraft are also available during wildfire season.

9 Ibid
10 Ibid
11 CCFD personal communication, 2019. Public Services, Infrastructure and Smart Cities Stakeholder Meeting with City Staff. September 3, 2019.
12 Los Angeles County Fire Department, 2021. Department Overview Booklet. https://fire.lacounty.gov/wp- content/uploads/2021/09/Department-Overview-Booklet_single-pages_9.09.21-A.pdf. Accessed April 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
LACFD is also home to California Task Force 2 (also known as USA Task Force 2), which is an urban search and rescue team that is qualified to respond to local, national, and international disasters.

Calls for emergency response are answered by nearly 100 dispatchers who dispatch units to approximately 400,000 incidents annually.
13 LACFD follows national guidelines that require a
five-minute response time for first-arriving fire and EMS units and eight minutes for paramedic units in urban areas, as well as an eight-minute response time for first-arriving fire and EMS units and 12 minutes for paramedic units in suburban areas.

The city’s SOI is part of Division VII of the LACFD and is located within the service area of LACFD Station 58, located at 5757 Fairfax Avenue within the city of Los Angeles.14 Police Protection
Culver City Police Department
Police protection for the city is provided by the Culver City Police Department (CCPD), which is responsible for providing visible patrol, preliminary criminal investigations, follow-up investigations, traffic accident investigations, and specialized investigations of crimes such as identify theft, vice offenses, and similar crimes. CCPD promotes community safety through deterrence and prevention of crime, apprehension of offenders, and education of the public in self-protective measures to minimize victimization. Additionally, CCPD collaborates with the Los Angeles County Sheriff’s Department (LASD), when needed, for large scale police related emergencies. CCPD, along with several other local cities, contracts with the South Bay Regional Public Communications Authority for dispatch services.

CCPD is staffed with two full time K-9 units, an Emergency Response Team (ERT), a Crisis Response Team (CRT), a Mental Health Evaluation Team (MET), and a Partnership in Policing Team (PIP). In addition, CCPD provides neighborhood and business watch programs to prevent criminal activities, which involve the PIP team. Crime patterns are routinely analyzed and dispersed to patrol officers and special crime suppression units. Monthly reports are prepared and made public that identify monthly statistics and information related to crime and arrests, staffing, parking and traffic citations and traffic collisions.

CCPD has 109 sworn officers and 52 professional staff that serve an area of approximately 5 square miles with a residential (nighttime) population of approximately 40,000, and a daytime population of 300,000+.
15,16,17 Table 4.14-3, CCPD Population, Officer, and Crime Comparison

13 Los Angeles County Fire Department, 2021. Department Overview Booklet. https://fire.lacounty.gov/wp- content/uploads/2021/09/Department-Overview-Booklet_single-pages_9.09.21-A.pdf. Accessed April 2023. 14 County of Los Angeles, 2023. LACoFD Fire Station Boundaries. Updated January 24, 2023. https://geohub.lacity.org/datasets/lacounty::lacofd-fire-station-boundaries-feature-layer- /explore?location=33.993802%2C-118.387710%2C14.25. Accessed April 2023. 15 Culver City Police Department, 2023a. About CCPD. https://www.culvercitypd.org/Office-of-the-Chief-of- Police/About-CCPD. Accessed May 2023.
16 Culver City Police Department, 2023b. 2023- Quarter 1 Report. 17 Daytime population is the number of people in a city during the day, including commuters and tourists. Nighttime population is the number of people who live in a city, typically residents.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
(2023), provides a summary of the population, sworn officers, officer to population ratio, annual report crimes, and crimes per 1,000 population for both the daytime population and the residential (nighttime) population. As shown in Table 4.14-3, Based on the number of sworn officers provided in the 2023 Quarter 1 Report published by CCPD, the City has an officer to daytime population ratio of approximately 1:2,752 and a nighttime officer to population ratio of approximately 1:367.

TABLE 4.14-3
CCPD POPULATION, OFFICER, AND CRIME COMPARISON (2023)
Population
Sworn
Officers
Officers/
Population
Ratio
Annual Reported
Crimes
Crimes per 1,000
Population
Daytime Population 300,000+ 109 1/2,752a 2,684b 7.1c
Residential (nighttime)
Population
40,000 109 1/367d 2,684b 53.3e
NOTES:
a 300,000+ daytime population/109 officers = 2,752 residents/1 officer. b Crime data is provided for Quarter 4 of 2022 (the latest whole year for which annual crime data was available). c 2,684 crimes/300,000 daytime population = 0.0071 x 1,000 = 7.1 crimes per 1,000 daytime population. d 40,000 residential (nighttime) population/109 officers = 367 residents/1 officer. e 2,684 crimes/40,000 residents = 0.0533 X 1,000 = 53.3 crimes per 1,000 residents.

SOURCE: ESA, 2023.

As shown in Figure 4.14-2, Police Stations within the Planning Area, CCPD is divided into five patrol districts and has one station located at 4040 Duquesne Avenue. The most current average response time documented in the CCPD December 2021 Monthly Report was 4 minutes and 18 seconds for emergency calls and 9 minutes and 36 seconds for non-emergency calls.18 Table 4.14-4, Culver City 2022 Crime Statistics, identifies crimes reported in the city in 2022 (the latest annual crime statistics). The crime statistics are based on the National Incident-Based Report System (NIBRS). As of January 1, 2021, the Federal Bureau of Investigation (FBI) made the nationwide implementation of NIBRS a top priority to provide more useful statistics to promote constructive discussion, measures, and informed policing. NIBRS establishes a new baseline that more precisely captures reported crime in a community.

18 Culver City Police Department, 2021. Monthly Report. December 2021. https://www.culvercitypd.org/files/assets/police/documents/monthly-reports/december-2021.pdf. Accessed April 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).

City of Los Angeles
#
GreenValleyCir
2 3
1 5
4 °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
!! Culver City Police Station
Car District 1
Car District 2
Car District 3
Car District 4
Car District 5
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
!! Culver City Police Station
Car District 1
Car District 2
Car District 3
Car District 4
Car District 5
Culver City General Plan 2045
Figure 4.14-2
Police Stations within the Planning Area
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

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.14-4
CULVER CITY 2021 CRIME STATISTICS
Crime Type Number
Percent of Culver
City Crimea
Murder 0 0%
Homicide 0 0%
Rape/Sexual Assault 26 1%
Aggravated Assault 144 5%
Simple Assault 243 9%
Kidnapping 11 0%
Human Trafficking 0 0%
Robbery 114 4%
Subtotal Violent Crime 538
Burglary 280 10%
Larceny/Theft 1,590 59%
Motor Vehicle Theft 264 10%
Arson 12 0%
Subtotal Property Crime 2,146
Total 2,684
a Percentages are rounded.

SOURCE: Culver City Police Department, 2021. Monthly Report. December 2021.

As indicated in Table 4.14-4, a total of 2,684 violent and property crimes were reported in Culver City in 2021. No homicides were reported in the city in 2022. It should be noted that in 2022, 2,146 (or approximately 79 percent) of the reported crimes were property crimes (burglary, larceny/theft, motor vehicle theft, and arson), compared to the 538 (or approximately 19 percent) reported violent crimes (assault, kidnapping, robbery, etc.). Based on these numbers, and as shown above under Table 4.14-3, Culver City has an existing annual crime rate of approximately 7.1 crimes per 1,000 daytime population of 300,000+ people. In addition, as also shown in Table 4.13-3, based on a residential (nighttime) population of approximately 40,000, Culver City has an existing annual crime rate of approximately 53.3 crimes per 1,000 residential (nighttime) population.

Los Angeles County Sheriff’s Department
Los Angeles Community College District (LACCD) contracts with LASD to provide college law enforcement services at West Los Angeles College (WLAC), located within the City’s SOI. The WLAC Sheriff’s Department has authority to apprehend and arrest individuals involved in illegal activity on the campus and areas immediately adjacent to the campus. The WLAC Sheriff Station is located on the western portion of the campus along Freshman Drive and includes one LASD team leader and two LASD deputies.19 In addition to assigning its own officers to the WLAC

19 West Los Angeles College, 2021. 2021 Annual Security Report – West Los Angeles College, pg. 18. https://www.wlac.edu/sites/wlac.edu/files/2022-08/2021AnnualSecurityReport.pdf. Accessed April 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Campus, the WLAC Sheriff Department/Vice President of Administrative Services supervised a corps of LACCD police cadets from January 2020 through April 2020. Police cadets provide college paraprofessional administrative support and parking enforcement. In 2020, there were no crimes reported on campus, off campus, or on public property. 20 Parks and Recreation Facilities
Please see Section 4.15, Recreation, of this Draft PEIR, for information pertaining to parks and recreation facilities.

Schools
Culver City Unified School District
The city is served by Culver City Unified School District (CCUSD), which offers public school programs from preschool and K–12, as well as adult education courses. CCUSD is comprised of five elementary schools, one middle school, one high school, one independent learning academy, and one adult education school.21
There are also six private elementary schools including Echo Center, Echo Horizon, Pacifica Montessori, Park Century Elementary, Willows Community School, and Turning Point School.

Further, the Exceptional Children's Foundation (ECF) Kayne Eras Center and STAR Prep Academy offer private education opportunities to city students in grades K–12. There are a variety of higher education institutions located in the Planning Area including Antioch University Los Angeles, Otis, and WLAC.

Capacity and Enrollment
Enrollment varies at each of the CCUSD campuses, with the highest number of students enrolled in Culver City High School (CCHS). Student enrollment for the 2022–23 school year at each CCUSD school is shown in Table 4.14-5, Capacity of CCUSD Schools. Attendance areas for El Rincon, Farragut, La Ballona, and Linwood E. Howe are shown in Figure 4.14-3, CCSUD Attendance Areas. Student enrollment at El Marino is open to all residents in the CCUSD attendance area who wish to participate in the school's unique Language Immersion programs.

Each of the five elementary schools funnel students into Culver City Middle School (CCMS) for sixth grade through eighth grade, which then leads to enrollment in CCHS for ninth grade through twelfth grade. An alternative independent study program is available for students in grades K–12 through iAcademy (CCUSD iAcademy).

20 West Los Angeles College, 2021. 2021 Annual Security Report – West Los Angeles College, pg. 18. https://www.wlac.edu/sites/wlac.edu/files/2022-08/2021AnnualSecurityReport.pdf. Accessed April 2023. 21 Culver City Unified School District. 2023c. Our Schools. https://www.ccusd.org/. Accessed May 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.14-5 C APACITY OF CCUSD SCHOOLS
Site Capacity
2018–2019
Existing
Enrollment
2022–2023
Existing
Enrollment
Remaining
Capacity as
of 2022–2023
Culver City Middle School 1,917 1,655 1,583 334
Culver City High School 2,565 2,230 2,155 410
Total Middle and High School Capacity 4,572 3,885 3,738 834 15% Efficiency Adjustment for Middle and High School -645 Practical Total Middle and High School Capacitya 3,927 3,885 N/A 189 El Marino Elementary 826 842 779 47
El Rincon Elementary 645 582 608 37
Farragut Elementary 549 576 560 (11)
La Ballona Elementary 657 595 568 89
Linwood E. Howe Elementary 511 601 559 (48)
Total Elementary School Capacity 3,188 3,196 3,074 114
Total District Capacity 7,115 7,081 6,812 303
a Practical capacity accounts for the 15% efficient adjustment made for middle and high school capacity.

SOURCE: CCUSD, 2020. Draft Developer Fee Study; California Department of Education, 2019b. California Department of Education, 2023.

Overall, enrollment in CCUSD has generally been increasing since the 2013–2014 school year from 6,691 students during the 2013–2014 school year to 6,812 students in the 2022–2023 school year.22,23 Although enrollment in CCUSD increased from 2013–2014 to 2018–2019, enrollment has decreased steadily from 2018–2019 to 2022–2023. Enrollment in Los Angeles County as a whole is projected to decrease by approximately 12 percent in enrollment by the 2023–2024 school year and by approximately 19 percent by the 2027–2028 school year. 24,25 Capacity
Table 4.14-5, Capacity of CCUSD Schools, shows the existing capacity, enrollment, and remaining capacity in the CCUSD schools. Although CCUSD is in the process of addressing existing deficiencies, including aging facilities and safety concerns in their school facilities, there is currently capacity remaining at all CCUSD schools, except for Farragut Elementary and Linwood E. Howe Elementary.

22 California Department of Education, 2019a. 2018–19 Enrollment by Ethnicity and Grade, Culver City Unified Report. https://dq.cde.ca.gov/dataquest/dqcensus/EnrEthGrd.aspx?cds=1964444&agglevel=district&year=2018-

19. Accessed March 2023.
23 California Department of Education, 2014. 2013–14 Enrollment by Ethnicity and Grade, Culver City Unified Report. https://dq.cde.ca.gov/dataquest/dqcensus/EnrEthGrd.aspx?cds=1964444&agglevel=district&year=2018-19.

Accessed March 2023.
24 California Department of Education, 2019b. 2018–19 Enrollment by Ethnicity and Grade, Los Angeles County Report. https://dq.cde.ca.gov/dataquest/dqcensus/EnrEthGrd.aspx?cds=19&agglevel=county&year=2018-19.

Accessed March 2023.
25 California Department of Finance, 2022. California Public K–12 Graded Enrollment Projections Table, 2022 Series. https://dof.ca.gov/forecasting/demographics/public-k-12-graded-enrollment/. Accessed March 2023. #
City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
CCUSD Attendance Area
El Rincon
Farragut
La Ballona
Linwood Howe
City of Los Angeles
West Los
Angeles
College
Ballo
na
Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

Inglewood Oil Field
Baldwin Hills
City of Los Angeles
GreenValleyCir
°00 .45 0 .90.225
Miles
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa r kw
ay
Washington Pl.

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

Washing
ton Blvd.

Unincorporated
County
Venice Blvd.

La Cie
nega Blvd.

Venice Blvd.

Wa
shin
gton
Blvd.

La Cienega Blvd
.

Sepulv
eda Blvd.

Culver City General Plan 2045
Figure 4.14-3
CCSUD Attendance Areas
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

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CCUSD has two middle school campuses and one high school campus that are currently not operational due to a decline in enrollment: Betsy Ross and Washington Middle Schools and Culver Park High School. The Middle School campuses are currently under long-term leases and are operated as private schools (Echo-Horizon School and Wildwood School). CCUSD had a third elementary school campus (Linda Vista/Ohr Eliyahu Academy), which was sold to the Westside Children's Center in 1992. The property was redeveloped as the Stoneview Nature Center operated by the State of California's Baldwin Hills Conservancy. The Westside Children's Center (renamed to Allies for Every Child) relocated to the Fox Hills neighborhood of the city.

Government and Other Community Facilities
Government Facilities
Figure 4.14-4, Government and Civic/Cultural Facilities within the Planning Area, shows the City- owned government facilities located within Culver City as described below. There are no government facilities located within the SOI.

City Hall. Culver City’s City Hall is located at 9770 Culver Boulevard and is a three-story, 75,964- square-foot structure built in 1995 with a two-level parking structure located beneath the building.26 The following City Departments are housed within City Hall:
• Administrative Services
• City Attorney
• City Manager
• Economic Development
• Planning and Development
• Housing and Human Services
• Finance
• Fire Administration & Community Risk Reduction
• Public Works Engineering, Mobility & Traffic Engineering • Technology
Transportation Facility. This 49,000-square-foot facility is located at 4343 Duquesne Avenue and houses the City’s Transportation Department. This facility has been serving the community since 1998.27
Public Works/Parks Maintenance Yard. This 82,112-square-foot facility is located at 9505 Jefferson Boulevard and houses the City’s public works and maintenance operations. This facility has been serving the community since 1978.28

26 Faithful and Gould, 2019a. Facility Condition Assessment for Culver City Hall. October 15, 2019. 27 Faithful and Gould, 2019b. Facility Condition Assessment for Culver City Transportation Facility. October 15, 2019. 28 Faithful and Gould, 2019c. Facility Condition Assessment for PW Maintenance Yard. October 8, 2019.

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

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

Jefferson
Blvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

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

City of Los Angeles
#
GreenValleyCir

CULVER CITY

JULIAN DIXON

LIBRARY

CULVER CITY

TEEN CENTER

TRANSFER AND

RECYCLING

STATION

PUBLIC WORKS

MAINTENANCE YARD

CITY HALL

CULVER CITY

SENIOR CENTER

TRANSPORTATION FACILITY

VETERANS

MEMORIAL
°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
Government Facilities
Civic and Cultural Facilities
City of Los Angeles
West Los
Angeles
College
Ballona Creek
Marina Del Rey
Ladera Heights
(Unincorporated County)
City of Santa
Monica
Washington Blvd.

SepulvedaBlvd.

OverlandAve.

CulverBlvd.

Slauson Ave.

JeffersonBlvd.

DuquesneAve.

National Blvd.

BristolParkway
WashingtonPl.

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

City of Los Angeles
#
GreenValleyCir

CULVER CITY

JULIAN DIXON

LIBRARY

CULVER CITY

TEEN CENTER

TRANSFER AND

RECYCLING

STATION

PUBLIC WORKS

MAINTENANCE YARD

CITY HALL

CULVER CITY

SENIOR CENTER

TRANSPORTATION FACILITY

VETERANS

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

Sepulveda Blvd.

OverlandAve.

CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa r kw
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

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
Government Facilities
Civic and Cultural Facilities
Culver City General Plan 2045
Figure 4.14-4
Government and Civic/Cultural Facilities
within the Planning Area
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

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Transfer and Recycling Station. This 29,144-square-foot facility is located at 9255 West Jefferson Boulevard and has been serving the city since 1983. It is a processing site for the temporary deposition of waste and recycling and accepts waste from construction and demolition, dry industrial, municipal solid waste, and recyclable materials and organic waste. 29 Media Park Renovation. The City has a long-term lease with the City of Los Angeles to improve and operate Media Park adjacent to the Downtown. A proposed conceptual park renovation plan was prepared and shared with the public in April 2021. The plans are still under consideration by the Culver City Council and Los Angeles Department of Parks and Recreation.

Libraries
The Los Angeles County Public Library (LACPL) provides library services to the city through its branch, the Culver City Julian Dixon Library, located at 4975 Overland Avenue as shown in Figure 4.14-4. The Julian Dixon Library, which began as the Culver City Library, was established in 1915 in the Pacific Electric Railroad Depot. Over the years, the library moved to several locations as it grew larger until it came to its current location, where it has been since 1970. The library was renamed the Culver City Julian Dixon Library by the Los Angeles County Board of Supervisors in honor of U.S. Congressman Julian Dixon who represented the 32nd U.S.

Congressional District from 1979 to 1993. After being closed for more than a year for renovations, the Culver City Julian Dixon Library re-opened on February 20, 2016. 30 The facility is
approximately 21,406 square feet in size, with sustainability and energy efficiency features, and includes amenities such as new computers, iPad catalogs, digital signage, new furniture, and a security system.

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

Federal
Occupational Safety and Health Administration
The Federal Occupational Safety and Health Administrations (OSHA) as well as California OSHA (Cal/OSHA) enforce the provisions of the federal and state Occupational Safety and Health Acts, respectively, which collectively require safety and health regulations for construction under Part 1926 of Title 29 Code of Federal Regulations (CFR). The fire-related requirements of the Federal Occupational Safety and Health Act are specifically contained in Subpart F, Fire Protection and Prevention, of Part 1926. Examples of general requirements related to fire protection and prevention include maintaining fire suppression equipment specific to construction on-site; providing a temporary or permanent water supply of sufficient volume, duration, and pressure;

29 Culver City, 2016. Americans with Disabilities Act (ADA) Self Evaluation and Transition Plan, PS0061 RFP Number 1590, Addendum No. 1. https://www.culvercity.org/home/showdocument?id=2339. Accessed on October 23, 2019.
30 Culver City News, 2016. Dixon Library re-opens after renovation. February 18, 2016. https://www.culvercitynews.org/dixon-library-re-opens-after-renovation/. Accessed March 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
properly operating the on-site fire-fighting equipment; and keeping storage sites free from accumulation of unnecessary combustible materials.

Federal Emergency Management Agency
The Federal Emergency Management Agency (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 U.S. 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. FEMA also initiates proactive mitigation activities, trains first responders, and manages the National Flood Insurance Program and the U.S. Fire Administration.

Disaster Mitigation Act of 2000
Disaster Mitigation Act (42 United States Code [USC] Section 5121) provides the legal basis for FEMA mitigation planning requirements for state, local, and Tribal governments as a condition of mitigation grant assistance. It amends the Robert T. Stafford Disaster Relief Act of 1988 (42 USC Sections 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 Disaster Mitigation Act reinforces the importance of pre-disaster infrastructure mitigation planning to reduce disaster losses nationwide and the streamlining of the administration of federal disaster relief and programs to promote mitigation activities. Some of the major provisions of the Disaster Mitigation Act include the following:
• 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)
• Adjusting ways in which management costs for projects are funded The mitigation planning provisions outlined in Section 322 of the Disaster Mitigation 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.

State
California Building Code and California Fire Code
The California Building Code (California Code of Regulations [CCR], Title 24, Part 2) is a compilation of building standards, including general fire safety standards for new buildings,

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
which are presented with more detail in the California Fire Code (CCR Title 24, Part 9). California Building Code standards are based on building standards that have been adopted by state agencies without change from a national model code, building standards based on a national model code that have been changed to address particular California conditions, and building standards authorized by the California legislature but not covered by the national model code.

The 2022 edition of the California Building Code became effective on January 1, 2023. 31 The
building standards in the California Building Code apply to all locations in California, except where more stringent standards have been adopted by state agencies and local governing bodies. Typical fire safety requirements of the California Fire Code include: the installation of fire sprinklers in all high-rise buildings; the establishment of fire resistance standards for fire doors, building materials, and particular types of construction; and the clearance of debris and vegetation within a prescribed distance from occupied structures within wildfire hazard areas.

Uniform Fire Code
The Uniform Fire Code contains regulations relating to construction, maintenance, and use of buildings. Topics addressed in the code include fire department access, fire hydrants, automatic storage and use, provisions intended to protect and assist fire responders, industrial processes, and many other general and specialized fire-safety requirements for new and existing buildings and the surrounding premises. The code contains specialized technical regulations related to fire and life safety.

California Health and Safety Code
State fire regulations are set forth in Section 13000 et seq. of the California Health and Safety Code, including regulations for building standards (also set forth in the California Building Code), and fire protection and notification systems, fire protection devices such as extinguishers and smoke alarms, high-rise building and childcare facility standards, and fire suppression training.

California Occupational Safety and Health Administration In accordance with California Code of Regulations, Title 8, Sections 1270, Fire Prevention, and 6773, Fire Protection and Fire Equipment, Cal/OSHA has established minimum standards for fire suppression and emergency medical services. The standards include, but are not limited to, guidelines on the handling of highly combustible materials; fire hose size requirements; restrictions on the use of compressed air; requirements for access roads; and guidelines for testing, maintaining, and using all firefighting and emergency medical equipment.

Mutual Aid Agreements
The California Disaster and Civil Defense Master Mutual Air Agreement, as provided by the California Emergency Services Act, provides statewide mutual aid between and among local jurisdictions and the state. The statewide mutual aid system exists to ensure that adequate resources, facilities, and other supports are provided to jurisdictions whenever resources prove to be inadequate for a given situation. Each jurisdiction controls its own personnel and facilities but can give and receive help whenever needed.

31 California Building Code (CCR, Title 24, Part 2).

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
California Vehicle Code, Section 21806
Section 21806 of the California Vehicle Code (CVC) pertains to emergency vehicles responding to Code 3 incidents/calls.32 This section of the CVC states the following:

Upon the immediate approach of an authorized emergency vehicle which is sounding a siren and which has at least one lighted lamp exhibiting red light that is visible, under normal atmospheric conditions, from a distance of 1,000 feet to the front of the vehicle, the surrounding traffic shall, except as otherwise directed by a traffic officer, do the following: (a)(1) Except as required under paragraph (2), the driver of every other vehicle shall yield the right-of-way and shall immediately drive to the right-hand edge or curb of the highway, clear any intersection, and thereupon shall stop and remain stopped until the authorized emergency vehicle has passed. (2) A person driving a vehicle in an exclusive or preferential use lane shall exit that lane immediately upon determining that the exit can be accomplished with reasonable safety … (c) All pedestrian upon the highway shall proceed to the nearest curb or place of safety and remain there until the authorized emergency vehicle has passed.

California Constitution Article XIII, Section 35
Section 35 of Article XIII of the California Constitution at subdivision (a)(2) provides: “The protection of public safety is the first responsibility of local government and local officials have an obligation to give priority to the provision of adequate public safety services.” Section 35 of Article XIII of the California Constitution was adopted by the voters in 1993 under Proposition 172. Proposition 172 directs the proceeds of a 0.50 percent sales tax to be expended exclusively on local public safety services. California Government Code Sections 30051–30056 provide rules to implement Proposition 172. Public safety services include fire protection. Section 30056 mandates that cities are not allowed to spend less of their own financial resources on their combined public safety services in any given year compared to the 1992–93 fiscal year.

Therefore, an agency is required to use Proposition 172 to supplement its local funds used on fire protection services, as well as other public safety services. In City of Hayward v. Trustee of California State University (2015) 242 Cal. App. 4th 833, the court found under Section 35 that cities have “a constitutional obligation to provide adequate fire protection services.” 33 The
Hayward ruling also concluded that “assuming the city continues to perform its obligations, there is no basis to conclude that the project will cause a substantial adverse effect on human beings” and the “need for additional fire protection services is not an environmental impact that CEQA requires a project proponent to mitigate.”
34 California Governor’s Office of Emergency Services
In 2009, the State of California passed legislation creating the California Governor's Office of Emergency Services (Cal OES) and authorized it to prepare a Standard Emergency Management

32 A Code 3 response to any emergency may be initiated when one or more of the following elements are present: a serious public hazard, an immediate pursuit, preservation of life, a serious crime in progress, and prevention of a serious crime. A Code 3 response involves the use of sirens and flashing red lights. 33 City of Hayward v. Board of Trustees of California State University (2015) 242 Cal.App.4th 833, 843, 847. 34 Ibid.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
System (SEMS) program (Government Code Section 8607; 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 government requests 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 coordinates the state response to major emergencies in support of local government. The primary responsibility for emergency management resides with 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, above). California Emergency Management Agency (Cal-EMA) maintains oversight of the state’s mutual aid system.

California Fire Service and Rescue Emergency Aid System CCFD participates in the California Fire Service and Rescue Emergency Mutual Aid System through which Cal OES, Fire and Rescue Division is responsible for the development, implementation and coordination of the California Fire Service and Rescue Emergency Mutual Aid Plan (Mutual Aid Plan).
35 The Mutual Aid Plan outlines procedures for establishing mutual aid agreements at the local, operational, regional, and state levels, and divides the state into six mutual aid regions to facilitate the coordination of mutual aid. CCFD is located in Region I.

Through the Mutual Aid Plan, Cal OES is informed of conditions in each geographic and organizational area of the state, and the occurrence or imminent threat of disaster. All OES Mutual Aid Plan participants monitor a dedicated radio frequency for fire events that are beyond the capabilities of the responding fire department and provide aid in accordance with the management direction of Cal OES.
36 California Penal Code
All law enforcement agencies in California are organized and operated in accordance with the applicable provisions of the California Penal Code. This code sets forth the authority, rules of conduct, and training for peace officers. Under state law, all sworn municipal and county officers are state peace officers.

Senate Bill 50 (Chapter 407, Statutes of 1998)
Under Senate Bill (SB) 50, a school district may levy impact fees on new development in order to mitigate potential impacts of the development on school facilities, and payment of these fees is considered full and complete mitigation of the impacts, according to California Government Code Section 65995. However, Government Code Section 65995 limits the power of cities and

35 California Governor’s Office of Emergency Services, Fire and Rescue Division, 2023. California Fire Service and Rescue Emergency Mutual Aid System, Mutual Aid Plan. Revised February 2023. 36 Los Angeles Fire Department, 2014. Mutual Aid Agreements/Disaster Declarations/Potential Fiscal Impacts. July 3, 2014.

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counties to require mitigation of school facilities impacts as a condition of approving new development.

California Education Code
Part 10.5, Chapter 1 School Sites
Sections 17210 to 17224 of the California Education Code governs the evaluation and selection of new sites and additions to existing sites for public schools, and for charter schools seeking state funding for school property acquisition or construction. Section 17211 requires the governing board of a school district to evaluate property proposed for a new school site or addition to an existing site at a public hearing prior to acquisition. Section 17212 requires the governing board of a school district to evaluate expert investigations into all factors affecting the public interest regarding a proposed school site prior to acquisition, including geological and soil engineering studies of such a nature as to preclude siting of a school in any location where the geological and site characteristics are such that the construction effort required to make the building safe for occupancy is economically infeasible. Under Section 17212, the evaluation should also include the site’s location in respect to population, transportation, water supply, waste disposal, utilities, traffic hazards, and surface drainage conditions, and other factors affecting the costs of the project. The chapter precludes the selection of a site where hazardous geological or soil conditions, hazardous substances, or proximity to an airport would pose a danger to public health or safety.

Part 10.5, Chapter 3 Construction of Buildings
The California Department of Education (CDE) establishes standards for the selection of school sites pursuant to Education Code Section 17251. In 2000, CDE’s School Facilities Planning Division (SFPD) updated the Guide to School Site Analysis and Development, which was originally published in 1966. The guide assists school districts in determining the amount of land needed to meet their educational purposes according to CDE recommendations.

California Public Resources Code Section 21151.8
Public Resources Code Section 21151.8 requires that an EIR or negative declaration for a project involving the purchase of a school site or the construction of a new elementary or secondary school by a school district must include information on potential safety and health hazards to school occupants, including the presence of hazardous waste, hazardous substance release, pipelines, and air quality risks.

Regional
Los Angeles County Fire Code
The County Fire Code consists of fire prevention provisions, development specifications and fuel modification requirements. Fire prevention provisions covered in the County Fire Code include fire apparatus access roads, adequate road widths, all-weather access requirements, fire flow requirements, and fire hydrant spacing. The code also requires clearance of brush around structures located in hillside areas that are considered at risk for wildland fire.

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Los Angeles County Operational Area Emergency Response Plan The County approved an Operational Area Emergency Response Plan in 1998, which was updated in 2012. The plan establishes the County’s emergency organization, assigns tasks, specifies policies and general procedures, and provides for coordination of planning efforts among the various emergency departments, agencies, special districts, and jurisdictions that make up the County Operational Area. The plan ensures the most effective allocation of resources for the protection of the public in the event of an emergency.

Los Angeles County General Plan
The 2015 Los Angeles County General Plan has two chapters that pertain to police and fire services: the General Plan Public Services and Facilities Element and the General Plan Safety Element. The Public Services and Facilities Element establishes goals and policies for effective service and facilities planning and maintenance. The General Plan Safety Element establishes goals and policies for reducing the potential risk of death, injury, and economic damage from natural and human-caused disasters. As it relates to public services, the General Plan Safety Element has goals and policies related to effective emergency response and preparing for and/or preventing fire hazards. Most of the General Plan goals and policies for fire hazard preparation and prevention pertain to wildland fire hazards.

County of Los Angeles Office of Emergency Management
The County of Los Angeles Office of Emergency Management (OEM), established by Chapter

2.68 of the Los Angeles County Code, is responsible for organizing and directing emergency preparedness efforts, as well as the day-to-day coordination efforts, for the County’s Emergency Management Organization. OEM’s broad responsibilities include, among others, planning and coordination of emergency services on a Countywide basis. 37 Los Angeles County organizes a formal mutual aid agreement between all police departments within its jurisdiction to provide police personnel and resources to assist other member agencies during emergency and/or conditions of extreme peril. This ensures adequate resources should an emergency arise that requires immediate response by more law enforcement personnel than would be available to the Los Angeles Police Department using only its own available resources.

Local
CCUSD Facilities Master Plan
CCUSD adopted its Facilities Master Plan in 2014, which outlined planned improvements to school facilities throughout its campuses. These changes were designed to increase student safety and health, familiarize students with the use of technology, and facilitate student learning and engagement. Planned improvements include asbestos and hazardous materials removal, exterior/site illumination improvements, fire alarm upgrades, security system installation, construction of shade structures, seismic retrofitting of existing structures, and installation of technology/telecom systems and electrical infrastructure. Overall, the cost of improvements to

37 County of Los Angeles Chief Executive Office, Office of Emergency Management, 2023. OEM at a Glance. https://ceo.lacounty.gov/emergency-management/#1509664666354-388bbaed-fcaf. Accessed March 2023.

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all CCUSD facilities identified in the Facilities Master Plan, along with construction contingencies, cost escalations, general conditions, liability, and design costs was estimated at $165,300,161. 38 The CCUSD is currently in the process of developing an updated Facility Master Plan. 39 Hazard Mitigation Plan
The federal Disaster Mitigation Act of 2000 requires that a community have an approved hazard mitigation plan in order to be eligible to apply for and receive FEMA hazard mitigation funds.

The City and CCUSD received a grant to prepare a Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) which was approved by Cal OES and FEMA on June 1, 2017. 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 identifies the types of hazards that threaten the city, evaluates the city’s vulnerability to those threats, and outlines a strategy to reduce or eliminate the risk posed by those threats. 40 The Act requires that the plan be updated every five years. The City and CCUSD are in the process of updating the MJHMP as required and to address recent state legislation (Assembly Bill 747 and Senate Bill 99) regarding evacuation routes.

Culver City Municipal Code
Sections of the City’s Municipal Code applicable to fire protection, police protection, and EMS services include but are not limited to the following:

Section 9.02.005 (Adoption of the 2022 CFC): Adopts the 2022 CFC with amendments as the Fire Code of Culver City (Fire Code).

Section 9.02.035 (Keysets, Handles, Locks and Keys): All noted exterior doors shall be provided with locksets and handles for Fire Department Access. Keys for required access shall be provided by the owner and made readily available in the KNOX Box.

Section 9.02.040 (Automatic Fire-Extinguishing System): An automatic fire-extinguishing (sprinkler) system shall be installed in every new building in the city, including any new residential building, hereinafter constructed or moved into the city, regardless of area separation or type of construction.

Section 9.02.055 (Fire Hydrant Spacing): Fire hydrant spacing in commercial/industrial/residential areas shall be 300 feet apart. The maximum distance of a fire hydrant to a Fire Department Connection (FDC) shall not exceed 100 feet.

Section 9.08.385 (Authority to Close Streets): This section requires coordination with the Public Works Department to notify the Police Department and Fire Department prior to street closure for construction or repair work.

38 Culver City Unified School District, 2014. Facilities Master Plan. https://www.ccusd.org/CapitalProjects/CCUSD_Facilities_Master_Plan.pdf. Accessed March 2023. 39 Culver City Unified School District, 2023a. Culver City USD Future-Ready Facilities Plan. https://www.ccusdfutureready.org/. Accessed March 2023. 40 Culver City, 2023. Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation- Plan. Accessed March 2023.

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Section 11.04.045 (Excessive False Alarms): This section allows the City to access services charges to property owners for each false alarm that results in a CCPD response in excess of three false alarms in a 12-month period.

Section 11.04.065 (Police Chief Discretion): This section states that the Chief of Police shall have discretion to enforce rules, regulations, policies, procedures and directives necessary to implement the provisions of Chapter 11.04, Alarm Systems. Such powers shall include, but are not limited to, the power to promulgate, execute and enforce a policy regarding dispatch of police to alarm signals, as well as the discretion to discontinue police response to alarm signals due to the user's failure to comply with the provisions of Chapter 11.04, or to properly repair alarm systems deemed to constitute runaway alarms.

Section 17.300.040 (Outdoor Lighting): This section requires that security lighting be provided at all building entrances and exits.

Section 17.540 (Site Plan Review): This section provides procedures and standards for the comprehensive review of proposed development projects to: ensure compliance with the required standards, design guidelines, and ordinances of the City; minimize potential adverse effects on surrounding properties and the environment; and protect the integrity and character of the residential, commercial, and public areas of the city. As such, this section may require new projects to be reviewed by CCFD and CCPD to ensure that fire- related, public safety, and site security measures are incorporated.

Section 17.560 (Comprehensive Plans): This section provides procedures and standards for Comprehensive Plans, including required findings to ensure that the proposed development is capable of creating an environment of sustained desirability and stability and will not be substantially detrimental to present and potential surrounding uses. As part of the Comprehensive Plan process, the Planning Department circulates project plans to other City departments for review and comment, including to CCFD and CCPD.

Culver City Fire Department 2019 Community Risk Assessment & Standards of Cover
CCFD’s 2019 Community Risk Assessment & Standards of Cover (CRA) serves as CCFD’s Integrated Risk Management Plan. The CRA defines the process, known as “deployment analysis,” as a written procedure which determines the distribution and concentration of fixed and mobile resources of an organization. The purpose for completing such a document is to assist the agency in ensuring a safe and effective response force for fire suppression, emergency medical services, and specialty response situations. The CRA serves as: (1) the basis for continually measuring service level performance; (2) a predictive tool for helping to determine workload and ideal unit utilization; (3) a management tool for determining apparatus type and staffing levels; (4) a descriptive tool for validating service levels; and (5) a baseline tool for defining service level objectives. Performance measures set forth in the CRA applicable to the Project include, but are not limited to, the following:
41 • Response Time Goals: Response time goals for fire suppression, technical rescue and HazMat are 7 minutes for the first due-in unit and 8 minutes for the Effective Response Force (ERF), 90 percent of the time. Response time goals for emergency medical services

41 Culver City Fire Department, 2019b. Community Risk Assessment, Standards of Cover. https://www.culvercity.org/home/showdocument?id=17458. Accessed March 2023.

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(EMS) are 6 minutes, 20 seconds for the first due-in unit and 9 minutes, 50 seconds for the ERF, 90 percent of the time. It is noted that the above are goals, not standards. • Fire Flow Requirements: Fire flow requirements range from 2,000 gallons per minute (gpm) in low-density residential areas up to 12,000 gpm in commercial and industrial areas. • High/Special Risk Fire Response: High and Special Fire Risk incidents in the city represent unique critical tasking situations where there is very little historical response information to base tasking upon. These types of incidents are addressed with the region’s mutual aid agreements to help augment City resources. For example, the minimum mutual aid request to meet the demands of a high/special risk fire is an “A Assignment,” (i.e., one truck company (5 personnel), three engine companies (12 personnel), two rescue ambulances (4 personnel), two battalion chiefs (4 personnel), and one EMS Supervisor (1 personnel), requiring a total of 26 personnel to assist with the incident).

4.14.4 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 public services if the project would:

Threshold PS-1: Result in substantial adverse physical impacts associated with the provision of new or physically altered governmental facilities, need for new or physically altered governmental facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives for any of the public services:
i. Fire Protection;
ii. Police Protection;
iii. Schools;
iv. Parks;
v. Other Public Facilities.

Impacts related to parks and recreational facilities are addressed in Section 4.15, Recreation, of this Draft PEIR.

Methodology
As discussed in Chapter 2, Project Description, of this Draft PEIR, this analysis uses a Planning Area population projection of 62,411 for the year 2045 with implementation of the General Plan Update and Zoning Code Update. This population number is derived from a projected 29,710 housing units by the year 2045.

Fire protection needs relate to the size of the population and geographic area served, the number and types of calls for service, and the characteristics of future development. The

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analysis of impacts on fire protection evaluates the Project’s effects on the demand for fire prevention and protection services to determine if implementation of the Project would require additional equipment, personnel, new facilities, or alterations to existing facilities.

Beyond the standards included in the Fire Code and other applicable regulations and plans, consideration is given to the anticipated growth projected to result from implementation of the Project, land uses proposed, fire flow necessary to accommodate the Project, the increase in demand for service created by the Project, and impacts to emergency response times. Based on these factors, a determination is made as to whether CCFD would require the addition of a new or physically altered facility to maintain acceptable service levels, the construction of which could result in a potentially significant environmental impact. The Project would require new facilities if the projected increase in service population would reduce CCFD’s inability to meet their emergency response times goals.

Police protection needs also relate to the size of the population and geographic area served, the number and types of calls for service, and the characteristics of future development. The Project’s police service population takes into consideration nighttime population (residents) and daytime population (employees) and considers the ratio of existing sworn police officers to the 2045 projected service population to determine if the Project would reduce CCPD’s existing officer to service population ratio.

Projected demand for school facilities is based on 2022–2023 student enrollment data from CDE and the increase in housing units and population resulting from implementation of the Project.

The increase in the number of elementary school, middle school, and high school student is projected based on the 2045 population projections under the Project. For example, projected elementary school enrollment was calculated by multiplying the projected 2045 population by the current proportion of the population in elementary school (2022–2023 elementary school enrollment divided by 2023 population). The projected increase in student enrollment for 2045 is then compared to the remaining capacity within the District as of 2023 to determine if there is a need for additional school facilities as a result of the Project.

Project Impact Analysis
Fire Protection
Threshold PS-1.i: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

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Impact Statement PS-1.i: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities as new facilities would be required to comply with existing regulations and Project policies, the concentration of new development would be in areas already well-served by fire protection services, and the Project includes additional policies to reduce fire hazards in the city.

Therefore, the Project would result in a less-than-significant impact related to fire protection facilities.

General Plan Update
Implementation of the General Plan Update would add an estimated 12,700 housing units, 21,612 residents, 3.7 million square feet of nonresidential uses, and 16,804 employees to the city, increasing the demand for fire protection services. While the projected population increase by 2045 would likely increase the demand for fire protection and emergency response services in the Planning Area, the increase in population is anticipated to occur incrementally over the next 25 years. Moreover, the Planning Area is a predominantly urban area that is built out, with limited land available for development. As discussed in Chapter 2, Project Description, and as shown in Figure 2-6, Draft General Plan Land Use Map, the Project’s proposed land use approach would primarily concentrate growth as infill development and maintain existing parks and open space resources. However, as described above, CCFD is not currently meeting their emergency response time goals and has plans to augment their existing staff by seven staff members. Population growth as a result of the General Plan Update would primarily occur within developed areas served by CCFD; however additional staff may be needed to serve future development and the resulting population growth in order to meet their emergency response time goals.

Existing regional and local policies would minimize calls for fire protection services. The Fire Prevention Code of Culver City adopts an amended version of the California Fire Code. As noted in Section 4.14.2, Environmental Setting, the Planning Area is within an LRA, with the eastern portion of the city, including the Blair Hills neighborhood, a portion of the Culver Crest neighborhood, and areas within the IOF, located in a VHFHSZ. Refer to Section 4.19, Wildfire, for a detailed discussion pertaining to the potential impacts of the Project related to wildfire and fire hazards.

Public safety in Culver City, including fire protection and emergency services provided by CCFD, is funded from the City’s general fund. Revenue sources that contribute to the general fund, including property and sales taxes, are anticipated to grow in rough proportion to the increase in residential dwelling units and nonresidential space in Culver City resulting from implementation of the General Plan Update. In addition, the Project promotes compact development patterns through infill development and redevelopment, ensuring new development would be located close to existing fire stations. In general, new development anticipated under the Project would be located in activity centers and along commercial corridors. Furthermore, proposed policies that promote traffic calming, alternative transportation, and road diets contain language to ensure that emergency vehicles could efficiently access all parts of the Planning Area, thereby reducing the need for new facilities located closer to new development.

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As Culver City’s population increases, additional fire stations or expansions may be required. The 2019 Standards of Cover and Community Risk Assessment and the Culver City Fire Department Strategic Plan outline recommendations to increase CCFD performance regarding deployment, response time, data collection, and mutual aid. To augment current emergency services deployment capabilities, CCFD plans to add a third rescue ambulance at Fire Station #2 to assist in instances of concurrent runs and to augment their existing employees by seven additional staff. To address response time deficiencies, CCFD has moved to a new dispatch center, implemented turnout timers in stations, and will publish performance reports to crew members to reduce turnout times. The 2019 Standards of Cover and Community Risk Assessment also recommends continued CCFD use of the heedful audio alert system alerting units to warn other motorists of emergency service vehicles in the area which will reduce overall travel time. CCFD plans to continue to monitor call response times to measure the success of implementing these strategies to achieve response time goals and focus improvement efforts. CCFD also plans to improve data collection methods by improving reporting consistency and including a layer for all fire management zones in the new Mark 43 CAD (computer-aided dispatch). 42,43 If these
planned improvements do not provide appropriate capacity for CCFD to meet their emergency response time goals, CCFD would increase staff as needed to maintain appropriate levels to meet these goals.

Future projects would be reviewed by the City and CCFD on an individual basis and would be required to comply with applicable requirements, such as the installation of automatic fire sprinkler systems and providing adequate emergency site access, in effect at the time building permits are issued. Policies and implementation actions in the proposed General Plan Update are designed to ensure collaboration between the City, CCFD, and other involved agencies. This collaboration would ensure sufficient revenue would be available for necessary service improvements through developer impact fees to provide adequate fire facilities, equipment, and personnel through the horizon year 2045.

While no additional fire stations are currently proposed, the Standards of Cover will be updated by CCFD during implementation of the General Plan Update to identify what new and/or expanded fire stations may be needed to service the Planning Area through the 2045 planning horizon.

The project-specific environmental impacts of constructing new or expanded fire facilities to support the growth anticipated under the Project cannot be determined at this time because the site-specific locations and designs of future new or expanded facilities are not known.

However, it can be expected that construction and operation of future new or expanded fire facilities would have similar impacts as would construction and operation of other types of new development allowed under the General Plan Update. Various localized environmental impacts related to new construction or redevelopment of fire stations could occur, including potential disturbances or conversion of habitat, water pollution during construction, increased noise

42 Culver City Fire Department, 2019b. Community Risk Assessment, Standards of Cover. https://www.culvercity.org/home/showdocument?id=17458. Accessed March 2023. 43 Culver City Fire Department, 2019a. Culver City Fire Department Strategic Plan 2019–2024. https://www.culvercityfd.org/About-the-Department/Documents. Accessed March 2023.

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levels, and an increase in impermeable surfaces. Development and operation of new fire stations may result from implementation of Policy S-7.6 which seeks to strengthen the City’s firefighting capability to respond to multiple fire incidents caused by earthquake, Santa Ana winds, climate change, or other extraordinary circumstances. New facilities would be located consistent with specified land use designations and would be subject to policies in the General Plan Update that serve to avoid or minimize environmental impacts. These policies would address potential impacts of siting, construction, and operation of new facilities to the extent assessed in other sections of this PEIR. Proposed policies include those requiring construction best management practices to limit land disturbance, development review to protect significant biological resources (Goals C-2 and C-3 and associated policies), air pollution mitigation measures, promotion of water- and energy-efficient construction and landscaping, implementation of noise mitigation measures (Policies N-2.1 and N-4.1), and management of archaeological materials found during development. Additionally, new projects, including development of new fire protection facilities would be subject to CEQA requirements, which would allow for the identification and consideration of potential impacts and mitigation, although compliance would not necessarily guarantee that significant impacts would be avoided or mitigated.

Due to the minimal effects that the development of new facilities could have on the environment with compliance with applicable regulations and proposed General Plan policies, the concentration of new development in areas already well-served by fire protection services, and the addition of policies to reduce fire hazards in the city, the impact of the Project with respect to fire protection is considered 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 are implemented in the development that will occur throughout the city over time.

Given that the Zoning Code Update would be consistent with the General Plan 2045, the Zoning Code Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire protection facilities. Furthermore, as the City proceeds with the construction of new or expanded fire protection facilities, those projects would be reviewed by the City for compliance with the policies and actions of the General Plan Update, the City’s Zoning Code Update, and applicable mitigation measures recommended in other sections of this Draft PEIR. Therefore, the Zoning Code Update would not require the construction of new or expanded fire protection facilities and impacts would be less than significant.

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

S-7.1: California Building Code and California Fire Code. Continue to adopt and enforce the most up-to-date California Building Code and California Fire Code, with local amendments as appropriate.

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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-7.6: Firefighting capability. Strengthen City firefighting capability to respond to multiple fire incidents caused by an earthquake, Santa Ana winds, climate change, or other extraordinary circumstances.

S-7.7: Building Code and Fire Code provisions. Enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions. Require additional standards for high-risk, high occupancy, dependent, and essential facilities where appropriate. This shall include assurance that structural and nonstructural architectural elements of the building are designed not to:
• Impede emergency egress for fire safety personnel, equipment, and apparatuses; and • Hinder evacuation from fire, including potential blockage of stairways or fire doors.

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.

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

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

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

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.

N-4.1: Limit disturbance from new construction. Minimize construction noise and vibration impacts to reduce the disturbance from new development.t 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 fire protection facilities.

Police Protection
Threshold PS-1.ii: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require the provision of new or physically altered police protection facilities, the construction of which could cause significant environmental impacts, in order to maintain acceptable service ratios, response times or other performance objectives.

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Impact Statement PS-1.ii: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered police protection facilities as new facilities would be required to comply with existing regulations and Project policies, the concentration of new development would be in areas already well-served by police protection services, and the Project includes additional policies to address crime potential in the city.

Therefore, the Project would result in a less-than-significant impact related to police protection facilities.

General Plan Update
Implementation of the General Plan Update would add an estimated 12,700 housing units, 21,612 residents, 3.7 million square feet of nonresidential uses, and 16,804 employees to the city, increasing the demand for police protection services. The projected increase in population and employment in the city would add to the number of service calls received and to the number of patrols and staff from CCPD and LASD necessary to service the Planning Area. Future growth in accordance with the General Plan Update is expected to create the typical range of calls for police service. To serve future growth, new and/or additional police resources would be needed to maintain the established service ratios. The anticipated growth that would result from the Project would likely increase the number of police responses in the city, which would increase the need for equipment and personnel. Therefore, the City’s costs to maintain facilities and equipment as well as train and equip police personnel would also increase. In addition, the redistribution and increase of the population and traffic density into areas proposed for growth, such as commercial corridors and activity centers, could necessitate the reassignment of certain resources pertaining to police services. The costs of additional personnel and materials are anticipated to be offset through the increased revenues and fees generated by future development. In addition, future projects would be reviewed by the City on an individual basis and would need to comply with any impact fee requirements in effect when the review is conducted and necessary permits are issued.

To maintain the existing sworn officers ratios to population based on daytime population (residents + employees) and nighttime population (residents)—1 :2,752 and 1:367, respectively— implementation of the General Plan Update would require hiring a minimum of 58 new officers for the nighttime ratio and 18 new officers for the daytime ratio. 44 The increase in
population is anticipated to occur incrementally over the next 25 years. Therefore, impacts to police services are anticipated to be adequately funded by an increase in tax revenues over an extended period of time, relative to the increase in development intensity. Although there is no direct fiscal mechanism ensuring that funding for police services from the general fund will grow exactly proportional to the increased need for services, development over time would increase contributions to the general fund through tax revenues and are expected to grow in rough proportion to any increase in residential dwelling units and/or nonresidential floor area in Culver City.

Additional police personnel and resources would be provided through the annual budget and CCPD review process. Annually, CCPD needs would be assessed and budget allocations revised

44 Daytime population projection for 2045 is calculated by 300,000 existing + 21,612 new residents + 28,100 new jobs (employees) for 349,712. Nighttime population for 2045 is 62,411 residents.

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accordingly to ensure that adequate levels of service are maintained throughout the city.

Additional resources and personnel funded by an increase in tax revenue would maintain the level of service needed to support the increase in growth. In addition, LASD services would not be affected by implementation of the General Plan Update as proposed land use designations within the City’s SOI would be “Open Space” and “Cemetery,” which would not result in additional residential or employment growth and thus, would not require additional police personnel or resources.

As discussed above, to maintain the existing ratio of sworn officers and civilian employees per capita, implementation of the General Plan Update would require hiring a minimum of 58 new officers. Given this level of staff increase and the fact that CCPD only has one existing police station, new facilities may be necessary at some point in the future to accommodate the projected increase is staff needed to maintain the service ratios. Such facilities would occur where allowed under the designated Institutional land use. In addition, the costs of additional police personnel and materials are anticipated to be offset through the increased revenues and fees, including property and sales taxes, generated by future residential and nonresidential development allowed under the General Plan Update.

The project-specific environmental impacts of constructing new or expanded other police facilities to support the growth anticipated under the Project cannot be determined at this time because the site-specific locations and designs of future new or expanded facilities are not known. However, it can be expected that construction and operation of future new or expanded police facilities would have similar impacts as would construction and operation of other types of new development allowed under the General Plan Update. The construction of new police facilities or alterations to existing police facilities in order to provide sufficient capacity could have environmental impacts, including potential disturbances or conversion of habitat, water pollution during construction, increased noise levels, and an increase in impermeable surfaces.

New facilities would be located consistent with specified land use designations and would be subject to policies in the General Plan Update. These policies would address potential impacts of siting, construction, and operation of new facilities to the extent assessed in other sections of this PEIR. Proposed policies include those requiring construction best management practices to limit land disturbance, development review to protect significant biological resources, air pollution mitigation measures, promotion of water- and energy-efficient construction and landscaping, implementation of noise mitigation measures, and management of archaeological materials found during development. Additionally, new projects, including development of new police protection facilities would be subject to CEQA requirements, which would allow for the identification and consideration of potential impacts and mitigation, although compliance would not necessarily guarantee that significant impacts would be avoided or mitigated.

Due to the minimal effects that the development of new facilities could have on the environment with compliance with existing regulations and proposed General Plan policies, impacts on police services related to implementation of the General Plan 2045 would be less than significant.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-33 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 are implemented in the development that will occur throughout the city over time.

Applicable Proposed General Plan Goals and Policies
There are no proposed General Plan goals or policies related to police services.

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 police protection facilities.

Schools
Threshold PS-1.iii: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require the provision of new or physically altered schools, or the need for new or physically altered schools , the construction of which could cause significant environmental impacts, in order to maintain sufficient capacity.

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

General Plan Update
The General Plan Update anticipates the construction of up to 10,996 new potential housing units and up to 62,411 residents in the Planning Area by 2045. Based on a 2023 population of 39,682 residents45 and 3,074 elementary school students and 3,738 middle and high school students (Table 4.14-5), the Project projects a 2045 enrollment of approximately 4,834

45 California Department of Finance, 2023. E-5 Population and Housing Estimates for Cities, Counties and the State — January 1, 2021–2023. https://dof.ca.gov/forecasting/demographics/estimates/e-5-population-and-housing- estimates-for-cities-counties-and-the-state-2020-2023/. Accessed May 2023.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-34 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
elementary school students46 and 5,950 middle and high school students.47 This would result in a growth in Culver City enrollment by approximately 1,761 elementary school students and 2,212 middle and high school students by 2045 in Culver City public school enrollment. No new school facilities are included in the Project. Based off the elementary school capacity of 3,188 students and middle and high school practical capacity of 3,927 students shown in Table 4.14-5, projected enrollment in 2045 would be over the elementary and middle and high school capacities by 1,646 students and 2,023 students, respectively.

The Project contains policies related to schools, including continued coordination with the CCUSD to inform the District on impacts of major developments and population growth trends that may impact school enrollment. Furthermore, CCUSD is currently in the process of preparing the Future-Ready Facilities Plan, which is an update to the current 2014 Facilities Master Plan that would provide the current status and future use of school facilities as well as possible renovations, additions and related construction to remedy deficiencies as well as support teaching and learning priorities.
48 The project-specific environmental impacts of constructing new or expanded other public facilities to support the growth anticipated under the Project cannot be determined at this time because the site-specific locations and designs of future new or expanded facilities are not known. However, it can be expected that construction and operation of future new or expanded schools would have similar impacts as would construction and operation of other types of new development allowed under the General Plan Update. The construction of new schools or alterations to existing schools in order to provide sufficient capacity could have environmental impacts, including potential disturbances or conversion of habitat, water pollution during construction, increased noise levels, and an increase in impermeable surfaces. The siting of new schools is regulated by CDE. The California Education Code contains various provisions governing the siting of new public schools that require school districts to consider potential hazards to school occupants as well as other factors relevant to the public interest prior to the acquisition of a proposed school site. Although in many cases the avoidance or mitigation of hazards to school occupants would reduce impacts to the surrounding environment, the provisions of the California Education Code would not eliminate the potential for all construction-based or operational impacts of a new school.

As described above, the growth anticipated by the Project would likely result in the need for new or expanded public school facilities due to anticipated population growth and anticipated school capacity. CCUSD would continue to collect development impact fees throughout implementation of the Project, meaning future development would incrementally pay for any needed facility upgrades and expansions. The payment of statutory fees fully mitigates the

46 Number of projected 2045 elementary students calculated by taking the existing proportion of elementary school students in Culver City and multiplying that factor by the projected number of residents in 2045. (3,074/39,682) x 62,411 = 4,835 elementary students.
47 Number of projected 2045 middle and high school students calculated by taking the existing proportion of middle and high school students in Culver City and multiplying that factor by the projected number of residents in 2045. (3,738/39,682) x 62,411 = 5,950 middle and high school students. 48 Culver City Unified School District, 2023b. Frequently Asked Questions. https://www.ccusdfutureready.org/faq.

Accessed April 2023.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.14-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
impacts of development on school facilities for purposes of CEQA per SB 50. In addition, as estimated housing growth and student generation under the General Plan 2045 are based on realistic development capacity of proposed land uses designations in the city, a student population that exceeds these estimates is unlikely. Impacts of the Project related to student generation and the potential need for additional school facilities 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 are implemented is the development that will occur throughout the city over time.

Given that the Zoning Code Update would be consistent with the General Plan 2045, the Zoning Code Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered schools. Therefore, the Zoning Code Update would not result in significant adverse effects related to school facilities. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Parks, Recreation, and Public Facilities Element
Goal PR-8: Educational opportunities. Students have access to exceptional educational opportunities at institutions in Culver City and through partnerships cultivated by the City.

PR-8.1: Partnerships with CCUSD. Formalize partnerships with the CCUSD to apprise the District on major development and population trends that may impact student enrollment and share data.

PR-8.2: Sitting of school facilities. Work closely with educational institutions to site new schools and facilities near parks, bike paths, and trails.

PR-8.3: Opportunities for students. Collaborate with CCUSD and higher educational institutions in the city to develop internships, job shadowing, capstones, and other opportunities targeted to students.

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 school facilities.

Other Public Facilities
Threshold PS-1.v: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require the provision of other public facilities, the construction of which could cause significant environmental impacts, in order to maintain sufficient capacity.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.14-36 SCH No. 2022030144 City of Culver City March 2024
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Impact Statement PS-1.v: The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities as new or expanded facilities would be required to comply with existing regulations and Project policies.

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

General Plan Update
Implementation of the General Plan Update would add an estimated 12,700 housing units, 21,600 residents, 3.7 million square feet of nonresidential uses, and 16,260 employees to the city. Development and growth in the city would increase demand for other public facilities. As demand for other public facilities increases as a result of implementation of the Project, there may be a need to increase staffing and facilities (i.e., libraries) to maintain acceptable service ratios and other performance objectives. If an existing public facility is at capacity for staffing, this could require an expansion of an existing public facility or construction of a new public facility, the construction of which could cause environmental impacts.

The project-specific environmental impacts of constructing new or expanded other public facilities to support the growth anticipated under the Project cannot be determined at this time because the site-specific locations and designs of future new or expanded facilities are not known. However, public facilities are allowed within the “Institutional” land use designation as shown on Figure 2-6, Draft General Plan Land Use Map, in Chapter 2, Project Description. As shown in Table 2-4, General Plan 2045 Projections by Land Use, in Chapter 2, Project Description, there would be no increase in the amount of land designated for institutional uses. As such, the City would maintain its existing 3,076,600 square feet of institutional uses. However, there is still expectation for population growth resulting from implementation of the General Plan Update, which could result in the expansion of existing public facilities or construction of new public facilities within the “Institutional” land use designations. It can be expected that construction and operation of future new or expanded public facilities would have similar impacts as would construction and operation of other types of new development allowed under the General Plan Update. As the City proceeds with the construction of new or expanded public facilities, those projects would be reviewed by the City for compliance with the policies and actions of the General Plan Update and the mitigation measures recommended in other sections of this Draft PEIR. Therefore, the physical effects on the environment from the construction of new or expanded other public facilities would be less than significant, and future development allowed under the General Plan Update would not result in significant adverse effects related to other public facilities. Impacts would be less than significant.

Due to the minimal effects that the development of new facilities would have on the environment with compliance with existing regulations and proposed General Plan policies, the impact of the Project with respect to public facilities is considered less than significant.

4. Environmental Impact Analysis

4.14 Public Services
General Plan 2045 and Zoning Code Update Project 4.14-37 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Update, the Zoning Code Update would not result in substantial adverse physical impacts associated with the provision of new or physically altered public facilities. Therefore, future development under the Project would not result in significant adverse effects related to public facilities, and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Parks, Recreation, and Public Facilities Element
Goal PR-7: Public facilities. Public facilities in Culver City, including libraries and City-owned facilities, offer high-quality services to the community.

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

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

PR-7.3: Programming on City-owned facilities. Continue to program events, update landscapes, and incorporate art on City-owned public facilities, including City Hall, to create more welcoming, activated, attractive, and unique places.

PR-7.4: Partnerships with the Los Angeles County Public Library. Establish and maintain partnerships with the Los Angeles County Public Library and collaborate to provide targeted programming and outreach to students in need of tutoring, mentoring, after- school programming and other support outside of the classroom.

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 other public facilities.

4.14.5 Cumulative Impacts Analysis
Fire Protection
CCFD maintains mutual aid agreements with the City of Los Angeles, Los Angeles County, and Cities of Beverly Hills, Santa Monica, and West Hollywood. The geographic context for the cumulative analysis of fire protection is the service area of CCFD and LACFD, which includes Culver City and incorporated and unincorporated areas of Los Angeles County. A significant cumulative environmental impact would result if future growth in the county consistent the general plans and zoning codes of local jurisdictions in the area, in combination with the growth anticipated as a result of the Project would exceed the ability of CCFD and LACFD to adequately meet its commitments, thus requiring construction of new facilities or modification of existing facilities. The Project and general plan updates or other development in areas served by CCFD,

4. Environmental Impact Analysis

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including those with mutual aid agreements, would increase the population of the service area, thereby increasing the need to provide staff, equipment, and facilities to maintain acceptable emergency response times and other indicators of fire protection services. Revenue sources that contribute to the Cities’ and the County’s general funds, including property and sales taxes, would be expected to grow in rough proportion to the increase in residential dwelling units and nonresidential space in areas served by CCFD resulting from implementation of general plan updates or other development. In addition, the Project promotes compact development patterns with infill development, thus ensuring that new development would be located close to existing fire stations. Furthermore, CCFD has established mutual aid agreements with both the City of Los Angeles and Los Angeles County to increase response levels of service to residents of the city as well as surrounding areas, if aid were needed. Therefore, the contribution of the Project to this impact would not be cumulatively considerable.

Police Protection
The geographic context for the cumulative analysis of police service is the service area of CCPD and LASD, which includes Culver City and incorporated and unincorporated areas of Los Angeles County. A significant cumulative environmental impact would result if future growth in the county would exceed the ability of CCPD and LASD to adequately meet its commitments, thus requiring construction of new facilities or modification of existing facilities. As the CCPD does not provide police protection services outside of the City boundary, development and growth associated with other nearby jurisdictions would not result in cumulative impact on CCPD resources and their service commitments. The costs of additional police personnel and materials are anticipated to be offset through the increased revenues and fees, including property and sales taxes, generated by future residential and nonresidential development allowed under general plan updates or other development. The Project also promotes compact development patterns with infill development, thus ensuring that new development would be located close to existing police stations. LASD services would not be affected by implementation of the Project as proposed land use designations within the City’s SOI would be “Open Space” and “Cemetery,” which would not result in additional residential or employment growth and thus, would not require additional police personnel or resources. As a result, the contribution of the Project to this impact would not be cumulatively considerable.

Schools
The geographic context for the cumulative analysis of schools is the boundaries of CCUSD. A significant cumulative environmental impact would result if future growth within the district would exceed the ability of the district to adequately meet the needs of its students, thus requiring construction of new facilities or modification of existing facilities. As discussed under Impact PS-1.iii, CCUSD would continue to collect development impact fees throughout implementation of the Project, meaning future development would incrementally pay for any needed facility upgrades and expansions that would ensure that there is sufficient capacity to accommodate future public-school students. The payment of statutory fees fully mitigates the impacts of development on school facilities for purposes of CEQA per SB 50. For this reason, the contribution of the Project to this impact would not be cumulatively considerable and cumulative impacts related to schools would be less than significant.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.14-39 SCH No. 2022030144 City of Culver City March 2024
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Other Public Facilities
The geographic context for the cumulative analysis of other public facilities, such as libraries, is the service area of the Los Angeles County Library system, which includes both incorporated and unincorporated areas of Los Angeles County. A significant cumulative environmental impact would result if future growth in the county would exceed the ability of the library system to adequately serve its patrons, thus requiring construction of new facilities or modification of existing facilities. Population growth anticipated under the Project may result in the need for new public facilities such as libraries, and new facilities would be subject to environmental review under CEQA, proposed General Plan land use designations, and proposed General Plan policies related to construction impacts. For this reason, the contribution of the Project to this impact would not be cumulatively considerable. The Project would result in less-than-significant cumulative impacts related to other public facilities.

4. Environmental Impact Analysis

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.15-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.15 Recreation

4.15.1 Introduction
This section provides an analysis of the potential environmental impacts on recreation from future development allowed under the Project, including potential impacts related to deterioration of existing recreational facilities and construction or expansion of recreational facilities. The section provides context regarding the Planning Area’s existing parks and recreational facilities, as well as relevant federal, State, and local regulations and programs.

4.15.2 Environmental Setting
Parks and Recreational Facilities
Culver City benefits from a diverse array of parks, open spaces, joint use facilities, and other outdoor open spaces that residents, employees, and visitors can visit within or near city limits.

Park Classifications
The City uses a classification system to divide parks and open spaces into eight types: regional parks, community parks, neighborhood parks, parkettes/mini parks, linear parks, special use areas, natural open space, and undeveloped land. These types vary in size, function, and amenities offered to residents, employees, and visitors of Culver City (see Table 4.15-1, Park and Open Space Classifications).

City Parks
The City owns and operates two community parks, seven neighborhood parks, and five parkettes/mini parks within city limits that the City’s Parks, Recreation and Community Services (PRCS) Department maintains and operates. Parks are listed in Table 4.15-2, Parks in the Planning Area, and depicted in Figure 4.15-1, Existing Parks and Recreational Facilities in the Planning Area. In total, the City owns and maintains approximately 85 park acres, excluding the Stoneview Nature Center, a facility owned and operated by Los Angeles County within city limits.

Other Outdoor Recreational Spaces
In addition to the parks that Culver City owns and maintains, Culver City residents, employees, and visitors can easily access other outdoor recreational spaces in the community, such as public plazas. In addition, there are some spaces outside the city’s boundaries, but within a walkable distance (one half-mile) of Culver City residents and workers. In total, these spaces comprise approximately 700 acres (193 within the city limits and 506 within a half mile of the city limits) and include the following:
• Public plazas owned by Culver City. The City owns and operates two public plazas that provide limited passive use. These plazas are Heritage Park in front of City Hall and the Town Plaza.

4. Environmental Impact Analysis

4.15 Recreation
General Plan 2045 and Zoning Code Update Project 4.15-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.15-1

PARK AND OPEN SPACE CLASSIFICATIONS
Type Description
Regional Parks Large recreation areas designed to serve the entire region beyond city limits. The City does not own any regional parks.

Community Parks Usually between 15 and 40 acres, community parks are designed to serve people within a 2- to 3-mile radius. They provide for a variety of passive and active uses.* Community parks may include sports fields (lit or unlit), basketball courts, restrooms, indoor facilities, picnic areas, and specialized facilities (such as dog parks and skateparks).

Neighborhood Parks Neighborhood parks are intended to serve neighborhood residents within a mile of the park and are usually between 3 and 15 acres. Neighborhood parks may have playgrounds, picnic areas, trails, open grass areas for passive use, outdoor basketball courts, and multi-use open grass areas for sports.

Parkettes/Mini Parks Less than 3 acre s, parkettes/mini parks are typically designed for use by small children or as green oases in the middle of an urban context. Parkettes/mini parks may have open grass areas, playgrounds, and a small picnic area.

Linear Parks Linear parks are developed landscaped areas and other lands that follow linear corridors such as rivers, creeks, abandoned railroad rights-of-way, canals, powerlines, and other elongated features. This type of park usually contains trails, landscaped areas, viewpoints, and seating areas.

Special Use Areas Special use areas are sites often occupied by a specialized recreation facility. Some uses that fall into this category include waterfront parks, boat ramps, botanical gardens, community gardens, single purpose sites used for a particular field sport, or sites occupied by recreation buildings.

Natural Open Space Natural open space is defined as undeveloped land primarily left in its natural form with recreation uses as a secondary objective. It is usually owned or managed by a governmental agency and may or may not have public access. This type of land may include wetlands, steep hillsides, or other similar spaces. In some cases, environmentally sensitive areas are considered open space and can include wildlife habitats, stream and creek corridors, or unique and/or endangered plant species.

Undeveloped Land This land is undeveloped and has not yet been designated for a specific park use. * The term “passive use” refers to recreational activities that do not require specialized park equipment and management, such as walking, biking, and picnicking. “Active uses” require the use of special facilities, courses, fields, or equipment. Examples of active uses include playing basketball, swimming, and using playground equipment.

SOURCE: Culver City, 2023. Parks, Recreation, and Public Facilities Element.

• Parks owned by other agencies. This includes parks owned by the State of California and the City of Los Angeles. The State of California’s Baldwin Hills Conservancy owns and operates the Baldwin Hills Scenic Overlook, which is within city limits. To the east of the city limits, the State owns and operates the Kenneth Hahn State Recreation Area. The City of Los Angeles owns and operates five parks within one half-mile of city limits. The City has a long- term lease with the City of Los Angeles to use Media Park. • Joint Use Facilities. The City has a joint use agreement with the Culver City Unified School District (CCUSD) that allows CCUSD to use City recreational facilities in exchange for use of school buildings and fields. The City does not have a formalized joint use agreement with West Los Angeles College, but the City rents space to West Los Angeles College as needed. • Privately Owned Public Open Spaces. Some private developers in the city operate privately owned public open spaces (POPOs) as conditions of development approval. These areas allow for passive uses like walking and sitting. This includes spaces like the Platform, Culver Steps, and the event lawn and town square at Ivy Station.

4. Environmental Impact Analysis

4.15 Recreation
General Plan 2045 and Zoning Code Update Project 4.15-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.15-2

PARKS IN THE PLANNING AREA
Facility Amenities Acres
Community Parks 50.2
Culver City Park Play area, basketball half courts, baseball fields (including Bill Botts Field), open turf area, restroom, picnic area, skatepark, playground, trails, the Boneyard Dog Park

34.1 Veterans Park Basketball courts (one with lights), tennis courts (with lights), softball fields (one with lights), open turf areas, handball walls, restroom, picnic shelter, playground, Veterans Memorial Building, aquatic center, teen center, community gardens, paddle tennis courts (with lights)

16.1 Neighborhood Parks 32.4
Blair Hills Park Playground, basketball court, softball field, restroom, picnic shelter 1.8 Blanco Park Tee-ball diamonds, recreation building, picnic shelter, open turf areas, walking path

3.1 Carlson Park Open turf area, restroom, picnic shelter, sculpture, night lighting 2.5 Culver West Alexander Park Playground, basketball court (with lights), tennis court (with lights), paddle tennis courts (with lights), handball courts (with lights), passive use area with mounds and shade trees, recreation building, picnic areas

3.1 El Marino Park Playground, basketball court (with lights), handball wall, open turf area, restroom, recreation building, picnic area, ceramics hut

1.6 Fox Hills Park Playground, basketball half courts (with lights), tennis courts (with lights), paddle tennis courts (with lights), volleyball court (with lights), softball fields, open turf areas, restroom, picnic area, fitness equipment, loop trail

10.0 Lindberg Park Playground, basketball court, softball fields (with partial lights), soccer field, handball wall, open turf areas, restroom, recreation building, picnic shelters

4.2 Syd Kronenthal Park Play area, basketball court (with lights), tennis court (with lights), paddle tennis courts (with lights), softball fields (with lights), recreation building, picnic shelters, fitness equipment, trail loop

6.1 Parkette/Mini Parks 2.8
Coombs Parkette No amenities, open turf area 0.5
Fox Hills Parkette Benches 0.8
Tellefson Park Playground, open turf areas, restroom, picnic shelter 1.5 Special Use Area 5.0
Stoneview Nature Centera Fitness zones, hiking trails, nature centers 5.0 Total Acres 90.4
a Stoneview Nature Center is within Culver City limits but is operated by Los Angeles County.

SOURCES: Culver City, 2009. Parks and Recreation Master Plan. https://www.culvercity.org/files/assets/public/documents/building- development/city-documents/1_2009_parksandrecreationm.pdf. Culver City, 2023. Parks, Recreation, and Public Facilities Element.

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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

4.15 Recreation
General Plan 2045 and Zoning Code Update Project 4.15-5 SCH No. 2022030144 City of Culver City March 2024
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Park Service
The City maintains park service standards for city parks, regional parks, and joint use facilities to evaluate park service. The park service ratio, or ratio of number of acres of parks per 1,000 residents, is a metric the City uses to measure park service and calculate park dedication requirements for new development. A higher service ratio indicates more acres of park per 1,000 residents.

The City’s current park service standard, established in the 1968 General Plan, aimed to provide 10 acres of park space per 1,000 residents. One acre per 1,000 residents may be satisfied with joint use agreements with the CCUSD and 6 acres per 1,000 residents may be satisfied by regional parks, leaving at least 3 acres per 1,000 residents to be satisfied by City-owned parks.

As shown in Table 4.15-3, Current Park Service, the city is not currently meeting its park service standard. Based on a projected population of 62,400 in 2045, the city would need an additional 264 park acres to achieve its service standard.

TABLE 4.15-3

CURRENT PARK SERVICE
Park Type
Standard (in acres
per 1,000 residents) Current Park Acres Current Service Ratioa Culver City Parks 3.0 90.4 2.2
Joint use facilities 1.0 30.0b 0.7
Regional parks 6.0 240.0b 6.0
Total 10.0 360.4 8.9
NOTES:
a Based on a 2019 population of 40,200.
b Acreage totals based on 2009 Parks and Recreation Master Plan. Regional park acreage includes the Kenneth Hahn Regional Park, which is outside city limits and not operated by Culver City.

SOURCES: Culver City, 2023. Parks, Recreation, and Public Facilities Element.

Culver City has a lower than average park service ratio compared to the rest of Los Angeles County, as the parks service ratio (based on City parks alone) averages 2.2 in Culver City and 3.3 countywide.1 However, the countywide ratio is inclusive of cities in more suburban settings, where there is generally more open space and greenery. For instance, compared to more suburban cities like Calabasas, Claremont, and Rolling Hills Estates, Culver City has a lower parks service ratio.2 However, the City has a greater parks service ratio than cities that are similarly situated in the urban core of the Los Angeles region, including Inglewood, Redondo Beach, and Santa Monica, indicating a stronger level of park service than comparable cities.

1 Los Angeles County Department of Parks and Recreation. 2016. Los Angeles Countywide Comprehensive Parks & Recreation Needs Assessment Appendix A: Study Area Profiles. https://lacountyparkneeds.org/final-report/.

Accessed March 2023.
2 Culver City. 2020. Parks, Public Facilities, and Public Services Existing Conditions Report, p. 8. https://www.pictureculvercity.com/resources. Accessed March 2023.

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Park Access
The City’s park service ratio provides an understanding of population relative to park acreage, and therefore provides a measure of the availability of park space to serve residents. However, this ratio alone is not sufficient to determine the quality of park service in Culver City. The park service ratio, for instance, does not consider park amenities that improve park usability, like illuminated space, which makes parks usable for more hours of the day, or active and passive space, which allow for a greater variety of uses and programming. Another important factor to consider is accessibility to parks and other public outdoor recreational spaces, or the quality of the pedestrian environment leading to and from a green space. Residents and workers are more likely to visit parks and outdoor recreational spaces if they live within a ten-minute, or one half- mile, walking distance of a park. Living within a walkable distance of a park or outdoor recreational space can benefit residents, as physical activity is linked to stress reduction, improved mental health, and respiratory fitness.

As shown in Figure 4.15-2, Public Access to Existing Parks, approximately 90 percent of Culver City residences are within a one half-mile walking distance of a park, trail, or open space, including facilities just outside city limits.

Recreational Facilities
The City owns and operates a range of recreational facilities available for classes, sports, performances, social events, camps, and more. These include the Municipal Plunge; recreational buildings at Blanco Park, Culver West Alexander Park, El Marino Park, Lindberg Park, and Syd Kronenthal Park; Veterans Memorial Building, the Culver City Teen Center, and the Culver City Senior Center. These facilities are also shown in Figure 4.15-1.

Municipal Plunge. The Culver City Municipal Plunge is a public swimming pool operated by the City. The City’s mission is to “… provide comprehensive aquatics programming that meets the needs of the community through highly accessible, enjoyable and varied opportunities for learning and recreation. We strive to offer a safe, responsive and welcoming aquatics environment that promotes the health and well-being of our City's residents.” 3 The City allows
CCUSD to use the Municipal Plunge via a joint use agreement.

Recreation Buildings. Blanco, Culver West Alexander, El Marino, Lindberg, and Syd Kronenthal Parks have recreation buildings with rentable meeting rooms. Most buildings are used for contract classes and afterschool and preschool programs.

Veterans Memorial Complex. Veterans Memorial Complex is a community facility located at Veterans Memorial Park, a 16.1-acre community park that occupies a full block. The Complex includes Veteran's Memorial Building and the Teen and Senior Centers. All facilities in the complex are available for rentals and regularly accommodate concerts and other performances, workshops and conferences, film and television shoots, private parties, community meetings, indoor sport activities, trade shows and exhibitions, as well as other events.

3 Culver City. 2023a. Culver City Pool. https://www.culvercity.org/Explore/Parks-Recreation/Culver-City-Pool.

Accessed July 28, 2023.

Culver City General Plan 2045
Figure 4.15-2
Public Access to Existing Parks
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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Veterans Memorial Building (VMB). Built in 1951, VMB is a Culver City Historical Society designated historic building located at 4117 Overland Avenue and is approximately 11,259 square feet in size.4 VMB houses Veterans Memorial Auditorium and the Culver City Historical Society.

Culver City Teen Center. Built in 1956, the Teen Center is located at 4153 Overland Avenue and is approximately 10,897 square feet in size.5 The facility is one story and available for rentals with a capacity of 100+. Amenities include audio/visual equipment, chairs, tables, risers, podiums, and Wi-Fi.6
Culver City Senior Center. Built in 2003, the Senior Center is located at 4095 Overland Avenue and is approximately 27,237 square feet in size.7 The Senior and Social Services Division, a multi- service agency housed at the Culver City Senior Center, provides a variety of educational, recreational and social services that meet the needs and interests of seniors, residents with disabilities and members of the general community. The numerous programs and services offered provide access to information and support as well as opportunities for participation in activities that lead to personal growth and enrichment. 8 Trails
The City manages a trail network that mostly consists of trails within existing parks. Several park facilities, including Culver City, Fox Hills, and Syd Kronenthal Parks have self-contained loop trails. Culver City's existing trail network has limited connectivity. In addition, a trail runs along a median in Culver Boulevard, connecting residents south to Del Rey. Culver City residents also have access to trails at regional parks, including the Culver City Stairs leading up to a scenic overlook at the Baldwin Hills Recreational Area.

The biggest opportunity for trail improvement in Culver City is the City’s Ballona Creek Revitalization Project, which has potential to improve water quality, better connect residents to Ballona Creek, provide recreational, aesthetic, and ecological benefits. Currently, a multi-use bicycle and pedestrian path follows the north side of the Creek through almost the entire stretch through the city, ending at Syd Kronenthal Park at the northeast end of the path. The path connects to the Park to Playa Trail, managed by the City of Los Angeles, a 13-mile trail linking parks, trails, and open spaces from Baldwin Hills to the Pacific Ocean. Implementing the

4 Culver City Historical Society, 2011. Historic Site #13 - Veterans Memorial Building. https://www.culvercityhistoricalsociety.org/historic-sites/veterans-memorial-building/. Accessed July 2023. 5 Culver City, 2016. Americans with Disabilities Act (ADA) Self Evaluation and Transition Plan, PS0061 RFP Number 1590, Addendum No. 1. https://www.culvercity.org/home/showdocument?id=2339. Accessed on October 23, 2019.
6 Culver City. 2023d. Teen Center. https://www.culvercity.org/Explore/Parks-Recreation/Teen-Center. Accessed March 2023.
7 Culver City, 2016. Americans with Disabilities Act (ADA) Self Evaluation and Transition Plan, PS0061 RFP Number 1590, Addendum No. 1. https://www.culvercity.org/home/showdocument?id=2339. Accessed on October 23, 2019.
8 Culver City. 2023b. Culver City Senior Center. https://www.culvercity.org/City-Hall/Jobs/Culver-City-Senior- Center. Accessed March 2023.

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Ballona Creek Revitalization Project will better connect neighborhoods to Ballona Creek and extend the existing multi-use path in Ballona Creek’s future development.

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

There are no federal regulations regarding recreation that apply to the Project.

State
Quimby Act
California Government Code Section 66477, Subdivision Map Act, referred to as the Quimby Act, authorized cities and counties to pass ordinances requiring that developers set aside land, donate conservation easements, or pay park fees (often referred to as in-lieu fees) for park improvements. Under the Quimby Act, fees must be paid or land must be conveyed directly to the local public agencies that provide park and recreation services on a communitywide level; however, revenues generated through the Quimby Act cannot be used for the operation and maintenance of park facilities. The act states that the dedication requirement of parkland can be a minimum of 3 acres per 1,000 residents or equal to the existing parkland provision (up to 5 acres per 1,000 residents) if the existing ratio is greater than the minimum standard. The Quimby Act allows cities to require a higher dedication if the need can be demonstrated.

Public Park Preservation Act
The primary instrument for protecting and preserving parkland is California’s Public Park Preservation Act of 1971, California Public Resources Code Sections 5400 through 5409 (the Act). Under the Public Park Preservation Act, cities and counties may not acquire any real property that is in use as a public park for any non-park use unless compensation, land, or both are provided to replace the parkland acquired. The Public Park Preservation Act only applies when a public agency both acquires real property that is in use as a public park and the public agency uses the property for non-park purposes.

Regional
Proposition A Funds
Proposition A Funds may be used to fund the development, acquisition, improvement, restoration and maintenance of parks; recreational, cultural and community facilities; and open space lands. These funds are administered by the Los Angeles County Regional Park and Open Space District. The Open Space District was created when voters approved Proposition A in 1992. Proposition A authorized an annual assessment on nearly all of the 2.25 million parcels of real property in the county. Proposition A funded $540 million for the acquisition, restoration or rehabilitation of real property for parks and park safety, senior recreation facilities, gang prevention, beaches, recreation, community or cultural facilities, trails, wildlife habitats, or natural lands, and maintenance and servicing of those projects. In 1996, voters approved another Proposition A to fund an additional $319 million for parks and recreation projects and additional funds for maintenance and to service those projects.

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Landscaping and Lighting Districts
The California Landscaping and Lighting Act of 1972 authorizes local legislative bodies to establish benefit related assessment districts, or Landscaping and Lighting Districts (LLADs), and to levy assessments for the construction, installation, and maintenance of certain public landscaping and lighting improvements. LLADs may be established to maintain local public parks.

Mello-Roos District
A developer may apply to the County to form a Mello-Roos District pursuant to the California Mello-Roos Community Facilities Act of 1982 to develop and maintain park improvements.

Pursuant to County guidelines, the parks should be regional in nature, and have an impact or benefit beyond the associated subdivision.

Los Angeles County General Plan
The Los Angeles County General Plan applies to the unincorporated County land in the Planning Area. Chapters 10 and 13 address parks and recreation facilities. Policies identified in the Parks and Recreation Element of the Los Angeles County General Plan include parkland classifications, parkland dedication requirements, funding mechanisms for the planning and development of recreational facilities, and issuance of development fees. 9,10 The following are applicable policies:

P/R 1.5: Ensure that County parks and recreational facilities are clean, safe, inviting, usable, and accessible.

P/R 1.7: Ensure adequate staffing, funding, and other resources to maintain satisfactory service levels at all County parks and recreational facilities.

P/R 2.2: Establish new revenue generating mechanisms to leverage County resources to enhance existing recreational facilities and programs.

P/R 3.1: Acquire and develop local and regional parkland to meet the following County goals: 4 acres of parkland per 1,000 residents in the unincorporated areas and 6 acres of regional parkland per 1,000 residents of the total population of Los Angeles County.

P/R 6.4: Ensure that new buildings on County Park properties are environmentally sustainable by reducing carbon footprints, and conserving water and energy.

Los Angeles Code of Ordinances
The Los Angeles County ordinance applies to the unincorporated County land in the Planning Area and contains provisions pertaining to park dedication. Title 21 – Subdivisions of the Los Angeles County General Plan contains guidance and requirements pertaining to the dedication of private and public park sites and identifies when park fees are required.

9 Los Angeles County, 2015a. Los Angeles County General Plan Chapter 10: Parks and Recreation Element. http://planning.lacounty.gov/assets/upl/project/gp_final-general-plan-ch10.pdf. Accessed March 2023. 10 Los Angeles County, 2015b. Los Angeles County General Plan Chapter 13: Public Services and Facilities Element. http://planning.lacounty.gov/assets/upl/project/gp_final-general-plan-ch13.pdf. Accessed March 2023.

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Local
Culver City Municipal Code
Chapter 15.10, Subdivisions of the Culver City Municipal Code (CCMC) requires developers subdividing land for residential uses to dedicate parkland or pay an in-lieu fee. Chapter 15.10 is consistent with the Subdivision Map and Quimby Acts, which allow cities whose general plan contains policies and standards for park and recreation facilities to adopt by ordinance a parkland dedication requirement or in-lieu fees. Subdivisions in Culver City exempt from this requirement include those containing senior housing and/or low- or moderate-income housing. Parkland dedications and in-lieu fees are based on residential density of a proposed development. Chapter

15.10 does not establish a service radius for dedications, but states that the parkland dedication or fees "shall be used only for the purpose of developing new or rehabilitating existing neighborhood or community park or recreational facilities reasonably related to serving the subdivision." The City must accept in-lieu fees for projects with 50 residential units or fewer per Chapter 15.10.

Further, Chapter 15.06 of the CCMC (Residential Development Park Dedication and In Lieu Parkland Fees) requires all residential development, not just residential development that is a result of a subdivision, to dedicate parkland and in-lieu fees. This allows the City to collect in-lieu fees from residential projects, additional units on the same property, and conversions of single- family homes to multi-family projects. Chapter 15.06 allows the City to acquire and dedicate parkland outside of the proposed residential development. For instance, if a developer owns a parcel adjacent to an existing park, and the City determines that this parcel would benefit the City's parks and recreation system, the City may allow the developer to dedicate that property instead of property within a proposed residential development.

The City, however, does not require non-residential developers to develop parkland or recreational facilities as a condition of development. Many other California cities, per the Fee Mitigation Act (Section 66000 of California Government Code), require non-residential developers to dedicate parkland or pay in-lieu fees. Park and public space dedications from non- residential development are negotiated between the City and developers on a project-to-project basis as conditions of development approval.

4.15.4 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 recreation if the project would:

Threshold REC-1: Increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

Threshold REC-2: Include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

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Methodology
As discussed in Chapter 2, Project Description, of this PEIR, this analysis uses a Planning Area projected population estimate of 62,411 for the Project. The Planning Area includes Culver City and the SOI. In addition, this analysis considers the existing parkland ratio of 10 acres of parkland per 1,000 residents, which is equal to the General Plan Update’s parkland standard.

The existing parkland ratio is comprised of 1 acre of parkland per 1,000 residents that may be satisfied with joint use agreements with the CCUSD and 6 acres of parkland per 1,000 residents that may be satisfied by regional parks. At least 3 acres of parkland per 1,000 residents are to be satisfied by City-owned parks.

The provision of recreational facilities and ability to fund their installation and maintenance is provided for at a statewide level under the Quimby Act, a regulation allowing cities to require dedication of land or payment of fees for parks and recreation as a condition of tentative or parcel map approval.

Project Impact Analysis
Deterioration of Existing Recreational Facilities
Threshold REC-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

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

General Plan Update
Implementation of the General Plan Update would result in 12,700 additional housing units and 21,600 new residents at full buildout. An increase in population could result in greater use of the City’s existing parks and recreational facilities. The Project would also result in an increase of daytime population as a result of the increase in non-residential floor area.

As shown in Table 4.15-3, the current City park service ratio is 8.9 acres of parkland per 1,000 residents, inclusive of regional parks and joint use facilities. The current service ratio for City- parkland is 2.2 acres per 1,000 residents, which does not meet the standard of 3 acres per 1,000 residents. Although the General Plan Update maintains the park service standards, the City would continue to fall short of acres of parkland needed to meet future demand, in accordance with the City’s service standard. Therefore, the Project would not meet the City’s 3 acres of City- parkland per 1,000 residents service ratio.

The City has identified locations for planned or proposed trails and recreational facilities throughout Culver City. While there are currently no planned or proposed parks, as part of the General Plan Update, there are plans to bridge the City’s aquatic center to the Teen Center and

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open new community meeting rooms in the planned bridge. In addition, the City plans to build a new lesson pool and update the Municipal Plunge as a warm pool for family use. Further, there are opportunities to strengthen the City’s joint use agreement with CCUSD and West Los Angeles College to provide more access to recreational facilities and open spaces to residents. Joint-use facilities are proposed throughout the City, as shown in Figure 4.15-3. A 2-mile extension of the multi-use path along Ballona Creek from Syd Kronenthal Park to Mid-City is also proposed under the Project. These locations are shown in Figure 4.15-3, Proposed Recreational Facilities.

While no new parks are currently proposed within the Planning Area, approximately 90 percent of Culver City residences are within a one half-mile walking distance of an existing park, trail, or open space, including facilities just outside City limits. The General Plan Update includes policies to reduce park access inequities (Policy PR-1.1); ensure the pursuit of new parks and public space development opportunities (Policy PR-1.4), investment in (Policy PR-5.1 and Policy PR-5.4), and maintenance of public recreation facilities (Policy PR-3.1), which would minimize substantial physical deterioration of existing or new facilities due to use. Policies provided in the General Plan Update include securing funding for park and recreational facility maintenance and requiring developers to dedicate land and/or contribute fees to support park and recreational facility development. Policy PR-1.4 identifies specific ways to develop parks and public space such as incorporating more green space, landscaping, and passive recreational uses onto City-owned property or land; naturalizing the Ballona Creek and incorporating new mini parks along the Creek; developing parkettes/mini parks, woonerfs, and plazas. This policy also encourages the purchase of parcels to convert to parks in SB 1000
11 priority neighborhoods and areas beyond a ten-minute walk of a park, as opportunities arise. Policy PR-1.4 encourages development of community gardens throughout the city; and identifying potential locations to extend curb bump-outs to reclaim public space from roadways for uses such as parklets and gardens. Furthermore, the addition of new trails and recreational facilities proposed under the Project would help serve residents in the Planning Area, although trails are not counted toward public parkland.

Although the City is currently not meeting the park service ratio standard, the General Plan Update includes policies that would prioritize new park development. The City’s park service ratio provides an understanding of population relative to park acreage, and therefore a measure of the availability of park space to serve residents, but this ratio alone does not determine the quality of park service available to residents. In addition to improving the amount of park space and access to parks, park amenities need to be enhanced to improve the park quality in the City.

The park service ratio does not consider park amenities that improve park usability, like illuminated space, which makes parks usable for more hours of the day, or active and passive space, which allow for a greater variety of uses and programming. Accessibility to parks and other public outdoor recreational spaces, and the quality of the pedestrian environment leading to and from a green space is also an important factor in quality which relates to use of recreational facilities. Residents and workers are more likely to visit parks and outdoor recreational spaces within close proximity to a park. Living within a walkable distance of a park

11 SB 1000 requires local governments to identify environmental justice communities (called "disadvantaged communities") in their jurisdictions and address environmental justice in their general plans.

Culver City General Plan 2045
Figure 4.15-3
Proposed Recreational Facilities
SOURCE: City of Culver City, 2021; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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or outdoor recreational space can benefit residents, as physical activity is linked to stress reduction, improved mental health, and respiratory fitness. The General Plan establishes policies to reduce park access inequities, plans for parks and other outdoor recreational spaces in areas lacking convenient park access, and establishes a performance metric to track the percent of population within walking distance of a park. City staff identified several needed improvements for its park system, including trail expansion; lighting in active spaces; shade; new and updated sports fields; Internet access; accessibility amenities and features; updated playgrounds, restrooms, and park buildings; and turf renovations. Implementation of the General Plan Update as well as adoption and continual updates to the City’s Park and Recreation Master Plan (PRMP) can ensure that City staff has direction and resources to make these improvements.

Policies in the proposed General Plan Update would reduce the likelihood that any existing neighborhood, community, or regional parks, or other recreational facilities would experience overuse resulting in the physical deterioration of those facilities. Therefore, the Project would not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated.

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 are implemented in the development that would occur throughout the city over time. In addition, development resulting from the General Plan Update would be required to pay parks and recreation impact fees in accordance with the City’s Municipal Code. Therefore, the Zoning Code Update would not result in significant adverse effects related to parks and recreational facilities and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Parks, Recreation, and Public Facilities Element
Goal PRI-1: Equitable access. Equitable and safe access to parks, recreation, open spaces, and programming.

PR-1.1: Park walkability. Strive for all residents to be within a ten-minute walk of parks, open spaces, and joint use facilities.

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• Developing community gardens throughout the city, particularly in neighborhoods lacking convenient access to healthy foods.
• Identifying potential locations to extend curb bump-outs to reclaim public space from roadways for uses such as parklets and gardens.

Goal PR-3: Maintenance. Parks, recreational facilities, and public facilities are well- maintained and upgraded.

PR-3.1: Maintenance funding and standards. Secure funding for park and recreational facility maintenance and establish standards to ensure parks and facilities are adequately maintained.

Goal PR-5: Funding and resources. Parks, recreational facilities, and public facilities have improved funding mechanisms for maintenance and capital improvements projects.

PR-5.1: Dedications from private developers. Require developers to dedicate land/or contribute fees to support park and recreational facility development.

PR-5.4: Alternative funding sources for parks and recreation. Seek alternative sources of funding for parks and recreational facilities.

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 deterioration of existing recreational facilities.

Require Construction or Expansion of Recreational Facilities Threshold REC-2: The Project wou ld have a significant impact if implementation of the General Plan Update and Zoning Code Update w ould include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment.

Impact Statement REC-2: The Project would not include recreational facilities or require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Therefore, the Project would result in a less than significant impact.

General Plan Update
As stated under Impact REC-1, as part of the General Plan Update, there are plans to bridge the City’s aquatic center to the Teen Center and open new community meeting rooms in the planned bridge. The City also plans to build a new lesson pool and update the Municipal Plunge.

In addition, the General Plan Update includes a 2-mile extension of the multi-use path along Ballona Creek from Syd Kronenthal Park to Mid-City. Construction of these facilities could result in physical impacts to the environment, including potential disturbance or conversion of habitat,

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impacts to water quality during construction, increased noise levels, and an increase in impermeable surfaces which could result in flooding or polluted runoff.

The Project encourages the development of future recreational facilities in order to meet demand associated with anticipated population growth under the General Plan Update. The Project includes Policy PR-1.4 under Goal PR-1 which encourages the pursuit of new opportunities to develop parks. This policy identifies specific ways to develop parks and public space including incorporating more green space, landscaping, and passive recreational uses onto City-owned property or land; naturalizing the Ballona Creek and incorporating new mini parks along the Creek; developing parkettes/mini parks, woonerfs,
12 and plazas; purchasing parcels to convert
to parks in SB 1000 priority neighborhoods and areas beyond a ten-minute walk of a park.

The precise amount, type, and location of future parks and recreational facilities would be determined during the planning process for individual development projects or master/specific plans. Future development would be consistent with the proposed land use designations and policies. Environmental impacts associated with construction of new and expanded of parks and recreational facilities identified above that are proposed as part of the Project development of parks and recreational facilities would be subject to additional environmental review under CEQA, as needed.

Various proposed goals and policies in the General Plan Update consider energy and water use efficiency and sensitive habitat preservation, encourage the use of native vegetation and/or drought-tolerant landscaping where reasonable; and promote sustainable stormwater management through the construction of on-site green infrastructure. 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 (Goal C-6 and associated policies). Further, future development would be subject to City Zoning Code requirements including setback requirements, landscape requirements, and outdoor lighting regulations designed to minimize environmental impacts associated with the construction of new or expanded parks and recreational facilities. Therefore, General Plan Update policies are designed to minimize environmental impacts associated with the construction of new parks or expanded recreational facilities. As such, 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 are implemented in the development that would occur throughout the city over time. Furthermore, construction of new or expanded parks and recreational facilities that would occur under the Project would be reviewed by the City for compliance with applicable policies of the General Plan Update, the Zoning Code Update, and applicable mitigation measures referenced in other sections of this PEIR. Therefore, the Zoning Code Update itself would not

12 Woonerfs are a streetscape design to accommodate pedestrians, bicyclists, and vehicles in a shared space.

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result in physical effects on the environment from the construction of new or expanded parks and recreational facilities. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Parks, Recreation, and Public Facilities Element
Goal PR-1: Equitable access. Equitable and safe access to parks, recreation, open spaces, and programming.

PR-1.4: New parks. Pursue new opportunities to develop parks and public space, including:
• Incorporating more green space, landscaping, and passive recreational uses onto City-owned property or land.
• Studying the potential to naturalize the Ballona Creek and incorporate new mini parks along the Creek.
• Developing parkettes/mini parks, woonerfs, and plazas, particularly in built-out areas (like Downtown) or neighborhoods in need of park space. • Purchasing parcels to convert to parks in SB 1000 priority neighborhoods and areas not within a ten-minute walk of a park, as opportunities arise. • Developing community gardens throughout the city, particularly in neighborhoods lacking convenient access to healthy foods.
• Identifying potential locations to extend curb bump-outs to reclaim public space from roadways for uses such as parklets and gardens.

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 requiring construction or expansion of recreational facilities.

4.15.5 Cumulative Impacts Analysis
The geographic context for the analysis of cumulative impacts associated with parks and recreational facilities is the Westside region of Los Angeles County, which is comprised of the cities of Beverly Hills, Culver City, Malibu, Santa Monica, and West Hollywood as well as the communities of Bel Air, Brentwood, Century City, Hollywood, Marina Del Rey, the Miracle Mile, Pacific Palisades, Playa Vista, Venice, and Westwood.
13 Future development in this portion of
the county, including future development allowed under the Project, could have an adverse effect on existing parks and recreational facilities in the region, and thus could result in a potentially significant cumulative impact with respect to the overuse and degradation of existing park facilities. Future development and population growth anticipated by the Project would

13 Los Angeles County Economic Development Corporation, 2023. Westside. https://laedc.org/thrive-in-la/regions- cities/westside/. Accessed March 2023.

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generate additional demand for parks and recreational facilities. While there are no new planned parks or park expansion identified for development through the Plan’s 2045 planning horizon, the General Plan Update includes a trail extension, expansion of joint-use agreements, and a proposal to bridge the City’s aquatic center to the Teen Center, construction of a new lesson pool and updates to the Municipal Plunge. The General Plan Update includes several policies to prioritize development of new parks, expand connections and access to existing and future parks and recreational facilities, and to improve existing facilities through 2045 to better serve the projected increase in population under the Project. Therefore, the Project’s contribution to this cumulative impact would not be cumulatively considerable.

Demand for parks and recreation facilities due to future development in this portion of the county, including future development allowed under the Project, could result in the construction or expansion of additional parks and recreational facilities, the construction of which might have adverse physical effects on the environment. As a result, the construction or expansion of additional parks and recreation facilities could result in a potentially significant cumulative impact. The Project contains plans for additional recreational facilities in the Planning Area. All new and expanded facilities would be subject to applicable General Plan land use designations and policies as well as applicable Zoning Code regulations related to construction and operational impacts. Elements of the General Plan Update and standards within the Zoning Code Update are designed to minimize potentially cumulatively considerable environmental impacts of new development, including sustainable park and recreational facility design, development, and planning standards. Therefore, the Project would not contribute to a cumulatively significant impact related to the construction or expansion of recreational facilities, the construction of which might have adverse physical effects on the environment.

4. Environmental Impact Analysis

4.15 Recreation
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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.16-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.16 Transportation

4.16.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on transportation from future development allowed under the Project, including potential impacts related to circulation programs, plans, ordinances, and policies; vehicle miles traveled (VMT); geometric hazards and incompatible uses; and inadequate emergency access. The section provides context regarding the Planning Area’s existing roadway network, bicycle and pedestrian conditions, and transit conditions, as well as relevant federal, state, and local regulations and programs.

4.16.2 Environmental Setting
The Planning Area, as shown in Figure 2-2, Planning Area, includes Culver City and its unincorporated sphere of influence (SOI). As shown in the figure, the Planning Area is bounded by the City of Los Angeles to the north, west, and south, and by unincorporated areas of Los Angeles County along its eastern boundary. 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 includes approximately 3,910 acres of land, including approximately 3,280 acres of land (84 percent) within the City’s jurisdictional boundaries and approximately 630 acres of land (16 percent) in its SOI. Existing land uses in the Planning Area include residential (44 percent), commercial (15.7 percent), industrial (7.1 percent), open space (19.8 percent), cemetery (7.5 percent), studio (3.5 percent), Ballona Creek (2.3 percent), and institutional (0.1 percent).

Existing Roadway Network
The existing roadway network is shown in Figure 4.16-1, Existing Roadway Network.

Freeways
Two freeways, the San Diego (I-405) and the Marina (SR-90), traverse Culver City. The Santa Monica Freeway (I-10) abuts the most northeast portion of the city. The California Department of Transportation (Caltrans) operates these facilities. From a roadway classification and hierarchy standpoint, freeways are the highest level of roadway in the Planning Area, providing limited access and grade-separated intersections from the rest of the roadway network. Their primary function is to carry large volumes of regional and interstate traffic at high speeds.

Primary Arteries
Primary arteries serve primarily through, non-local traffic and provide limited local access. They have a curb-to-curb width of 95 feet or more; however, many primary arterials in the city are not as wide due to existing development. High vehicular volumes and speeds characterize traffic flow on primary arteries. The number of lanes on primary arteries ranges from four and six lanes

§¨¦405
!(90
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00 .510.25
Miles
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 Parkway
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

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
Roadway Network
Primary Arterial
Secondary Arterial
Major Collector
Minor Collector
Truck Route
Future Roadway Network & Classiﬁcation
Local Street
FIGURE 26
Culver City General Plan 2045
Figure 4.16-1
Existing Roadway Network
SOURCE: Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

4.16. Transportation
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plus left-turn lanes, with limited occurrences of private driveways. Some primary arteries, such as Culver Boulevard and Venice Boulevard,1 accommodate landscaped medians and on-street parking. Designated primary arteries in Culver City include Adams Boulevard, Centinela Avenue, Culver Boulevard, Fairfax Avenue, Jefferson Boulevard, La Cienega Boulevard, Overland Avenue, Playa Street, Robertson Boulevard, Sepulveda Boulevard, Slauson Avenue, Venice Boulevard, Washington Place, and Washington Boulevard. Several of these primary arteries are also designated truck routes.

Secondary Arteries
Secondary arteries connect primary arteries and neighborhood feeders serving both non-local through traffic and local access. They have a right-of-way ranging from 80 to 94 feet, although some streets within the city serving this function are observed to be narrower. The number of travel lanes on secondary arteries ranges from two and four lanes. Designated secondary arteries in Culver City include Bristol Parkway, Buckingham Parkway, Duquesne Avenue, Glencoe Avenue, Green Valley Circle, Hannum Avenue, National Boulevard, and Sawtelle Boulevard.

Neighborhood Feeders
Neighborhood feeder streets are primarily located in residential neighborhoods connecting arteries and local streets. With one lane in each direction, neighborhood feeders are not designed to accommodate regional through traffic. However, many have become popular bypass routes due to heavy peak period congestion and the proliferation of smartphone-based traffic applications. Designated neighborhood feeder streets in Culver City include Beethoven Street, Braddock Drive, Elenda Street (Washington to Culver), Girard Avenue, Higuera Street (Washington to Hayden), Lucerne Avenue, Redwood Avenue, and Walgrove Avenue.

Local Streets
Local streets provide access between adjacent land uses and connect private parking and driveways to larger non-local streets. Local streets typically do not exceed 60 feet in right-of-way (40 feet in pavement width) or have a painted centerline and are found mostly in residential neighborhoods. Examples of designated local streets in Culver City include Irving Place, Kinston Avenue, Selmaraine Drive, and McConnell Avenue.

Bicycle and Pedestrian Conditions
Bicycle, walking, and micromobility services are integral to Culver City's transportation network and provide essential first/last-mile connections to transit. City staff have expressed the desire to provide a connected bicycle network, including Class II, Class III, and Class IV facilities (see description of bicycle facility classifications, below), where appropriate. Potential locations for low-stress active travel improvements include Culver Boulevard, Elenda Street, and north-south arteries such as Overland Boulevard. As an important active transportation corridor, the Ballona Creek Bike Path, can also be improved, with lighting, safety, additional access points in permitted areas, and other related improvements. A comprehensive inventory of proposed

1 It should be noted that for much of Venice Boulevard, the city limit runs along the south side of the street, with just the curb-side parking area west of Sawtelle Boulevard located within the city.

4. Environmental Impact Analysis

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bicycle facilities is outlined in Table 10 of the 2020 Bicycle and Pedestrian Action Plan.

Additionally, Culver City released the Local Road Safety Plan in November 2021.

Bikeway Facilities
Culver City's existing network of Class I and Class II bicycle facilities is disconnected, with few routes intersecting others, forcing cyclists to share space with motor vehicles. Bicycle lanes along Washington Boulevard are inconsistent, changing between Class II and Class III multiple times. The Ballona Creek Bike Path is a popular regional bicycle route, but it has few access points into Culver City, and some access points are busy arterial streets without bicycle infrastructure (such as Sepulveda Boulevard and Overland Avenue). Other access points, such as Duquesne Avenue, were restriped with Class II bicycle lanes using green paint, providing a connection to downtown. Bicycle lanes along Jefferson Boulevard also provide a connection to the lanes on Duquesne Avenue to the north but do not continue to the south.

Overall, Culver City's location and boundaries present a challenge for a continuous, connected bicycle network. Surrounded by the City of Los Angeles and several unincorporated areas on all sides, many of Culver City's arterial streets function as regional connectors for motor vehicle traffic in all directions. Any reallocation of street space would require significant coordination from a regional traffic perspective. Further, streets such as Sepulveda Boulevard and Washington Place are not contiguously inside the city's boundaries, therefore requiring that the respective government agencies coordinate to design continuous bikeways along these corridors.

The following section provides a description of the functional classification of bicycle facilities within the Planning Area, as mapped in Figure 4.16-2, Existing and Proposed Bicycle NetworkI-.

The general purpose of the bikeway network is to encourage access for both work and non-work trips by active modes within the city and adjoining communities, in addition to enhancing opportunities for recreation.

Class I Bicycle Path
Class I are shared-use bicycle paths, or paved trails. The facilities provide separate, exclusive right-of-way for bicycling, walking, and other non-motorized uses. They can be considered the lowest stress facilities, as there are few potential conflicts between bicycles and motor vehicles.

Culver City has a total of 4.4 miles of shared-use path facilities, with Ballona Creek Bike Path the longest at 3.2 miles.

Class II Bicycle Lane
Class II are striped, preferential lanes on roadways for one-way bicycle travel. Some bicycle lanes include striped buffers that add a few feet of separation between the bicycle lane and traffic lane or parking aisle. These facilities are important for the overall bikeway network that Culver City strives to achieve because they provide a designated space for riders along a roadway. Culver City currently has 6.5 miles of roads with bicycle lanes.

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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 Parkway
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

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

Existing Class II: Bicycle Lane
Existing Class III: Bicycle Route
Existing Class I: Bike Path
Proposed Class I: Bike Path
Proposed Class II: Bicycle Lane
Proposed Class III: Bicycle Route
Existing Class IV: Separated Bikeway
Proposed Class IV: Separated Bikeway
FIGURE 28
Culver City General Plan 2045
Figure 4.16-2
Existing and Proposed Bicycle Network
SOURCE: Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

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Class III Bicycle Route (Sharrow)
Class III are signed routes where people riding bicycles share a travel lane with people driving.

Because they are mixed-flow facilities, bicycle routes are only appropriate for low-volume streets with slow travel speeds. Some routes are designated only by Caltrans-compliant Bicycle Route signs, while others are designated by signs and painted shared-lane markings, or "sharrows," to indicate a shared environment for bicycle riders and motorists. Among other benefits, shared-lane markings reinforce the legitimacy of bicycle traffic on the street, recommend proper bicyclist positioning, and may be configured to offer directional and wayfinding guidance. Class III on residential streets may be designated as "bicycle boulevards." Traffic calming measures that help to slow traffic and assist bicyclists and pedestrians in crossing busier roadways are included as needed to help reduce cut through vehicle trips. Culver City currently has about 3.5 miles of Class III bicycle routes.

Class IV Separated Bikeway
Class IV–or separated bikeways–also known as cycle tracks, are on-street facilities that are physically separated from motor vehicle traffic by a vertical element or barrier, such as a curb, bollards, or vehicle parking aisle. This facility type provides extra separation between moving vehicles and people riding bicycles so that bicyclists feel more secure while traveling along a roadway. Culver City currently has no separated bikeway facilities.

Pedestrian Facilities
Most streets in Culver City have sidewalks in good condition. Downtown Culver City features wide promenade sidewalks with space for amenities like seating, planters, and public art.

However, there are gaps in sidewalk coverage along Bentley Avenue from Venice Boulevard to Washington Place, on both sides of the street, and on the south side of Slauson Avenue, east of Hannum Avenue. A comprehensive inventory of proposed pedestrian facilities is outlined in Table 11 of the 2020 Bicycle and Pedestrian Action Plan along with recommended improvements and sample costs.

Transit Conditions
Culver City Transit Center
The Culver City Transit Center is located at the southeast corner of the Slauson Avenue and Sepulveda Boulevard intersection, north of the Westfield Mall and SR-90. The Transit Center is an outdoor facility that connects multiple bus services, including Metro Lines 110, 108/358, and 217; and Culver CityBus Lines 3, 4, and 6. City Bus Lines 2 and Rapid 6 also provide service to Slauson Avenue and Sepulveda Boulevard next to the Transit Center. Services connect riders to Metro Rail B (Red), A (Blue), C (Green), and E Line (Expo). Additionally, riders can take Culver CityBus Line 6 or Rapid 6 to the Los Angeles International Airport (LAX) City Bus Center to transfer for free on LAX Shuttle C, which serves all passenger terminals at LAX. Free parking is available at the Culver City Transit Center and the adjacent Westfield Mall parking lot.

Robertson Transit Hub
The Robertson Transit Hub is located on the east side of Robertson Boulevard between Venice Boulevard and Washington Boulevard. The Transit Hub connects riders to multiple services

4. Environmental Impact Analysis

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including Culver City Bus Line 7, Metro Line 17, and Big Blue Bus Line 17. The Transit Hub is adjacent to Metro E Line Culver City Station and Metro's Culver City Bike Hub, which provides secure parking for 64 bicycles as well as a variety of bicycle commuter-related services including bike rentals, repairs, classes, and community events. Metro's Culver City Bike Hub also provides a lounge and restroom facility for all rail/bus operators.

West Los Angeles Transit Center
The West Los Angeles Transit Center, or the Washington Fairfax Hub, is a terminal located directly underneath Interstate Highway 10 on Washington Boulevard and Fairfax Avenue.

Although the West Los Angeles Transit Center is located just outside of Culver City limits, it serves as an important transit node. Many transit lines begin and terminate at the West Los Angeles Transit Center, including Metro Lines 14, 35, 37, 38, 105, 217, 705 and 780 and Culver City Bus Lines 1 and 4.

Fixed-Route Transit Service
The Metro E Line (Expo) Culver City Station opened in 2012 and the E Line was extended to Downtown Santa Monica in 2016, providing a catalytic boost to the city's transit accessibility and viability as a location for transit-oriented development. The E Line is complemented with Culver City's CityBus fixed-route and Dial-A-Ride service, in addition to a limited number of Metro, Los Angeles Department of Transportation (LADOT) and Santa Monica Big Blue Bus (BBB) fixed-route bus services. Below is an inventory of transit services in the city, and as shown in Figure 4.16-3, Existing and Proposed Transit Routes.

Culver CityBus
Culver CityBus serves nearly 6 million annual riders throughout a 25.5-square-mile service area2 that includes Culver City and the following Westside communities outside of the city limits:

Venice, Westchester, Westwood, West Los Angeles, Palms, Playa Vista, Marina Del Rey, Rancho Park, Mar Vista, and Century City. Descriptions for Culver CityBus service are provided below, including routes, stop locations, and schedules, and are reflective of 2019 conditions (i.e., pre- pandemic).
• CityBus Line 1 runs east to west from Washington Boulevard and Fairfax Avenue to Venice Beach. Some major destinations it serves include the West Los Angeles Transit Center, Helms Bakery District, the Metro Expo Culver City Light Rail Station, Culver City Hall, and Venice Beach. Service runs from approximately 5:40 a.m. to 11:36 p.m. on weekdays, and from 6:00 a.m. to 11:55 p.m. on weekends and holidays, with 14- to 18-minute headways during weekday peak hours and approximately 20-minute headways during weekends. • CityBus Line 2 is a 9.8-mile round-trip weekday community circulator connecting Washington and Lincoln Boulevards with the Fox Hills Mall and Corporate Pointe. It serves commercial and residential neighborhoods along the route and Venice High School. Service runs from 5:37 a.m. to 6:22 p.m. with one-hour headways.

2 Culver City, 2023. Culver CityBus About Us. https://www.culvercitybus.com/Culver-CityBus/About-Us. Accessed March 2023.

To
Century
City
To
Century
City
To UCLATo UCLA
To AMC Station/
Airport People Mover
To AMC Station/
Airport People Mover
1 3
3 7
5 4
6 3
1 1
5 4
5 7
4 6
7 2
2 2
45 6R
6R
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New
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City Transit Center
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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 Parkway
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

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
Transit
Network
Existing (2020) CityBus route to maintain in the future Existing (2020) CityBus route proposed for improved frequency Existing (2020) CityBus route proposed for future realignment New New CityBus route
Transit Priority Corridor
Future Rixed-Route Transit and HCT Improvements
Downtown and Jefferson Circulators
Circulators
Service Areas
Microtransit
FIGURE 29
Culver City General Plan 2045
Figure 4.16-3
Existing and Proposed Transit Routes
SOURCE: Mobility Element, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

4. Environmental Impact Analysis

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• CityBus Line 3 serves Century City, Palms, West Los Angeles College, Fox Hills, and the Corporate Pointe area of Culver City. Service runs from 5:20 a.m. to 11:38 p.m. on weekdays and from 5:40 a.m. to 11:38 p.m. on weekends, with 18- to 26-minute peak period headways on weekdays and 30- to 40-minute headways on weekends. • CityBus Line 4 is a 16.4-mile route providing connections to several transit hubs including Westfield-Culver City Transit Center, West Los Angeles Transit Center, and Expo Line Light Rail La Cienega Station. This line serves key destinations, including West Los Angeles College and Culver City Park. Service runs from 5:37 a.m. to 9:10 p.m. on weekdays and on Saturdays from 5:40 a.m. to 9:12 p.m. with 40- to 50-minute headways. • CityBus Line 5 is a weekday community circulator route that connects Inglewood and Washington Boulevards with Blair Hills via Braddock Drive. Destinations include Culver City Junior and Senior High Schools, downtown Culver City, the Hayden Industrial Tract, and La Cienega Boulevard. Service is specifically tailored to school schedules, so students can take the bus before and after school. Service runs one westbound trip from 7:15 a.m. to 7:44 a.m. and two eastbound trips from 2:40 p.m. to 3:58 p.m. on weekdays. • CityBus Line 6 runs north and south along the Sepulveda corridor from Westwood and UCLA to the Metro Green Line Station at Aviation Boulevard and Imperial Highway. Service runs from 5:00 a.m. to 12:53 a.m. weekdays and from 5:40 a.m. to 12:05 a.m. on weekends, with 17- to 23-minute headways during weekday peak hours and approximately 23-to-30-minute headways during weekends.
• CityBus Rapid 6 runs a similar route to Line 6 and travels along the Sepulveda corridor from UCLA through Westwood to the Metro Green Line Aviation Station. It has limited stops at major intersections and does not directly service the Howard Hughes Center and the Westfield-Culver City Transit Center. The route only operates on weekdays from 5:45 a.m. to 8:57 p.m. with 10- to 30-minute headways.
• CityBus Line 7 runs primarily along Culver Boulevard and connects downtown Culver City with the Fisherman's Village in Marina Del Rey. Some major destinations it serves include the Robertson Transit Hub, Metro E Line Culver City Station, City Hall, Culver City Senior Center, Veterans Memorial Park, and the Fisherman's Village in Marina del Rey. Service runs from 5:20 a.m. to 9:16 p.m. on weekdays, with headways of 40 to 50 minutes.

Big Blue Bus
Santa Monica's BBB Line 17 connects the Metro E Line Culver City Station to UCLA in Westwood daily, with 20-minute headways on weekdays and 30-minute headways on weekends. In addition, there are other BBB bus lines that intersect with or operate adjacent to the Culver City boundary including BBB Lines 3, Rapid 3, Rapid 12, and 16.

Los Angeles Department of Transportation
LADOT Commuter Express 437 also serves Culver City and provides connections to Downtown Los Angeles. It is a peak hour directional service that shuttles passenger to Downtown Los Angeles in the morning and brings them back to the westside in the afternoon.

4. Environmental Impact Analysis

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LA Metro
Seven Metro bus routes serve Culver City daily, with four out of the five routes stopping at the Culver City Transit Center at Westfield Mall, which offers transfers to other service providers.

The E Line light-rail connects Culver City with Downtown Santa Monica, West Los Angeles, the University of Southern California, and Downtown Los Angeles. Metro bus Line 108 connects passengers at the Metro rail Slauson A (Blue) Line station with the Venice Pier. Line 110 stops at Metro A Line Florence Station, and Line 217 serves the Kaiser Permanente Hospital, the Grove, several museums, and the Howard Hughes Center. Line 33/733 connects Culver City with Santa Monica and Union Station in Downtown Los Angeles. Line 35 connects Culver City with Downtown Los Angeles. Line 358 serves the same route as Line 108, but it does not run on weekends. Line 17 also runs only during the week and travels from Downtown Los Angeles to Century City. Line 780 connects Culver City with Hollywood, Los Feliz, Glendale, Eagle Rock, and Pasadena and only runs on weekdays.

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

Federal
Americans with Disabilities Act of 1990
Titles I, II, III, and V of the Americans with Disabilities Act (ADA) have been codified in Title 42 of the United States Code (U.S.C.), beginning at Section 12101. Title III prohibits discrimination based on disability in “places of public accommodation” (businesses and non-profit agencies that serve the public) and “commercial facilities” (other businesses). The regulation includes Appendix A through Part 36 (Standards for Accessible Design), establishing minimum standards for ensuring accessibility when designing and constructing a new facility or altering an existing facility. Examples of key guidelines include detectable warnings for pedestrians entering traffic where there is no curb, a clear zone of 48 inches for the pedestrian travel way, and a vibration- free zone for pedestrians.

America’s Transportation Infrastructure Act of 2019
America’s Transportation Infrastructure Act of 2019 authorizes $287 billion for the Highway Trust Fund over five years in investments to maintain and repair America’s roads and bridges.

The legislation includes provisions to improve road safety, accelerate project delivery, improve resiliency to disasters, reduce highway emissions, and grow the economy.

State
California Department of Transportation
Caltrans implements state planning priorities in all plans, programs, and activities. Caltrans has the responsibility to coordinate and consult with local jurisdictions when proposed local land use planning and development may impact state highway facilities. Pursuant to Public Resources Code (PRC) § 21092.4, for projects of statewide, regional, or area-wide significance, the lead

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agency must consult with transportation planning agencies and public agencies that have transportation facilities which could be affected by a project.

Complete Streets Act
Assembly Bill (AB) 1358, the Complete Streets Act (Government Code Sections 65040.2 and 65302), was signed into law by Governor Arnold Schwarzenegger in September 2008. As of January 1, 2011, the law requires cities and counties, when updating the part of a local general plan that addresses roadways and traffic flows, to ensure that those plans account for the needs of all roadway users. Specifically, the legislation requires cities and counties to ensure that local roads and streets adequately accommodate the needs of bicyclists, pedestrians and transit riders, as well as motorists.

At the same time, Caltrans, which administers transportation programming for the state, unveiled a revised version of Deputy Directive 64 (DD-64-R1 October 2008), an internal policy document that now explicitly embraces Complete Streets as the policy covering all phases of state highway projects, from planning to construction to maintenance and repair.

California Vehicle Code
The California Vehicle Code (CVC) provides requirements for ensuring emergency vehicle access regardless of traffic conditions. Sections 21806(a)(1), 21806(a)(2), and 21806(c) define how motorists and pedestrians are required to yield the right-of-way to emergency vehicles.

Assembly Bill 32/Senate Bill 32
On September 27, 2006, Governor Schwarzenegger approved AB 32, the California Global Warming Solutions Act of 2006. The purpose of AB 32 is to require a sharp reduction in greenhouse gas (GHG) emissions and set the stage for a sustainable future. AB 32 requires California to reduce its GHG emissions to 1990 levels by 2020, a reduction of 15 percent below emissions expected under a “business as usual” scenario. AB 32 requires the California Air Resources Board (CARB) to develop regulations and market mechanism to meet the GHG emission reduction targets.

On September 8, 2016, Governor Brown approved Senate Bill (SB) 32. The purpose of SB 32 is to set additional GHG emission reduction targets following the California Global Warming Solutions Act of 2006. SB 32 requires CARB to ensure that GHG emissions are reduced to 40 percent below the 1990 level by 2030. (See Section 4.7, Greenhouse Gas Emissions, for further discussion regarding GHG regulatory framework.)
Senate Bill 375
On September 30, 2008, Governor Schwarzenegger approved SB 375. The purpose of SB 375 is to coordinate transportation and land use planning to reduce GHG emissions. SB 375 requires Metropolitan Planning Organizations (MPOs) to adopt Sustainable Communities Strategies (SCS) as part of the Regional Transportation Plan (RTP) to achieve goals for the reduction of GHG emissions from automobiles and light trucks in the region. SB 375 also requires CARB to work with MPOs to provide each region with GHG reduction targets for 2020 and 2035 by September

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30, 2010. The bill requires transportation planning and programming activities by the MPOs to be consistent with the SCS. To the extent the SCS is unable to achieve the GHG reduction targets set by CARB, MPOs are required to prepare an alternative planning strategy to the SCS showing how the targets would be achieved through alternative development patterns, infrastructure, or additional transportation measures and policies. CARB is required to review each MPOs SCS and alternative planning strategy to determine whether the strategy would achieve GHG emission reduction targets.

Senate Bill 743
On September 27, 2013, Governor Brown signed SB 743, which became effective on January 1, 2014. The purpose of SB 743 is to streamline the review under the California Environmental Quality Act (CEQA) process for several categories of development projects including the development of infill projects in transit priority areas and to balance the needs of congestion management with statewide goals related to infill development, promotion of public health through active transportation, and reduction of GHG emissions. SB 743 added Chapter 2.7, Modernization of Transportation Analysis for Transit Oriented Infill Projects, to the CEQA Statute (Section 21099). Among other things, SB 743 mandates that alternative metric(s) for determining impacts relative to transportation shall be developed to replace the use of Level of Service (LOS) in CEQA documents. Previously, environmental review of transportation impacts focused on the delay that vehicles experience at intersections and on roadway segments, which is often measured using LOS. Pursuant to SB 743, the focus of transportation analysis changes from vehicle delay to VMT. The Office of Planning and Research (OPR) released two rounds of draft proposals for updating the CEQA Guidelines related to evaluating transportation impacts and, after further study and consideration of public comment, submitted a final set of revisions to the Natural Resources Agency in November 2017. This was followed by a rulemaking process that would implement the requirements of the legislation. The updates to the CEQA Guidelines required under SB 743 were approved on December 28, 2018. Under CEQA Guidelines Section 15064.3, statewide application of the new VMT metric was required beginning on July 1, 2020.

Regional
Southern California Association of Governments 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy
In compliance with SB 375, on September 3, 2020, the Southern California Association of Governments (SCAG) Regional Council adopted the 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (2020–2045 RTP/SCS), a long-range visioning plan that incorporates land use and transportation strategies to increase mobility options and achieve a more sustainable growth pattern while meeting GHG reduction targets set by CARB. The 2020– 2045 RTP/SCS contains baseline socioeconomic projections that are used as the basis for SCAG’s transportation planning, as well as the provision of services by the six-county region of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura counties. SCAG policies are directed towards the development of regional land use patterns that contribute to reductions in vehicle miles and improvements to the transportation system.

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The 2020–2045 RTP/SCS builds on the long-range vision of SCAG’s prior 2016-2040 RTP/SCS to balance future mobility and housing needs with economic, environmental and public health goals. A substantial concentration and share of growth is directed to Priority Growth Areas (PGAs), which include high quality transit areas (HQTAs), Transit Priority Areas (TPAs), job centers, Neighborhood Mobility Areas (NMAs) and Livable Corridors. These areas account for 4 percent of SCAG’s total land area but the majority of directed growth. HQTAs are corridor- focused PGAs within 0.5 miles of an existing or planned fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes (or less) during peak commuting hours. TPAs are PGAs that are within a 0.5 miles of a major transit stop that is existing or planned. Job centers are defined as areas with significant higher employment density than surrounding areas which capture density peaks and locally significant job centers throughout all six counties in the region. NMAs are PGAs with robust residential to non- residential land use connections, high roadway intersection densities, and low-to-moderate traffic speeds. Livable Corridors are arterial roadways, where local jurisdictions may plan for a combination of the following elements: high-quality bus frequency; higher density residential and employment at key intersections; and increased active transportation through dedicated bikeways.

The 2020–2045 RTP/SCS’ “Core Vision” prioritizes the maintenance and management of the region’s transportation network, expanding mobility choices by co-locating housing, jobs, and transit, and increasing investment in transit and complete streets. Strategies to achieve the “Core Vision” include, but are not limited to, Smart Cities and Job Centers, Housing Supportive Infrastructure, Go Zones, and Shared Mobility. The 2020–2045 RTP/SCS intends to create benefits for the SCAG region by achieving regional goals for sustainability, transportation equity, improved public health and safety, and enhancement of the regions’ overall quality of life. These benefits include, but are not limited to, a 5 percent reduction in VMT per capita, 9 percent reduction in vehicle hours traveled, and a 2 percent increase in work-related transit trips.

Local
Circulation Element of the General Plan, 2004
The General Plan’s Circulation Element was originally adopted in 1995 and many goals, policies, and objectives are still reflective of that time. Minor amendments were made to establish policies governing development along Ballona Creek in 2004. The element sets a vision for mobility around revitalizing the local street system and reduce vehicular travel and will be updated as part of the General Plan Update.

Neighborhood Traffic Management Program, 2004
The Neighborhood Traffic Management Program (NTMP) aims to improve the quality of life in the City’s neighborhoods by implementing transportation solutions to make streets safer and more comfortable. The NTMP allows Culver City residents and the City to work together to address traffic problems, such as speeding or cut-through traffic, on local streets by considering various traffic calming solutions.

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Ballona Creek Greenway Plan, 2010
The Ballona Creek Greenway Plan summarizes several design opportunities focusing on trail connections, gathering and entry points, stormwater mitigation, and street design.

Recommendations specific to Culver City include improving connections to local parks by integrating Ballona Creek with nearby Culver City neighborhoods using urban forestry and greenway landscaping combined with complete street updates. The 2011’s Greenway Projects is a follow-up exploration of a natural trail along the Adams Channel.

Culver City Bicycle/Pedestrian Safety Assessment, 2014
The objectives of the Culver City Bicycle/Pedestrian Safety Assessment are to improve pedestrian and bicyclist safety, enhance walkability and bike-ability, and to increase accessibility for all pedestrians and bicyclists. The study analyzed the City’s existing and future pedestrian and bicycle demands, which included local Safe Route to School programs, the 2010 Bicycle Pedestrian Master Plan, and the review of collision data. This study focused on identifying opportunities to build on these existing efforts and offered recommendations for potential improvements. Walking and bicycle study areas included Washington Boulevard, Culver Boulevard, the Tri-School area, and Fox Hills Park. Additional bicycle studies were conducted at Washington Boulevard from the Metro E Line to Downtown Culver City, the Ballona Creek Bike Path at Duquesne Avenue, and Elenda Street from La Ballona Elementary School to Farragut Elementary School.

Transit-Oriented Development Visioning Study and Recommendations, 2017 The Transit-Oriented Development (TOD) Visioning Study and Recommendations refocuses mobility planning in the TOD area to foster multi-modal connectivity and promote safe pedestrian, bicycle, transit, and automobile travel. Beginning with the Metro E Line Culver City Station, the mobility visioning study explored linkages to improve station areas connections with Downtown and with its surrounding neighborhoods. Adopted in 2017, the plan is anchored by the overarching principle to optimize viable choices for movement within Culver City for those living and working in the city. Other plan principles that inform mode-based recommendations include:
• Pedestrians first
• Capitalize on transit opportunities
• First/last mile options
• Accommodate safe bike facilities
• Optimize mobility hub
• Allocate “appropriate” space for cars
Expo-Downtown Bicycle Connector Feasibility Study, 2017 The PWD evaluated the feasibility of connecting the Metro E Line Culver City Station to Downtown Culver City with a high-quality bicycle facility to complement the City’s efforts to encourage bicycle-friendly, walkable transit-oriented development. The recommended project, which has not been implemented, would install a two-way protected bike lane on Washington

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Boulevard connecting to the Expo Bike Path at Wesley Street, Culver City Station, and Town Plaza in Downtown Culver City. The project would also install a two-way protected bike lane on Robertson Boulevard from Washinton to Venice Boulevard to connect to the Expo Phase II Bike Path north of Venice. Similar protected two-way cycle track (Class IV) on Culver Boulevard connecting Duquesne Avenue where Class II bike lanes exist to Washington Boulevard.

Reimagining Fox Hills, 2019
In 2014, the City launched the “Reimagine Fox Hills” program to revitalize commercial property in Fox Hills, which is bounded by Slauson Avenue to the north, the 405 Freeway to the west, Centinela Avenue to the south, and the City of Los Angeles to the east. The revitalization could include the creation of a “Main Street” along Bristol Parkway with retail and restaurant uses, expanded creative office campuses, structured parking, and walkable/bike-able streets. The Economic Development Division is planning to develop a Master Plan for the Fox Hills area, which will identify market feasibility for redevelopment potential and provide a new development framework that syncs with the City’s emerging economy.

Bike Share Feasibility Study, 2017
The purpose of this study is to evaluate the feasibility of operating a bike share system in Culver City, to evaluate which system would best serve the City’s goals and interests. As a result, the Study recommended that Culver City pursue a smart bike system in partnership with Metro. The implementation of a bike share system in Culver City would encourage bicycling as a mode of transportation and could greatly increase connections to local destinations and regional transit.

American Disabilities Act Transition Plan, 2018
The American Disabilities Act (ADA) Transition Plan aims to assess curb ramps, intersections, sidewalk barriers, and transit stops in an effort to identify facility needs, prioritize implementation and funding, and make recommendations to improve the safety and comfort of walking and wheelchair use in Culver City.

Complete Streets Policy, 2020
In January 2020, the City adopted a Complete Streets Policy intended to establish guiding principles for transportation improvements to accommodate people of all ages and abilities traveling by the different modes of transportation. The policy aims to promote healthy and sustainable multimodal mobility for Culver City residents and visitors. To accomplish this, the Policy guides the provision of a safe, convenient, and comfortable street system throughout the city that provides for the needs of road users of all ages, abilities, and backgrounds including bicyclists, pedestrians, drivers, and transit users.

Short Range Mobility Plan
The Short Range Mobility Plan FY 2022-26 (SRMP) is a five-year planning and policy document that outlines regulatory requirements, strategic performance goals and objectives, and provides a three-year financial plan for the Culver CityBus and the Culver City Transportation

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Department.3 The SRMP provides analysis of the current fixed route service and the impact of local and regional transit projects, and evaluation of main corridors and the on-demand services offered by Culver CityBus.

Local Road Safety Plan, 2021
This plan is a living document that identifies conditions that contribute to collisions within the City and recommends potential traffic safety improvements tailored to Culver City’s unique traffic needs and issues. The plan is aligned with the US Department of Transportation Federal Highway Administration’s goal to reduce transportation related fatalities and severe injuries across the transportation system and vision of zero deaths and severe injuries.

Transportation Study Criteria and Guidelines, 2020
The PWD Mobility and Traffic Engineering Division, Community Development Department Advance and Current Planning Divisions, and Transportation Department developed these guidelines for the preparation of transportation studies. The document includes thresholds and criteria for CEQA analysis and supplemental analysis for factors like traffic and transit operations, safety, and parking.

Culver City Bicycle and Pedestrian Action Plan, 2020
Adopted in June 2020, the Culver City Bicycle and Pedestrian Action Plan establishes a long-term vision for improving walking and bicycling in Culver City by updating the previous Bicycle and Pedestrian Master Plan adopted by the City Council in 2010. Like the previous plan, this update seeks to ensure comfortable, safe, and attractive places to hike and walk so that these forms of active transportation become first choices for travelling around the city. The plan’s vision is that “Culver City will be a community where bicycling and walking provide affordable, safe, and healthy mobility options for all residents. New projects and programs will work to enhance multi-modal mobility.” Goals include access and connectivity, healthier and safer communities, affordability, collaboration, and equitability.

The Culver City Municipal Code
Sections of the City’s Municipal Code (CCMC) applicable to transportation include but are not limited to the following:
• Section 7.05.015 (Transportation Demand and Trip Reduction Measures): Prior to issuance of a certificate of occupancy of any new development of 25,000 gross square feet (sf) of floor area or more, the property owner shall make lasting provisions for a bulletin board, display, case, or kiosk displaying transit route, ridesharing, bicycle route, and carpool/vanpool information. Prior to the issuance of a certificate of occupancy of any new development of 50,000 gross sf of floor area or more, not less than 10 percent of the employee parking area shall be located as close as is practical to employee entrances and be reserved for potential carpool or vanpool vehicles. Additionally, preferential parking spaces reserved for employee vanpool services shall be accessible to vanpool vehicles.

Furthermore, bicycle racks or other secure bicycle parking shall also be provided at a rate of

3 City of Culver City, Resolution Adopting 2022-2026 Short Range Mobility Plan, February 28, 2022.

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four spaces for the first 50,000 sf of new development, and one space for each additional 50,000 sf. For projects of 100,000 gross sf of floor area or more, the following shall also be provided: (1) sidewalks or other designated pedestrian pathways following direct and safe routes from the external pedestrian circulation system, vehicle and bicycle parking areas and transit facilities, to each building in the development; (2) if determined necessary by the City to mitigate impacts, bus stop improvements; and (3) a safe and convenient zone in which vanpool and carpool vehicles may deliver or board their passengers. [Note to City:

Please provide input regarding status of TDM Ordinance] • Section 9.04.035 (Construction): All 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
• Section 17.320.020 (Number of Parking Spaces Required): There shall be no minimum required parking for any use, except as may be determined through a Comprehensive Plan.

Any parking provided voluntarily or otherwise, shall comply with the applicable development standards.
• Section 17.320.030 (Accessible Parking): Parking spaces for persons with disabilities shall be provided in compliance with the Uniform Building Code and the Federal Accessibility Guidelines. Accessible parking spaces shall count toward fulfilling the parking requirements of this Chapter.
• Section 17.320.050.B (Loading Area Requirements): Non-residential buildings meeting specified floor area as well as vehicle accessibility criteria shall include on-site loading areas.

4.16.4 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 transportation if the project would:

Threshold TR-1: Conflict with a program, plan, ordinance or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities;
Threshold TR-2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b);
Threshold TR-3: Substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment);
Threshold TR-4: Result in inadequate emergency access.

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Methodology
A memorandum was prepared by Fehr & Peers to evaluate the potential transportation impacts of the Project. The memorandum is provided in Appendix G of this PEIR. The results of the study are incorporated into the below analysis and include a review of consistency with the City’s plans, programs, ordinances, and policies; a VMT analysis; a geometric hazards evaluation; and an evaluation of emergency access. Methodology utilized to determine significance for each topic is described in further detail below.

Project Impact Analysis
Conflict with Adopted Circulation Program, Plan, Ordinance, or Policy Threshold TR-1: The Project would have a significant impact if future development allowed by the 2045 General Plan would conflict with a program, plan, ordinance, or policy addressing the circulation system including transit, roadway, bicycle and pedestrian facilities.

Impact TR-1: The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities.

Therefore, the impact would be less than significant.

Under CEQA, a project is considered consistent with an applicable program, plan, ordinance, or policy if it is consistent with the overall intent of the policy and would not preclude the attainment of its primary goals. This analysis is performed to determine whether the proposed General Plan Update would conflict with an adopted program, policy, plan, or ordinance that is adopted to protect the environment. Any inconsistency with adopted policy is only a significant impact under CEQA if the plan, ordinance, or policy were adopted for the purpose of avoiding or mitigating an environmental effect and if the inconsistency itself would result in a direct physical impact on the environment.

The CEQA thresholds of significance for transportation and traffic impacts have shifted in recent years. In the past, transportation analysis focused on the metric of LOS, which measured congestion at local intersections and roadway segments. The emphasis of these past studies was to ensure that the street grid network functioned well and allowed for efficient movement of vehicles. The current focus is to encourage active transportation (e.g., pedestrians, bicyclists, etc.) and transit, and to limit increases in VMT (see also Impact TR-2 below). This analysis was also conducted with review of the Culver City Short Range Mobility Plan, Bicycle and Pedestrian Action Plan, Complete Streets Policy, and the Local Road Safety Plan.

The Planning Area contains existing non-vehicular transportation, such as pedestrian and bicycle facilities and transit services as detailed above in Section 4.16.2, Environmental Setting.

Implementation of the General Plan Update would improve connections to local and regional transit services (Policy M-2.3) and encourage the use of alternative modes of transportation (Policy M-5.2), including walking and biking through supportive land use development.

The roadway network in Culver City is considerably built out, such that no roadway capacity improvements (lane additions, lane widening, medians) are proposed that would change the

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functional classification of the roadway network. The General Plan Update contains goals and policies in support of the expansion of a multi-modal network (Goal M-5). In addition, the General Plan Update includes policies to install and improve bike lanes (Policy M-2.2) and improve public transportation services (Policy M-4.1).

The General Plan Update would not preclude the implementation of the Short Range Mobility Plan, and would provide complimentary goals, policies, and implementation actions that would include transit improvements (Goal M-3). Additionally, the Mobility Element would support and complement the measures, objectives, and policies in the City’s Bicycle and Pedestrian Action Plan (Policies M-2.1, M-2.2, M-4.4, M-8.5). Further, the Mobility Element places an emphasis on Complete Streets and a layered transportation network consistent with the City’s Complete Streets Policy (Goal M-2). The City’s Local Road Safety Plan (LRSP) establishes a series of goals and objectives to identify high-risk roadways and create continued safety. The Mobility Element would establish the goal of providing a transportation network that is safe and accessible for all travel modes (Goal M-1).

The General Plan Update would enable the City to improve bicycling programs and infrastructure throughout the City, providing connections to the existing and proposed bicycle network. Supporting policies include Policies M-2.1, M-4.4, and M-7.4, which would identify gaps in the existing bicycle network and prioritize multimodal projects, provide additional bicycle parking, and implement bicycle detection at crossing signals. Implementation of the General Plan Update would also enhance pedestrian infrastructure by providing improvements to existing pedestrian facilities, constructing planned pedestrian facilities, and prioritizing pedestrian safety.

New trips and increased VMT may affect the operation of existing transit services or routes.

Several policies and goals included in the Mobility Element address these impacts by balancing the multimodal transportation network to provide alternatives to the automobile, improving transit service connections, and encouraging the use of alternative modes of transportation to minimize the potential for negative effects. The goals and policies in the Mobility Element would be consistent with the City’s existing Short Range Mobility Plan, Bicycle and Pedestrian Action Plan, Complete Streets Policy, and Local Road Safety Plan. Based on the availability of non- vehicular transportation options for the community outlined above and the Mobility goals and policies provided in the General Plan Update, the Project would not conflict with any applicable program, plan, or ordinance on the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and the impact would be less than significant.

Zoning Code Update
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. The Zoning Code Update would not affect the plans, policies, and ordinances related to transportation.

Therefore, the Zoning Code Update would result in a less-than-significant impact.

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

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

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

M-2.3: Transit priority lanes. Evaluate Implementing transit priority lanes and other speed and reliability improvements on roadways meeting transit priority corridor thresholds.

M-2.4: Street space and public realm design. Prioritize allocating street space and public realm designs that advance sustainable transportation, increase safety, expand public space, enhance placemaking, and foster local business activity.

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

M-2.6: Update and maintain street classifications. Reclassify the Roadway Classification table every three to five years based on modal priorities and corresponding land uses to achieve more equitable use of roadway space.

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

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

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

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

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

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

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

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

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

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

M-5.1: 2017 Transit-Oriented Development (TOD) Visioning Study and Recommendations. Continue to implement the 2017 TOD Visioning Study and Recommendations.

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

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

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

M-5.5: Traffic congestion and parking management. Proactively manage traffic congestion and parking at major destinations and job centers.

M-5.6: Off-street parking. Allow flexible approaches to providing off-street parking, including sharing spaces between different uses.

M-5.7: Parking management and dynamic parking strategies. Deploy parking management strategies and explore dynamic parking pricing strategies, like parking rates that fluctuate based on peak parking demands, to manage parking, improve transit-oriented districts, and support the mobility paradigm shift.

M-5.8: Funding sources for multi-modal investment projects. Leverage appropriate and eligible alternative funding sources including the Mobility Improvement Fee and assessment districts to support multimodal projects and mobility services in transit priority areas and transit priority corridors.

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Goal M-7: Technology. New transportation technology is proactively leveraged and managed to achieve equitable access, provide high-quality mobility services, achieve efficient operations, and yield sustainable transportation outcomes.

M-7.1: Emerging mobility. Seek and leverage new transportation technologies that support new forms of transportation or business models while continuing to provide safe and effective mobility services.

M-7.2: Micromobility management. Continue to regulate and manage micromobility within the city and establish strategic partnerships and pilots with the mobility industry and community organizations that increase access to mobility options, including the regional transit network.

M-7.3: Last-mile delivery platforms. Monitor, promote, and regulate the use of sustainable, last-mile delivery technologies and strategies such as micro-distribution hubs, delivery lockers, and smaller-vehicle electric delivery fleets, including cargo bicycles.

M-7.4: Intelligent Transportation System (ITS). Continue to deploy existing and new technologies that help streamline operation protocol to achieve costing-saving and/or high operating efficiency will prioritizing the movements of modes with higher people moving capacity. ITS measures may include transit signal priority to enhance the efficiency of transit vehicles, pedestrian and bicycle detection at signals, and incident management to minimize delay with traffic operations.

M-7.5: Parking and curb management. Continue to deploy advanced parking management techniques, such as the real-time parking information signs in the Downtown area, to make parking more efficient and minimize unnecessary auto traffic circulation. Evaluate and implement performance monitoring and evaluation systems, such as digitizing curbside assets, to dynamically manage evolving curbside demands.

M-7.6: Mobility platforms. Seek and leverage new transportation technologies that aim to improve user experience and encourage the use of alternative modes of transportation including continued investment in online platforms and customer service interface applications that promote and encourage using Culver City mobility services.

M-7.7: Shared mobility data sharing. Require private operators of shared mobility devices to provide real-time information of their vehicles’ availability and parking location.

M-7.8: Equitable mobility technology. Ensure that mobility solutions and technologies are designed and deployed to prioritize equity by reducing barriers to access in disadvantaged communities and Senate Bill 1000 Priority Neighborhoods, with consideration for those residents who may have physical disabilities or other barriers to access.

M-7.9: Caltrans coordination. Continue to coordinate with Caltrans to advance the implementation of congestion management and incident management solutions on I-10 and I-405 to reduce passthrough traffic.

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

M-8.1: Transportation improvements and physical ability. Prioritize transportation investments that provide regular physical activity and access to healthcare and social services, schools, employment, and retail.

M-8.2: Active modes of travel to parks, recreation facilities, open spaces, and trails.

Improve access of active modes of travel to parks, recreation facilities, open space, and trails.

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.

M-8.6: Multimodal project performance. Evaluate multimodal project performance and mode shift after implementation of projects based on Key Performance Indicators.

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 programs, plans, ordinances, or policies addressing the circulation system.

Conflict with CEQA Guideline Section 15064.3, Subdivision (b) Threshold TR-2: The Project would have a significant impact if future development allowed by the 2045 General Plan would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b).

Impact Statement TR-2: The Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b). As there are no feasible mitigation measures, the impact would be significant and unavoidable.

Previously, CEQA analysis for traffic impacts was conducted using the metric of LOS, which measures congestion at local intersections and roadway segments. The emphasis of past studies was to ensure that land use development projects would not hinder acceptable operations of the street network and efficient movement of vehicles. However, in 2013, SB 743 was passed by the California legislature and signed into law by the governor. SB 743 requires that LOS, which measures congestion and vehicle delay, no longer be used as the performance measure for the determination of transportation impacts in studies conducted under CEQA. Instead, VMT is used as the metric for evaluating transportation impacts.

The CEQA thresholds of significance for transportation impacts are intended to encourage the use of active transportation and transit, and to limit increases in VMT. Land development patterns, including the density and mix of land uses, coupled with the accessibility or alternative modes of transportation (e.g., presence of pedestrian and bicycle infrastructure, transit

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services), have a direct effect on the number, and length, of vehicle trips, which determine the amount of VMT generated by a project. 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. As discussed above, Culver City Municipal Code Section

7.05.015, which requires a TDM program, includes measures that aim to reduce the number of vehicle trips that would occur in the City as a result of new development of 25,000 gross square feet or more.

Fehr & Peers conducted a VMT assessment of the entire Culver City, using the Culver City Citywide Travel Demand Forecasting Model to obtain daily vehicle trips, daily VMT, and VMT per capita metrics. The General Plan Update would result in a significant VMT impact if the average daily VMT per Capita, Daily VMT per Employee, and total VMT per service population exceeds 15 percent below the corresponding City Baseline.

Table 4.16-1, General Plan Update Buildout VMT Metrics, demonstrates that at buildout the development resulting from the General Plan Update would result in an average daily VMT per capita, VMT per employee, and total VMT per service population above the 15 percent threshold. As shown in Table 4.16-1, the General Plan Update buildout would represent a

0.95 percent decrease in residential VMT per capita compared to the existing conditions, a

7.26 percent decrease in work VMT per employee compared to existing conditions, and a

3.60 percent increase in total daily VMT per service population. However, the reduction in VMT metrics resulting from the General Plan Update buildout would not be sufficient to be below the 15 percent reduction threshold of significance. Even with implementation of all goals and policies contained in the Mobility Element that would promote transit priority lanes, multimodal connectivity, integrated public transportation services, and prioritize public transit and mobility service such as Policies M-2.3, M-2.5, M-4.1, and M-4.8, the proposed General Plan Update would not meet the 15 percent VMT reduction threshold. Thus, buildout of the General Plan Update would result in significant VMT impacts. There are no feasible mitigation measures available.

TABLE 4.16-1

GENERAL PLAN UPDATE BUILDOUT VMT METRICS
VMT Metrics 2019 City Baseline
2019 City VMT
Threshold
(15% Below 2019
City Baseline) GPU Buildout
Percent Difference –
GPU Buildout vs. 2019
Residential VMT per Capita 8.30 7.06 8.23 -0.95%
Work VMT per Employee 10.12 8.60 9.39 -7.26%
Total Daily VMT per Service
Population

22.45 19.09 23.26 3.60%
SOURCE: Fehr & Peers 2024

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permitted and conditional uses, densities and intensities, setbacks, and heights. As with the General Plan, the Zoning Code Update would locate higher density within proximity of transit and would provide for mixed-use development, which serve to reduce VMT. However, as discussed above, the Project would result in a significant VMT impact. Applicable Proposed General Plan Goals and Policies
Mobility Element
Goal M-3: Transit and other mobility services. Frequent, reliable, and high-quality public transit and mobility services that are adaptable for the dynamic future of mobility needs, markets, and solutions. Travel behavior shifts from driving to more sustainable modes by establishing comprehensive and high-quality mobility service options and infrastructure.

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

M-3.1: Regional mobility coordination. Improve and influence regional mobility service quality and ensure that Culver City community members are connected to regional mobility options and resources by continuing to coordinate with Metro and other municipal mobility service providers.

M-3.2: Mobility funding. Work with regional partners and elected representatives to continually seek regional, state, and federal funding for mobility services and infrastructure.

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

M-3.4: High-quality transit service. Prioritize capital investments and improvements that align with Culver City’s SMRP, regional studies, and LA Metro’s LRTP to enhance transit reliability and rider experience to make transit competitive with driving.

Mitigation Measures
No feasible mitigation measures are available to reduce impacts related to VMT.

Level of Significance after Mitigation
The Project would result in significant and unavoidable impacts related to VMT. No feasible mitigation measures are available to reduce the severity of this impact.

Introduce Incompatible Uses
Threshold TR-3: The Project would have a significant impact if future development allowed by the 2045 General Plan and Zoning Code Update would substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment).

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Impact Statement TR-3: The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses (e.g., farm equipment) and impacts would be less than significant.

The General Plan Update does not specify design features for the transportation system in the Planning Area and would thus not substantially increase hazards due to a design feature.

Impacts regarding the potential increase of hazards due to a geometric design feature generally relate to the design of access points to and from the Planning Area and may include safety, operational, or capacity impacts that must be assessed. Given the programmatic nature of the Project, these are evaluated at the program/citywide level.

The land use diagram and policies contained in the General Plan Update emphasize transition areas and buffers between land uses of varying intensity, which would serve to reduce potential conflicts between users of the transportation system connected with each land use, including commercial and industrial truck traffic, commute traffic, pedestrians, and cyclists. The specific design and operations of individual future development projects are unknown at this time; however, policies included in the General Plan Update would serve to reduce potential impacts from future development.

Access locations for development allowed under the General Plan Update would be designed to the City’s standards and would provide adequate sight distance, sidewalks, crosswalks, and pedestrian movement controls to meet the City’s requirements to protect pedestrian safety.

The installation of street trees and other potential impediments to adequate driver and pedestrian visibility in the public right-of-way would require review for sight distance and be designed to City standards and best practices to avoid obstructions. Pedestrian entrances separated from vehicular driveways would provide access from the adjacent streets. The General Plan Update has been developed with an emphasis on multi-modal street networks, which would improve compatibility between different transportations modes and between the transportation system and adjacent land uses. Proposed policies that promote bicycle and pedestrian safety would help identify and address potential safety concerns. Additionally, the General Plan Update would advance strategies for thoughtful infill development, which would itself provide safety benefits by reducing motor vehicle collision exposure, lowering speeds, and increasing pedestrian and cyclist volumes.

The various goals and policies contained within the Mobility Element are designed to address transportation safety, improve circulation, implement transportation projects, and advance current City plans, policies, programs, and ordinances. The transportation projects included in the Mobility Element are envisioned to improve mobility, safety, and access, and thus would be designed to applicable federal, state, and City Engineering Design Standards or other applicable roadway standards. As a result, the General Plan Update would not substantially increase hazards due to a geometric design feature or incompatible use, and this impact is considered less than significant.

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Zoning Code Update
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. The Zoning Code Update would not amend the City’s standards or review processes regarding sight distance, sidewalk widths, crosswalks, or movement controls related to transportation.

Therefore, impacts related to hazardous conditions would be less than significant.

Applicable Proposed General Plan Goals and Policies
Mobility Element
Goal M-1: Safety. A transportation network that is safe and accessible for all travel modes and people of all ages, physical abilities, and financial means.

M-1.1: Safe systems approach. Implement strategies to reduce severe and fatal traffic collisions and improve overall traffic safety conditions.

M-1.2: Priority Safety Corridors. Maintain regular updates every three to five years to the Local Road Safety Plan (LRSP) that identifies a High Injury Network (HIN), also identified as Priority Safety Corridors, and location-specific safety improvements.

M-1.3: Improve transportation network safety. Design transportation network improvements with the most vulnerable users in mind to ensure the transportation network is accessible to all travelers regardless of age, race, gender, or ability.

M-1.4: Safe travel programs. Implement programs that increase awareness of safe travel practices.

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 conditions.

Result in Inadequate Emergency Access
Threshold TR-4: The Project would have a significant impact if future development allowed by the Project would result in inadequate emergency access.

Impact Statement TR-4: The Project would not result in inadequate emergency access and impacts would be less than significant.

The General Plan Update applies citywide and is a programmatic document. Emergency accessibility is typically assessed at a project level. Project-level review required by the City includes site access review for emergency vehicles and traffic control plans that account for emergency vehicles. As stated above, future development under the proposed General Plan update would be compliant with the City’s design guidelines that incorporate safety and emergency access needs, where applicable. The City’s development review process would

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assure that future development under the General Plan Update would be consistent with these policies and would not hinder emergency access for individual sites. For these reasons, the General Plan Update would not result in inadequate emergency access, and this impact is considered less than significant.

Zoning Code Update
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. The Zoning Code Update would not amend the City’s design guidelines that incorporate safety and emergency access needs nor the review processes. Therefore, impacts related to emergency access would be less than significant.

Applicable Proposed General Plan Goals and Policies
There are no applicable proposed General Plan Goals or Policies that relate to emergency access.

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 emergency access.

4.16.5 Cumulative Impacts Analysis
By nature, the transportation analysis presented above represents a cumulative analysis of transportation conditions through 2045. Cumulative impacts are determined through consistency with the SCAG RTP/SCS, in that a Plan must demonstrate compliance with air quality conformity requirements and GHG reduction targets. The General Plan Update buildout reallocates population and employment growth and reflects a greater amount of service population overall than is assumed in the SCAG RTP/SCS in the city area, and therefore requires a cumulative impact analysis comparing the cumulative “no project” scenario, i.e., the existing conditions, representing RTP/SCS cumulative year conditions, to the cumulative “plus project” scenario, i.e., General Plan Update buildout scenario representing reallocation of the population/employment growth associated with implementation of the General Plan Update in the city area.

The General Plan Update would have a cumulative impact if average daily VMT per capita and VMT per employee at buildout would exceed the corresponding VMT metrics, and if total VMT would exceed the total VMT for the existing conditions. The daily VMT per capita, per employee, and per service population for the existing conditions and buildout of the General Plan Update demonstrate that all the VMT metrics are lower in the General Plan Update buildout scenario than the existing conditions, indicating that the General Plan Update buildout scenario has no cumulative impact on VMT. As shown in Table 4.16-2, Cumulative VMT Metrics, the General Plan Update buildout would represent a 4.26 percent decrease in residential VMT per capita compared to the existing conditions, a 4.59 percent decrease in work VMT per employee

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compared to the existing conditions, and a 6.39 percent decrease in total daily VMT per service population. The resulting cumulative VMT impact would be less than significant, as shown in Table 4.16-2.

TABLE 4.16-2

CUMULATIVE VMT METRICS
VMT Metrics
General Plan Update
Baseline
General Plan Update
Buildout
Percent Difference –
Buildout vs. Baseline
Residential VMT per Capita 8.59 8.23 -4.26%
Work VMT per Employee 9.84 9.39 -4.59%
Total Daily VMT per Service Population 24.85 23.26 -6.39% SOURCE: Fehr & Peers 2024

It is possible that traffic generated by future development in the region could conflict with a program, plan, ordinance, or policy addressing the circulation system, thus resulting in a potentially significant cumulative impact. However, given the Project’s consistency with the various local, regional, and state regulatory frameworks that are in place, the Project’s contribution to this cumulative impact would not be cumulatively considerable.

Additionally, it is possible that traffic generated by future development in the region could substantially increase hazards due to a geometric design feature or incompatible use, thus resulting in a potentially significant cumulative impact. The General Plan Update includes policies which emphasize transition areas and buffers between land uses of varying intensity, which would serve to reduce potential conflicts between users of the transportation system connected with each land use. The General Plan Update has also been developed with an emphasis on multi-modal street networks which would improve compatibility between different transportation modes and address potential safety concerns. As described above, future development under the Project would be compliant with the City’s design guidelines where applicable. The Project’s contribution to this impact would not be cumulatively considerable.

The Project would result in less-than-significant cumulative impacts related to transportation.

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4.17 Tribal Cultural Resources

4.17.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on tribal cultural resources from future development allowed under the Project. The section provides context regarding the Planning Area’s ethnographic setting and includes results of a Sacred Lands File (SLF) search and the city’s consultation with the Native American community pursuant to Assembly Bill (AB) 52 and Senate Bill (SB) 18.

4.17.2 Environmental Setting
Ethnographic Setting – The Gabrielino
The Planning Area is in a region traditionally occupied by Indigenous Peoples. Groups of Indigenous Peoples of Los Angeles include Gabrieleño, Gabrielino, Tongva, and Kizh. “Gabrielino” and “Gabrieleño” are Spanish names deriving from the San Gabriel Mission. “Tongva” was likely a Native village in the same vicinity. The name the Indigenous Peoples may have originally called themselves is “Kizh,” meaning home. 1 However, there is pan-tribal name
for LA’s Indigenous Peoples that predates the arrival of Europeans.2 For this report, the term “Gabrielino” will be used, in keeping with the state-recognized name of San Gabriel Band of Mission Indians.

Their neighbors included the Chumash and Tataviam to the north, the Juañeno to the south, and the Serrano and Cahuilla to the east. The Gabrielino are reported to have been second only to the Chumash in terms of population size and regional influence. 3 The Gabrielino language is part
of the Takic branch of the Uto-Aztecan language family.

At the time of Spanish contact, many Gabrielino practiced a religion that was centered around the mythological figure Chinigchinich.
4 This religion may have been relatively new when the
Spanish arrived, and was spreading at that time to other neighboring Takic groups. The Gabrielino practiced both cremation and inhumation
5 of their dead. A wide variety of grave
offerings, such as stone tools, baskets, shell beads, projectile points, bone and shell ornaments, and otter skins, were interred with the deceased.

Coming ashore on Santa Catalina Island in October 1542, Juan Rodriguez Cabrillo was the first European to make contact with the Gabrielino; the 1769 expedition of Portolá also passed

1 Stickel, Gary E., PhD. 2016. Why the Original Indian Tribe of the Greater Los Angeles Area is Called Kizh not Tongva. Available at: https://www.cpp.edu/~tgyoung/Pom_Parks/Kizh%20not%20Tongva_9-27-17.pdf. 2 Los Angeles Almanac. January 2, 2019. Original Settlers of Los Angeles. Available at:
http://www.laalmanac.com/history/hi03c.php.
3 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 4 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 5 Inhumation is the action of burying the corpse of the dead (as opposed to cremating the remains).

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through Gabrielino territory.6 Native Americans suffered severe depopulation, and their traditional culture was radically altered after Spanish contact. Nonetheless, Gabrielino descendants still reside in the greater Los Angeles and Orange County areas and maintain an active interest in their heritage.

A Gabrielino village, or “rancheria,” known as Guaspet, Guasna, Guashna, Guachpet, Guashpet, and Guaspita, appears to have been located southwest of the city. Based on mission baptism records, the rancheria appears to have been occupied from about 1790 to 1820. 7,8 At least 193
people are known to have lived at the rancheria and been baptized. Records suggest that recruitment into the mission system did not occur until native populations in closer proximity to Mission San Gabriel had been assimilated, and after grazing expanded into the vicinity of the Planning Area, bringing native inhabitants of the region into closer contact with Spanish-era ranchers.
9 Two archaeological sites with components dating to the Spanish era (CA-LAN-62 and -211), located within about 2 miles from the city, may be the location of Guaspet, although this has not been confirmed in the historical record.10
Sacred Lands File Search
The California Native American Heritage Commission (NAHC) maintains a confidential SLF that contains sites of traditional, cultural, or religious value to the Native American community. The NAHC was contacted on October 15, 2019, to request a search of the SLF. The NAHC responded to the request in a letter dated October 24, 2019, indicating that the results were positive and contact the Gabrielino Tongva Indians of California Tribal Council for more information (see Appendix G of this Draft PEIR).

Native American Consultation
Assembly Bill 52 and Senate Bill 18
On March 2, 2022, the city submitted notification and request to consult letters to seven individuals and organizations pursuant to AB 52. On March 2, 2022, the city also submitted notification and request to consult letters to seven individuals and organizations pursuant to SB 18. In particular, AB 52 and SB 18 letters were sent via certified mail to the following California Native American tribes and individuals:
• Sandonne Goad, Gabrielino/Tongva Nation
• Charles Alvarez, Gabrielino-Tongva Tribe
• Andrew Salas, Gabrieleño Band of Mission Indians— Kizh Nation

6 Bean, L.J., and C.R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538–549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C. 7 Reedy, Seetha N. 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pp. 48–66. 8 McCawley, William, 1996. The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press, Morongo Indian Reservation.
9 Stoll, Anne Q., John G. Douglass, and Richard Ciolek-Torrello. 2009. Searching for Guaspet: A Mission Period Rancheria in West Los Angeles. SCA Proceedings, Vol. 22. 10 Reedy, Seetha N. 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pp. 48–66.

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• Robert Dorame, Gabrielino Tongva Indians of California Tribal Council • Anthony Morales, Gabrielino/Tongva San Gabriel Band of Mission Indians • Scott Cozart, Soboba Band of Luiseño Indians
• Lovina Redner, Santa Rosa Band of Cahuilla Indians
On March 4, 2022, the city received a response from the Gabrieleño Band of Mission Indians – Kizh Nation (Kizh Nation). The Kizh Nation indicated they are in agreement with the General Plan update; however, if there will be ground disturbance for any or all of the future projects, they would like to request consultation. To date, no other responses from the Native American community have been received as part of the AB 52 nor SB 18 tribal consultation effort. The AB 52 and SB 18 Native American consultation documentation is provided in Appendix H of this Draft PEIR.

4.17.3 Regulatory Framework
This section provides the relevant state regulations applicable to the Project. There are no federal, regional, or local regulations which apply to the Project.

State
Assembly Bill 52
AB 52 was approved on September 25, 2014. The act amended California Public Resources Code (PRC) Section 5097.94, and added PRC Sections 21073, 21074, 21080.3.1, 21080.3.2, 21082.3, 21083.09, 21084.2, and 21084.3. The primary intent of AB 52 is to involve California Native American Tribes early in the environmental review process and to establish a category of resources related to Native Americans, known as tribal cultural resources, that require consideration under the California Environmental Quality Act (CEQA). PRC Section 21074(a)(1) and (2) defines tribal cultural resources as “sites, features, places, cultural landscapes, sacred places, and objects with cultural value to a California Native American Tribe” that are either included or determined to be eligible for inclusion in the California Register or included in a local register of historical resources, or a resource that is determined to be a tribal cultural resource by a lead agency, in its discretion and supported by substantial evidence. A tribal cultural resource is further defined by PRC Section 20174(b) as a cultural landscape that meets the criteria of subdivision (a) to the extent that the landscape is geographically defined in terms of the size and scope of the landscape. PRC Section 20174(c) provides that a historical resource described in Section 21084.1, a unique archaeological resource as defined in subdivision (g) of Section 21083.2, or a “nonunique archaeological resource” as defined in subdivision (h) of Section 21083.2 may also be a tribal cultural resource if it conforms with the criteria of subdivision (a).

PRC Section 21080.3.1 requires that, within 14 days of a lead agency determining that an application for a project is complete, or a decision by a public agency to undertake a project, the lead agency provide formal notification to the designated contact, or a tribal representative, of California Native American Tribes that are traditionally and culturally affiliated with the geographic area of the project (as defined in PRC Section 21073) and who have requested in

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writing to be informed by the lead agency of projects within their geographic area of concern. 11 Tribes interested in consultation must respond in writing within 30 days from receipt of the lead agency’s formal notification and the lead agency must begin consultation within 30 days of receiving the tribe’s request for consultation.12
PRC Section 21080.3.2(a) identifies the following as potential consultation discussion topics: the type of environmental review necessary; the significance of tribal cultural resources; the significance of the project’s impacts on the tribal cultural resources; project alternatives or appropriate measures for preservation; and mitigation measures. Consultation is considered concluded when either (1) the parties agree to measures to mitigate or avoid a significant effect, if a significant effect exists, on a tribal cultural resource; or (2) a party, acting in good faith and after reasonable effort, concludes that mutual agreement cannot be reached. 13 In addition to other CEQA provisions, the lead agency may certify an environmental impact report or adopt a mitigated negative declaration for a project with a significant impact on an identified tribal cultural resource, only if a California Native American tribe has requested consultation pursuant to Section 21080.3.1 and has failed to provide comments to the lead agency, or requested a consultation but failed to engage in the consultation process, or the consultation process occurred and was concluded as described above, or if the California Native American tribe did not request consultation within 30 days. 14 PRC Section 21082.3(c)(1) states that any information, including, but not limited to, the location, description, and use of the tribal cultural resources, that is submitted by a California Native American tribe during the environmental review process shall not be included in the environmental document or otherwise disclosed by the lead agency or any other public agency to the public without the prior consent of the tribe that provided the information. If the lead agency publishes any information submitted by a California Native American tribe during the consultation or environmental review process, that information shall be published in a confidential appendix to the environmental document unless the tribe that provided the information consents, in writing, to the disclosure of some or all of the information to the public.

Confidentiality does not apply to data or information that are, or become, publicly available, are already in lawful possession of the applicant before the provision of the information by the California Native American tribe, are independently developed by the applicant or the applicant’s agents, or are lawfully obtained by the applicant from a third party that is not the lead agency, a California Native American tribe, or another public agency. 15 Senate Bill 18
SB 18 (Statutes of 2004, Chapter 905), which went into effect January 1, 2005, requires local governments (city and county) to consult with Native American tribes before making certain

11 Public Resources Code, Section 21080.3.1(b) and (c). 12 Public Resources Code, Sections 21080.3.1(d) and 21080.3.1(e) 13 Public Resources Code, Section 21080.3.2(b)
14 Public Resources Code, Section 21082.3(d)(2) and (3) 15 Public Resources Code, Section 21082.3(c)(2)(B).

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planning decisions and to provide notice to tribes at certain key points in the planning process.

The intent is to “provide California Native American tribes an opportunity to participate in local land use decisions at an early planning stage, for the purpose of protecting, or mitigating impacts to, cultural places.”
16 The purpose of involving tribes at these early planning stages is to allow consideration of cultural places in the context of broad local land use policy, before individual site-specific, project-level, land use designations are made by a local government. The consultation requirements of SB 18 apply to general plan or specific plan processes proposed on or after March 1, 2005.

According to the Tribal Consultation Guidelines: Supplement to General Plan Guidelines, the following are the contact and notification responsibilities of local governments:
17 • Prior to the adoption or any amendment of a general plan or specific plan, a local government must notify the appropriate tribes (on the contact list maintained by the NAHC) of the opportunity to conduct consultations for the purpose of preserving, or mitigating impacts to, cultural places located on land within the local government’s jurisdiction that is affected by the proposed plan adoption or amendment. Tribes have 90 days from the date on which they receive notification to request consultation, unless a shorter timeframe has been agreed to by the tribe (Government Code Section 65352.3). • Prior to the adoption or substantial amendment of a general plan or specific plan, a local government must refer the proposed action to those tribes that are on the NAHC contact list and have traditional lands located within the city or county’s jurisdiction. The referral must allow a 45-day comment period (Government Code Section 65352). Notice must be sent regardless of whether prior consultation has taken place. Such notice does not initiate a new consultation process.

Local government must send a notice of a public hearing, at least 10 days prior to the hearing, to tribes who have filed a written request for such notice (Government Code Section 65092).

4.17.4 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 tribal cultural resources if the project would:

Threshold TCR-1: Cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the

16 Governor’s Office of Planning and Research. 2005. Tribal Consultation Guidelines: Supplement to General Plan Guidelines.
17 Governor’s Office of Planning and Research. 2005. Tribal Consultation Guidelines: Supplement to General Plan Guidelines.

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landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in the local register of historical resources as defined in Public Resources. Code
Section 5020.1(k).
ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code
Section 5024.1, the lead agency shall consider the
significance of the resource to a California Native American tribe.

Methodology
The analysis is based on a SLF search conducted by the NAHC and consultation between the city and Native American groups pursuant to AB 52 and SB 18. Specifically, the city submitted notification and request to consult letters to Native American individuals and organizations and conducted follow-up Native American consultation.

Project Impact Analysis
Tribal Cultural Resource Significance
Threshold TCR-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would cause a substantial adverse change in the significance of a tribal cultural resource, defined in Public Resources Code section 21074 as either a site, feature, place, cultural landscape that is geographically defined in terms of the size and scope of the landscape, sacred place, or object with cultural value to a California Native American tribe, and that is:
i. Listed or eligible for listing in the California Register of Historical Resources, or in the local register of historical resources as defined in Public Resources. Code Section 5020.1(k); or ii. A resource determined by the lead agency, in its discretion and supported by substantial evidence, to be significant pursuant to criteria set forth in subdivision (c) of Public Resources Code Section 5024.1. In applying the criteria set forth in subdivision (c) of Public Resource Code Section 5024.1, the lead agency shall consider the significance of the resource to a California Native American tribe.

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

The City submitted notification and request to consult letters pursuant to AB 52 and SB 18 to seven Native American individuals and organizations on March 2, 2022. The City received one response from the Kizh Nation indicating that they are in agreement with the General Plan Update; however, they also indicated that they would like to request consultation if there would be ground disturbance occurring for any and all future projects within the Planning Area.

As discussed in Section 4.4, Cultural Resources, of this Draft PEIR, there are 12 known prehistoric archaeological resources that have been previously identified within the Planning Area, one of which is a multicomponent resource. None of these resources have been evaluated as potential tribal cultural resources. The NAHC has indicated that the SLF results were positive and identified one resource in their database. The NAHC recommended that the City contact the Gabrielino Tongva Indians of California Tribal Council for more information on this particular resource.

Furthermore, some existing improvements within the city (e.g., roads, buildings, structures, etc.) were likely constructed prior to the existence of cultural resources protection laws and may have been built on tribal cultural resources; therefore, the current or prior existence of development throughout the city does not preclude the presence of tribal cultural resources located underneath this development.

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

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

Implementation of the General Plan Update may facilitate future development that would include ground-disturbance activities (e.g., excavation, trenching, boring, grading, drilling, demolition, clearing/grubbing, etc.), which have the potential to cause a substantial adverse change to tribal cultural resources. Specifically, anticipated development in the Planning Area would occur through infill development on vacant property, and through redevelopment, which could result in damage to tribal cultural resources. In addition, infrastructure improvements, such as storm water quality projects, and other improvements needed to support the projected growth and development from implementation of the General Plan Update that require ground disturbance could result in damage to or destruction of tribal cultural resources buried below the ground surface. Future development that results in changes to the setting through incompatible adjacent construction or facilitates public access to culturally significant sites could result in additional impacts to tribal cultural resources.

4. Environmental Impact Analysis

4.17. Tribal Cultural Resources
General Plan 2045 and Zoning Code Update Project 4.17-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
In summary, no tribal cultural resources have been identified within or adjacent to the Planning Area. However, there are unevaluated prehistoric resources within the Planning Area that could be potential tribal cultural resources and, given the prehistoric occupation of the area, it is possible that future development within the Planning Area may result in the identification of unrecorded tribal cultural resources. However, future projects would be required to comply with the provisions of SB 18 and AB 52, as necessary, to incorporate tribal consultation into the review process to ensure that tribal cultural resources are properly identified and that mitigation measures are identified to reduce impacts on these resources. General Plan Policy C-1.16 also reinforces the continuation of consultation with Native American groups per the requirements of SB 18 and AB 52. Furthermore, the City would continue to implement standard conditions of approval that require and specify the steps to be taken to avoid damage and promote preservation if tribal cultural resource are uncovered during construction in support of the City’s goals for protection of cultural resources. Adherence to the regulations and implementation of proposed General Plan policies and implementation actions would ensure that the Project’s impact with respect to tribal cultural resources would be less than significant.

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

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

C-1.16: Tribal Consultation. Continue to consult with Native American groups in accordance with Senate Bill 18 and Assembly Bill 52 to identify Tribal Cultural Resources.

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

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

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

Mitigation Measures
No mitigation measures are required.

Level of Significance after Mitigation
Not applicable. The Project would result in less-than-significant impacts related to tribal cultural resources.

4.17.5 Cumulative Impacts Analysis
The geographic context for the analysis of impacts related to tribal cultural resources is generally site-specific, rather than cumulative in nature, because each development site has unique tribal cultural considerations. In this way, potential cumulative impacts relating to tribal cultural resources would be minimized on a site-by-site basis to the extent that appropriate

4. Environmental Impact Analysis

4.17. Tribal Cultural Resources
General Plan 2045 and Zoning Code Update Project 4.17-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
consultation is conducted. Future development within the Planning Area and the larger Los Angeles County region, including growth anticipated through implementation of the General Plan Update, could result in a substantial adverse change in the significance of tribal cultural resources, thus resulting in a potentially significant cumulative impact. All future development in the Planning Area and surrounding region, would be required to comply with SB 18 and AB 52 consultation, which would ensure that tribal cultural resources are properly identified and that mitigation measures are identified to reduce impacts on these resources. For this reason, the Project’s contribution to this potentially significant cumulative impact would not be cumulatively considerable.

4. Environmental Impact Analysis

4.17. Tribal Cultural Resources
General Plan 2045 and Zoning Code Update Project 4.17-10 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 4.18-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.18 Utilities and Service Systems

4.18.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on utilities and service systems from implementation of the Project, including potential impacts related to water supplies and infrastructure, wastewater treatment (capacity and infrastructure), stormwater drainage, electric power, natural gas, or telecommunications facilities, and solid waste capacity and regulations. The section provides context regarding the Planning Area’s existing water, wastewater, solid waste, electricity, natural gas, and telecommunication services, as well as relevant federal, state, and local regulations and programs.

4.18.2 Environmental Setting
Potable Water Systems
Water Service
The Planning Area’s water service is provided by the Golden State Water Company (GSWC) and Los Angeles Department of Water and Power (LADWP). The two independently-operated systems are interconnected and provide the ability to share water between them if necessary.

GSWC serves the majority of Culver City and LADWP serves the western portion of the Planning Area. GSWC serves the connections east of Mclaughlin Avenue, while LADWP serves the connections west of Mclaughlin Avenue.

Water Distribution Network
Both GSWC and LADWP main water lines (12-inch diameter and greater) are located within the Planning Area. As indicated above in Water Service, Mclaughlin Avenue demarcates the service areas, with LADWP serving the west side and GSWC serving most of the Planning Area to the east. As the primary provider to the Planning Area, the GSWC system currently serves more than 9,200 connections, distributing approximately 5,000 acre-feet (AF) of potable water annually.1 Water distribution services in the Planning Area encompass potable pipeline networks, storage, and fire water access. The Planning Area’s fire hydrant and water storage tank network provides fire protection and includes three water storage tanks within the Baldwin Hills Scenic Overlook area. Operating and maintaining independently owned systems and upgrading the system ensures the infrastructure can support additional demand. Neither water agency serving the Planning Area has reported any operating capacity issues.

Supply
Regionally, LADWP's supply is from both imported and local water sources, including the Los Angeles Aqueduct, local groundwater, and the Metropolitan Water District of Southern California (Metropolitan). GSWC purchases its water from the West Basin Municipal Water District (WBMWD), a large water purveyor that imports its water supply from Metropolitan. The Metropolitan water supply comes from the Colorado River Aqueduct and the State Water

1 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.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Project (SWP) (California Aqueduct). GSWC has not relied upon groundwater to serve Culver City in recent years. From 2016 to 2019, no groundwater was used to serve GSWC customers in Culver City, and in 2020, GSWC pumped approximately 0.1 AF of groundwater from the Santa Monica Subbasin (California Department of Water Resources [DWR] Basin No. 4-011.01).

Nevertheless, GSWC maintains a single groundwater well, the Sentney well, in the Planning Area and may institute potential service from the Santa Monica Basin in the future upon completion of the Santa Monica Basin Groundwater Sustainability Plan (GSP) and implementing actions. 2 In
addition, initiatives such as the One Water LA 2040 Plan are in place to reduce dependency on imported water and use alternate sources, such as recycled water systems, groundwater recharge, and upgraded treatment processes.

Once LADWP and GSWC acquire its water, the water goes through a treatment and distribution process to connect to Culver City residents and businesses. GSWC issues annual water quality consumer confidence reports to provide information on local water quality. 3 Metropolitan and
WBMWD treat the water after importing it and before distributing it to the Culver City system through three Metropolitan West Basin (WB) connections-WB-23, WB-24, and WB-34. Each of the connections have maximum capacities of 9,000 gallons per minute (gpm), 9,000 gpm, and 4,500 gpm, respectively. Four reservoirs that have a total capacity of 2.7 million gallons feed the system.

Demand
To operate effectively, Culver City's water infrastructure must meet current and projected future demand. Evaluating historical and current water usage helps inform future projections.

Southern California Association of Governments (SCAG) publishes population, employment, and housing data and a methodology to extrapolate growth projections from historical data sets.

GSWC follows SCAG's forecasting processes to estimate future water demands in Culver City.

The SCAG-based water use projections are based on the population and housing growth rates.

Household projections are used to determine growth in single- and multi-family service connections, while employment growth projections are used to determine growth in commercial, industrial, institutional, landscape and other service connections. Based on GSWC historical water use data, most water demand in Culver City is attributed to residential activity followed by commercial, industrial, public/institutional, and landscaping. 4 Although Culver City is implementing measures to decrease its water use and trends depict decreased water use, population and housing growth may counter this trend. GSWC provides

2 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. 3 Golden State Water Company, 2020. Culver City Water System Consumer Confidence Report on Water Quality for 2019. https://www.gswater.com/sites/main/files/file-attachments/water-quality-2019-culver- city.pdf?1591302565. Accessed March 2023.
4 Culver City, 2017. Water Supply Assessment Culver Studios Innovation Plan. Prepared by GSWC. https://culvercity.prelive.opencities.com/files/assets/public/documents/planning-amp-development/current- projects/culver-studios/appendixmwatersupplyreport.pdf. Accessed April 2023.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
most of Culver City's water, which declined by 4.8 percent between 2016 and 2020.5 This decline may be the result of the implementation of tiered water rates, plumbing code updates, economic downturn, and statewide drought.

State and local legislation requires Culver City to reduce its water use. Senate Bill (SB) X7-7, The Water Conservation Act of 2009, requires a 20 percent reduction in urban per capita water use across the state by December 31, 2020. Retail water suppliers were required to report existing baseline water usage and set targets for reduction. Also, LADWP must meet the conservation goals established in response to the multi-year California drought as outlined in the state's Executive Directive No. 5 (ED5) and Sustainable City Plan (pLAn) water conservation measures.

These measures require reducing per capita potable use by 22.5 percent by 2025 and 25 percent by 2035, reducing imported water purchases from the Metropolitan Water District of Southern California (MWD) by 50 percent by 2025, and expanding all local sources of water so that they account for at least 50 percent of the total supply by 2035. Culver City's Water Conservation Plan encourages residents to conserve water and imposes mandatory water use restrictions on LADWP and GSWC's business and residential customers.
6 As presented in GSWC’s 2020 UWMP, the Culver City service area is currently using 116 gallons of water per capita per day (GPCD).
7 LADWP serves the western portion of the Planning Area and provides its customers with a combination of imported and local water sources, including the Los Angeles Aqueduct, local groundwater, and Metropolitan. As presented in LADWP’s 2020 UWMP, the LADWP service area is currently using 106 GPCD. 8 GSWC’s projected demands for potable and non-potable use within the Culver City service area are shown in Table 4.18-1, Culver City Service Area Total Projected Water Demand, and LADWP’s projected demands for potable and non-potable use are shown in Table 4.18-2, LADWP Total Projected Water Demand.

5 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. 6 Culver City, 2015. Water Conservation Plan for Fiscal Year 2015/2016, 2015. https://www.culvercity.org/files/assets/public/documents/building-development/city- documents/culvercitywaterconservatio.pdf. Accessed April 2023. 7 Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed August 2023. 8 Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan. May 2021. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F9314518570%2F1.%20LADWP %202020%20UWMP.pdf. Accessed April 2023.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-1

CULVER CITY SERVICE AREA TOTAL PROJECTED WATER DEMAND
Use Type
Projected Water Use (AF)
2025 2030 2035 2040 2045
Single Family 1,508 1,514 1,520 1,525 1,531
Multi-Family 1,051 1,064 1,077 1,090 1,103
Commercial/Institutional 1,897 1,933 1,969 2,006 2,044
Industrial 156 159 161 164 166
Landscape 142 165 192 223 259
Other 0 0 0 0 0
Losses 247 251 256 260 265
Total 5,002 5,086 5,175 5,269 5,370
NOTES: AF = acre-feet
SOURCE: Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area, Table 4-6, Projected Water Demands.

TABLE 4.18-2

LADWP TOTAL PROJECTED WATER DEMAND
Use Type
Projected Water Use (AF)
2025 2030 2035 2040 2045
Single Family 228,529 233,366 237,297 242,761 246,779
Multi-Family 192,727 205,728 219,798 233,602 244,853
Commercial/Government 156,407 157,341 158,236 159,030 157,680 Industrial 13,651 12,902 12,171 11,418 10,503
Non-Revenue Water 51,321 50,826 51,334 51,026 50,687
Additional Conservation Savingsa 133,133 133,506 142,688 143,351 144,752 Total 509,501 526,658 536,148 554,486 565,751
NOTE: AF = acre-feet
a Additional Conservation Savings includes projected future active and passive savings and additional retained passive savings.

SOURCE: Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan, Exhibit 2M, LADWP Water Demand Projections by Sector.

Water purchased from WBMWD constitutes the primary source of supply for the GSWC Culver City service area, and is expected to be the sole source of supply within the 2045 planning horizon.

The total projected potable supplies for the GSWC Culver City service area for normal, single dry, and multiple dry years are presented in Table 4.18-3, Projected Normal Year Water Supply and Demand for Culver City Service Area; Table 4.18-4, Single Dry Year Water Supply and Demand for Culver City Service Area; and Table 4.18-5, Five Consecutive Dry Years Water Supply and Demand through 2045 for Culver City Service Area, respectively. As shown in the tables, GSWC has sufficient supplies to meet demand in normal, single dry, and multiple dry years without shortages through 2045.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-3

PROJECTED NORMAL YEAR WATER SUPPLY AND DEMAND FOR CULVER CITY SERVICE AREA Supply/Demand
Projected Water Use (AF)
2025 2030 2035 2040 2045
Supply Totals 5,002 5,086 5,175 5,269 5,370
Demand Totals 5,002 5,086 5,175 5,269 5,370
Difference 0 0 0 0 0
NOTES: AF = acre-feet
SOURCE: Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area, Table 5-2, Normal and Single Dry Year Water Supply and Demand through 2045 (values in acre-feet).

TABLE 4.18-4

SINGLE DRY YEAR WATER SUPPLY AND DEMAND FOR CULVER CITY SERVICE AREA Supply/Demand
Projected Water Use (AF)
2025 2030 2035 2040 2045
Supply Totals 5,502 5,594 5,692 5,796 5,907
Demand Totals 5,502 5,594 5,692 5,796 5,907
Difference 0 0 0 0 0
NOTES: AF = acre-feet
SOURCE: Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area, Table 5-2, Normal and Single Dry Year Water Supply and Demand through 2045 (values in acre-feet).

The WBMWD 2020 UWMP states that it will be able to serve 100 percent of projected demands in normal, single dry and multiple dry years. As such, GSWC expects that under all hydrologic conditions purchased water supplies will fully meet future purchased water demands.

Therefore, consistent with the Culver City service area 2020 UWMP, the available supplies to the GSWC Culver City service area are considered to be equal to demands under all conditions (i.e., current and projected, and for normal, single dry, and multiple dry years including a five-year drought period).

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-5
FIVE CONSECUTIVE DRY YEARS WATER SUPPLY AND DEMAND THROUGH 2045 FOR

CULVER CITY SERVICE AREA
Supply/Demand
Projected Water Use (AF)
2025 2030 2035 2040 2045
First Year
Supply Totals 5,502 5,594 5,692 5,796 5,907
Demand Totals 5,502 5,594 5,692 5,796 5,907
Difference 0 0 0 0 0
Second Year
Supply Totals 5,520 5,613 5,712 5,817 5,907
Demand Totals 5,520 5,613 5,712 5,817 5,907
Difference 0 0 0 0 0
Third Year
Supply Totals 5,538 5,633 5,733 5,839 5,907
Demand Totals 5,538 5,633 5,733 5,839 5,907
Difference 0 0 0 0 0
Fourth Year
Supply Totals 5,557 5,652 5,754 5,862 5,907
Demand Totals 5,557 5,652 5,754 5,862 5,907
Difference 0 0 0 0 0
Fifth Year
Supply Totals 5,575 5,672 5,775 5,884 5,907
Demand Totals 5,575 5,672 5,775 5,884 5,907
Difference 0 0 0 0 0
NOTES: AF = acre-feet
SOURCE: Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area, Table 5-3, Five Consecutive Dry Years Water Supply and Demand through 2045 (values in acre-feet).

LADWP’s 2020 UWMP provides water supply and demand projections in 5-year increments to 2045 for average year, single dry year, and multiple dry years; refer to Table 4.18-6, LADWP Service Area Reliability Assessment for Average Weather Year, Table 4.18-7, LADWP Service Area Reliability Assessment for Single Dry Year, and Table 4.18-8, LADWP Service Area Reliability Assessment for Multiple Dry Years (Year 5 of 5). Table 4.18-8, which shows multiple years, is based on historic conditions that occurred between 1988 and 1992, with Year 5 (1992) presenting the worst-case conditions when supplies would be at their lowest. These tables show that LADWP can provide reliable water supplies under all three hydrologic scenarios through the 25-year planning period.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-6

LADWP SERVICE AREA RELIABILITY ASSESSMENT FOR AVERAGE WEATHER YEAR Demand and Supply Projections (in acre-feet)
Average by Forecast Year – Fiscal Year Ending
(FYE) on June 30
2025 2030 2035 2040 2045
Total Water Demanda 642,600 660,200 678,800 697,800 710,500 Post-Conservation Demand 509,500 526,700 536,100 554,500 565,800 Existing/Planned Supplies
Conservation (Additional Activeb and Passivec after FY 14) 133,100 133,500 142,700 143,300 144,700 Los Angeles Aqueductd 190,400 188,900 187,300 185,800 184,200 Groundwater
Entitlementse 109,400 109,400 109,400 108,800 108,800
Groundwater Replenishment 7,000 11,000 11,000 11,000 11,000 Stormwater Recharge (Increased Pumping) 4,000 8,000 15,000 15,000 15,000 Recycled Water – Irrigation and Industrial Use 17,300 29,200 29,700 29,800 30,000 Subtotal (Existing/Planned Supplies) 461,200 480,000 495,100 493,700 493,700 MWD Water Purchases (with Existing/Planned Supplies) 181,400 180,200 183,700 204,100 216,800 Total Supplies 642,600 660,200 678,800 697,800 710,500
NOTES:
a Total Demand with existing passive conservation prior to FY 2014. b Cumulative “hardware” savings since late 1980s reached 110,822 AFY by FYE 2014. c Additional non-hardware conservation inclusive of retained passive savings from the dry period ending in 2017. d Los Angeles Aqueduct supply is estimated to decrease 0.1652 percent per year due to climate impacts. e LADWP Groundwater Remediation projects in the San Fernando basin are expected to be in operation by FYE 2023. Sylmar Basin production will increase to 4,170 AFY from FYE 2021 to 2036 to avoid the expiration of stored water credits, then revert to entitlement amounts of 3,570 AFY in 2037.

SOURCE: Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan, Exhibit 11E. May 2021.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-7

LADWP SERVICE AREA RELIABILITY ASSESSMENT FOR SINGLE DRY YEAR Demand and Supply Projections (in acre-feet)
Average by Forecast Year – Fiscal Year Ending
(FYE) on June 30
2025 2030 2035 2040 2045
Total Water Demanda 674,700 693,200 712,700 732,700 746,000 Post-Conservation Demand 509,500 536,700 536,100 554,500 565,800 Existing/Planned Supplies
Conservation (Additional Activeb and Passivec after FY 14) 165,200 165,500 176,600 178,200 180,200 Los Angeles Aqueductd 70,800 70,200 69,600 69,000 68,500 Groundwater
Entitlementse 121,300 121,300 121,300 120,700 120,700
Groundwater Replenishment 7,000 11,000 11,000 11,000 11,000 Stormwater Recharge (Increased Pumping) 4,000 8,000 15,000 15,000 15,000 Recycled Water – Irrigation and Industrial Use 17,300 29,200 29,700 29,800 30,000 Subtotal (Existing/Planned Supplies) 385,600 406,200 423,200 423,700 425,400 MWD Water Purchases (with Existing/Planned Supplies) 289,100 287,000 289,500 309,000 320,600 Total Supplies 674,700 693,200 712,700 732,700 746,000
NOTES:
a Total Demand with existing passive conservation prior to FY 2014. b Cumulative “hardware” savings since late 1980s reached 110,822 AFY by FYE 2014. c Additional non-hardware conservation inclusive of retained passive savings from the dry period ending in 2017. d Los Angeles Aqueduct supply is estimated to decrease 0.1652 percent per year due to climate impacts. e LADWP Groundwater Remediation projects in the San Fernando basin are expected to be in operation by FYE 2023. Sylmar Basin production will increase to 4,170 AFY from FYE 2021 to 2036 to avoid the expiration of stored water credits, then revert to entitlement amounts of 3,570 AFY in 2037.

SOURCE: Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan, exhibit 11F. May 2021.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 4.18-8
LADWP SERVICE AREA RELIABILITY ASSESSMENT FOR MULTIPLE DRY YEARS (YEAR 5 OF 5) Demand and Supply Projections (in acre-feet)
Multiple Dry Year by Forecast Year: Year 5 (1992) –
Fiscal Year Ending on June 30
2025 2030 2035 2040 2045
Total Water Demanda 655,700 673,600 692,600 712,000 724,900 Post-Conservation Demand 507,600 536,600 536,100 554,400 565,700 Existing/Planned Supplies
Conservation (Additional Activeb and Passivec after FY 14) 148,100 147,000 156,500 157,600 159,200 Los Angeles Aqueductd 141,900 140,700 139,500 138,400 137,300 Groundwater
Entitlementse 109,400 109,400 109,400 108,800 108,800
Groundwater Replenishment 7,000 11,000 11,000 11,000 11,000 Stormwater Recharge (Increased Pumping) 4,000 8,000 15,000 15,000 15,000 Recycled Water – Irrigation and Industrial Use 17,300 29,200 29,700 29,800 30,000 Subtotal (Existing/Planned Supplies) 427,700 445,300 461,100 460,600 461,300 MWD Water Purchases (with Existing/Planned Supplies) 228,000 228,300 231,500 251,400 263,600 Total Supplies 655,700 673,600 692,600 712,000 724,900
NOTES:
a Total Demand with existing passive conservation prior to FY 2014. b Cumulative “hardware” savings since late 1980s reached 110,822 AFY by FYE 2014. c Additional non-hardware conservation inclusive of retained passive savings from the dry period ending in 2017. d Los Angeles Aqueduct supply is estimated to decrease 0.1652 percent per year due to climate impacts. e LADWP Groundwater Remediation projects in the San Fernando basin are expected to be in operation by FYE 2023. Sylmar Basin production will increase to 4,170 AFY from FYE 2021 to 2036 to avoid the expiration of stored water credits, then revert to entitlement amounts of 3,570 AFY in 2037.

SOURCE: Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan, Exhibit 11G. May 2021.

Sewage and Wastewater
Wastewater Treatment
Sewage in Culver City is transported through a series of gravity mains and lift stations that the City owns and maintains. The wastewater is conveyed through trunk sewers to the Los Angeles Sanitation and Environment’s (LASAN) Hyperion Water Reclamation Plant (HWRP) facility located in Playa Del Rey and Los Angeles County Sanitation District’s (LACSD) Joint Water Pollution Control Plant (JWPCP) located in the city of Carson.

The HWRP is permitted to provide secondary treatment for up to 450 million gallons per day (mgd) average dry weather flow (ADWF), with a current ADFW of 275 mgd. Treatment consists of screening, sand/grit removal, primary treatment, secondary treatment, digestion, and solid handling.9

9 Los Angeles Sanitation and Environment, 2023. Treatment Process. https://www.lacitysan.org/san/faces/ wcnav_externalId/s-lsh-wwd-cw-p-hwrp-tp?_adf.ctrl-state=pi7xilsd2_5&_afrLoop=6341396168899773#!.

Accessed April 2023.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The JWPCP provides both primary and secondary treatment for approximately 260 mgd of wastewater and has a total permitted capacity of 400 mgd.10 Solids collected in primary treatment and secondary treatment are processed in anaerobic digestion tanks where bacteria break down organic material and produce methane gas. After digestion, the solids are dewatered at Solids Processing and hauled off-site to composting, land application, and landfill disposal locations. Methane gas generated in the anaerobic digestion process is used to produce power and digester heating steam in a Total Energy Facility that utilizes gas turbines and waste- heat recovery steam generators. The on-site generation of electricity permits the JWPCP to produce most of its electricity.
11 Collection Network
Sewage in Culver City generally moves through the gravity mains and lift stations system from northwest to south. The gravity mains are made of various materials including primarily polyvinyl chloride (PVC) and in some cases vitrified clay pipe (VCP). A few gravity mains near Mar Vista and Palms belong to the City of Los Angeles but discharge into the northern side of Culver City.
12 The City-operated Bristol, Fox Hills, Mesmer, and Overland pump stations were replaced in 2020 by the Bankfield Pump station, located at 5722 Bankfield, which pumps 1.3 mgd.13 Recycled Water Systems
No recycled water systems currently connect to Culver City. However, future supply needs and regional cooperation may make it possible to explore implementing recycled water networks.

Stormwater
Hydrology
Culver City's water use affects various watersheds and water bodies in the region. The Planning Area is located predominantly within the Ballona Creek Watershed with a few parcels on the western side of the Planning Area located within the Marina Del Rey Watershed, as shown in Figure 4.9-1, Existing Hydrologic Setting, in Section 4.9, Hydrology and Water Quality. 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. 14 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. A majority of

10 Los Angeles County Sanitation District, 2023a. Wastewater Treatment Process at JWPCP. https://www.lacsd.org/services/wastewater-sewage/facilities/joint-water-pollution-control-plant/wastewater- treatment-process-at-jwpcp. Accessed April 2023.
11 Ibid.
12 Culver City, 2023a. Sewer Infrastructure Management System (SIMS). https://gisproxy.culvercity.org/Html5Viewer/index.html?viewer=Sims.sims. Accessed April 2023. 13 Culver City, 2022. Capital Improvement Plan FY 2022/2023 to FY 2026/2027, pg. 59. https://www.culvercity.org/files/assets/public/documents/finance/governmenttransparency/02_annualcitybudg ets/3_cip/cip_2022-2023.pdf. Accessed July 2023.
14 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 April 2023.

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the Planning Area's land area drains into the Ballona watershed.15 The remaining area drains into the small, 2.9-square mile Marina del Rey Watershed, which surrounds the Marina del Rey harbor. Ballona Creek's stormwater flows westward through an engineered channel, discharging into the Santa Monica Bay through the Oxford Basin, a 10.7-acre human-made flood control retention facility, located in the harbor, that the Los Angeles County Flood Control District owns and operates.16,17
Drainage Collection
Stormwater is collected and conveyed through storm drains owned and maintained by Culver City and Los Angeles County. These lines generally drain towards the southwest or northeast, depending on their location within the Planning Area, before discharging into larger conveyance pipes that drain into Ballona Creek. Major outfall pipes for the Planning Area’s stormwater system vary in size from 18 to 87 inches in diameter and are found along the east and west sides of Ballona Creek. There are also outfall pipes along National Boulevard, Higuera Street, Duquesne Avenue, Madison Avenue, La Bouget Avenue, Sepulveda Boulevard, Saint Nicholas Avenue, Overland Avenue, and off the Baldwin Hills Scenic Overlook.

Culver City and Los Angeles County also have a network of catch basins that trap debris before entering the storm drain system. These catch basins help the storm drain system work effectively and more efficiently.

Solid Waste Disposal
Solid waste management in Culver City involves both public and private refuse collection services as well as public and private operation of solid waste transfer, resource recovery, and disposal facilities.

Pursuant to Section 5.01.01 of the City’s Municipal Code, solid waste handling and recyclable waste material handling shall be performed exclusively by the City or its authorized agents. In accordance with this section, all trash collection in the city is managed by the City’s Public Works Department (PWD), Environmental Programs and Operations Division (EPO), with all residential, commercial and industrial solid waste in the city collected by the EPO or its authorized agents.

The EPO also provides a curbside recycling program for paper, cardboard, cans/aluminum, plastic, and glass, with recyclable and green waste hauled to private recycling facilities. 18 Culver City does not own or operate any landfills. The majority of solid waste generated in the city is disposed of at County landfills. Per the County of Los Angeles Countywide Integrated Waste Management Plan (CoIWMP) 2020 Annual Report, while the economy has continued to grow in recent years, the amount of waste that residents and businesses generated and

15 Ibid.
16 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. 17 Marina del Rey Enhanced Watershed Management Program Agencies, 2016. Marina del Rey Enhanced Watershed Management Program Plan. https://file.lacounty.gov/SDSInter/dbh/docs/1025171_MdR_EWMP_Final.pdf.

Accessed April 2023.
18 Culver City, 2023b. Trash & Recycling. https://www.culvercity.org/Services/Trash-Recycling. Accessed April 2023.

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disposed of in the county remained relatively low.19 The CoIWMP 2020 Annual Report shows a downward disposal trend from 2009 to 2011 with a plateau between 2011 through 2014, an increase from 2014 to 2018 and another slight plateau from 2018 to the present. In 2020, the most recent year for which reported data is available, the county disposed of approximately 11 million tons of materials. The CoIWMP assumes an ongoing diversion rate of 65 percent Countywide. The overall reduction is due to the reduction in waste disposal at in-county facilities, likely due to the County’s solid waste management efforts, markets for recyclable materials, development of alternative technology facilities, diversion credit for such facilities, and State Assembly Bill (AB) 341, which has a 75 percent recycling goal. The 2020 average daily disposal for in-county landfills was 19,291 tons per day (tpd) and the maximum daily capacity was 45,297 tpd.
20 The CoIWMP 2020 Annual Report indicates that the County can adequately meet future Class III disposal needs through 2035 with assumptions that include meeting the California Department of Resources Recycling and Recovery (CalRecycle) statewide disposal target, meeting SB 1383 organic waste disposal reduction targets, and all solid waste management options considered become available. Therefore, a shortfall in disposal capacity is not expected to occur during this scenario during the 15-year planning period.

Landfills
Class III landfills accept non-hazardous municipal solid waste. There are 10 Class III landfills in the county, which collectively accept the majority of solid waste generated in the county (approximately 6,018,869 tons in 2020), followed by exports to out-of-county landfills in Orange, Riverside, San Bernardino, Ventura, and Kern counties (4,544,808 tons in 2020) and transformation facilities (337,989 tons in 2020). The remaining disposal capacity for the County’s Class III landfills is estimated at approximately 142.67 million tons as of December 31, 2020.

Of the 10 County Class III landfills serving the city, Sunshine Canyon landfill is the largest recipient of non-hazardous solid waste disposal materials. The maximum daily capacity for the landfill is approximately 12,100 tpd, and the 2020 average daily disposal was approximately 7,907 tpd. Based on Appendix E-2, Table 4 of the County of Los Angeles Countywide Integrated Waste Management Plan (ColWMP), as of December 31, 2020, Sunshine Canyon landfill had a remaining capacity of approximately 54.08 million tons and a remaining life expectancy of approximately 17 years.

Unclassified landfills accept construction and demolition (C&D) waste, certain green (landscaping) waste, and concrete, asphalt, and similar materials that are chemically and biologically inactive. In 2020, the amount of inert waste materials disposed countywide was 321,830 tons.

19 County of Los Angeles Department of Public Works, 2021. CoIWMP 2020 Annual Report, p. 5. October 2021. 20 County of Los Angeles Department of Public Works, 2021. CoIWMP 2020 Annual Report, Appendix E-2, Table 4, Remaining Permitted Disposal Capacity of Existing Solid Waste Disposal Facilities in Los Angeles County. October 2021.

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As of 2020, there is only one permitted Inert Waste Landfill in Los Angeles County that has a full solid waste facility permit, which is the Azusa Land Reclamation Landfill. The remaining capacity of this landfill is estimated at 51.71 million cubic yards (64.64 million tons) with a projected closure date of 2045.

In addition to the County-permitted facility, there are a number of Inert Debris Engineered Fill Operation facilities operating under state permit provisions that provide additional capacity in the county, collectively processing approximately 3.35 million tons in 2019. 21 Waste Diversion and Recycling
Under AB 341, all cities and counties in the state had a goal to divert 75 percent of their solid waste streams from landfills by 2020.22 The County and multiple cities in the County, including Culer City, have a diversion rate at 65 percent according to the CoIWMP 2020 Annual Report, the latest report available.

Culver City achieved a 70 percent diversion rate in 2015 as a result of a combination of measures required in the City’s Source Reduction and Recycling Element (SRRE). For purposes of compliance with SB 1016, CalRecycle compares reported disposal tons to population to calculate per capita disposal expressed in pounds/person/day with a target specified for each city, county, or regional agency with a CalRecycle-approved planning document. The specific targets for the Culver City are 8.9 pounds/resident/day and 8.3 pounds/employee/day. 23 In 2021, Culver City
achieved a per capita disposal of 6.5 pounds/resident/day and 4.9 pounds/employee/day.24 Electricity
Culver City is a member of the Clean Power Alliance (CPA), which provides clean, renewable energy. CPA is a nonprofit entity, formed in 2019 through a Joint Powers Authority 25 and is
made up of 32 public agencies across Los Angeles and Ventura counties. CPA purchases clean power and supplies 100 percent renewable electricity to Culver City as the community's default- selected tier option. Lower renewable percentage rate options (36 percent and 50 percent renewable) are available to consumers through two additional tiers offered at a reduced cost.

Southern California Edison (SCE) distributes electric power from the CPA to Culver City and LADWP produces, purchases, conveys, and delivers electric power to other parts of Culver City. LADWP's main Receiving Station
26 D, that brings high voltage power into the city and steps it down to local

21 County of Los Angeles Department of Public Works, 2021. CoIWMP 2020 Annual Report, p. 33. October 2021. 22 California Public Resources Code, Section 41730 et seq. 23 California Department of Resources Recycling and Recovery, 2021a. Countywide, Regionwide, and Statewide Jurisdiction Diversion/Disposal Progress Report, for reporting year 2021. https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/slcp/capacityplanning/recycling/DiversionDisposal.

Accessed April 2023.
24 California Department of Resources Recycling and Recovery, 2021b. Jurisdiction Per Capita Disposal Trends – Culver City, for reporting year 2021. https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/ReviewReports.

Accessed April 2023.
25 A joint powers authority is when two or more public authorities (e.g., local agencies, or utility or transport districts), not necessarily located in the same state, jointly exercise any power common to all parties. 26 A receiving station is one type of high voltage substations used by LADWP that serves as a bridge between power plants and local distribution: https://clui.org/projects/ladwp-power/high-voltage-control-facilities.

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distribution levels, is located directly north of the city. Since 2017, renewable energy sources have supplied 30 percent of LADWP's power throughout its service area. LADWP is working aggressively to expand Los Angeles' supply of renewable resources, which impacts Culver City.

Electric Distribution Network
The Santa Monica District of SCE delivers electric power to Culver City through a series of 29 distribution circuits connecting the Planning Area and has been working to improve its network resiliency to disruptions. Between 2017 and 2018, Culver City's sustained unexpected interruptions to electricity services decreased from an average of 121.7 minutes to 36.6 minutes. In comparison, the entire SCE systemwide network sustained 136.8 minutes of interruptions in 2018 and 139.7 minutes of interruptions in 2017, not including interruptions caused by acts of nature. Causes of repair outages in Culver City in 2018 were attributed largely to equipment failure (48.5 percent), urgent maintenance operations (33.7 percent), and weather/fire/earthquake (9.7 percent).
27 At the California Public Utilities Commission's (CPUC) request, SCE prepared a Wildfire Mitigation Plan that showed that six of the City's 29 circuits are within wildfire-prone areas. The Plan includes a Public Safety Power Shutoff program that monitors weather conditions and, when necessary, shuts the power off within one or more of the City's six circuits to reduce the likelihood of wildfire caused by their power lines.

Natural Gas
The Southern California Gas Company (SoCalGas) conveys and delivers natural gas services to residential and public services in Culver City using a combination of storage and pipeline facilities. This network has been instrumental in helping the City integrate compressed natural gas (CNG) vehicles into its municipal fleet, which began in 1996. By 2004, the Culver CityBus network transitioned to 100 percent CNG, which was ranked the second-best green fleet in North America in 2008.

The City's fleet of over 350 vehicles and equipment includes 41 CNG powered vehicles including refuse trucks, heavy duty public works trucks, park vehicles, and various staff cars. 28 Currently,
the City is working towards converting this CNG fleet into an all-electric fleet. In 2016, the City approved an agreement with Clean Energy Renewable for consulting and managing services of renewable natural gas as part of the City's participation in the Low Carbon Fuel Standard (LCFS) program under AB 32 to support greening the City's transportation facilities.

Natural Gas Distribution Network
Natural gas distribution service networks cover the majority of Culver City and are fed largely by the natural gas storage facility located in Playa del Rey. A portion of the Inglewood Oil Field (IOF), which actively produces both oil and natural gas, is located within the Planning Area.

27 S outhern California Edison, 2019. Circuit reliability Review, Culver City, 2019. https://www1.sce.com/nrc/reliability/reports/CulverCity.pdf. 28 Southern California Gas Company, 2014. Natural Gas Vehicles: Customer Case Study. https://www.socalgas.com /documents/innovation/natural-gas-vehicles/NGV-CulverCity-CNG-Bus.pdf. Accessed April 2023.

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Regionally connected transmission and high-pressure distribution lines intersect the Planning Area, which connect to the locally distributed pipeline network. However, as discussed in Section 4.11, Mineral Resources, the City adopted an Oil Termination Ordinance to implement an amortization program that would terminate and phase out nonconforming oil and gas activities within the city portion of the IOF by November 24, 2026. Similar to the City, the County adopted an Oil Well Ordinance for unincorporated areas of the County that prohibits 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. See Section 4.11 for a more detailed discussion.

Telecommunications
Communication systems located throughout the Planning Area include underground fiber optic cable, telephone transmission lines (overhead and underground), and cellular towers owned or leased by telecommunications service providers.

Landline telephone service in the Planning Area is provided by various commercial communications companies. The majority of the landline facilities are located in County or City- owned rights-of-way and on private easements. Telecommunications lines are either copper wire or fiber optic cable and are routed overhead on utility poles and underground.

In addition to landline service, a large number of communications towers have been constructed throughout the Planning Area for cellular telephone service. Cellular towers have been erected along major travel corridors to meet emergency service objectives. Cellular service is available, to varying degrees, throughout the Planning Area.

4.18.3 Regulatory Framework
This section provides the relevant federal, state, regional, and local regulations applicable to the Project relevant to the various utilities evaluated in this section.

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

Federal Water Pollution Control Act of 1972 – Clean Water Act The Clean Water Act (CWA) establishes the basic structure for regulating discharges of pollutants into the “waters of the United States.” The Act specifies a variety of regulatory and non-regulatory tools to sharply reduce direct pollutant discharges into waterways, finance municipal wastewater treatment facilities, and manage polluted runoff.

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Section 303(d) of the CWA requires states, territories, and authorized tribes to develop a list of water quality limited segments of rivers and other water bodies under their jurisdiction. These waters on the list do not meet water quality standards, even after point sources of pollution have installed the minimum required levels of pollution control technology. The law requires that these jurisdictions establish priority rankings for waters on the list and develop action plans, called Total Maximum Daily Loads (TMDL), to improve water quality. These are action plans designed to improve the quality of water resources. As part of the TDML process, municipalities must examine the water quality problems and identify sources of pollutants in order to create specific actions designed to improve water quality.

Section 402 of the CWA regulates point-source discharges to surface waters through the National Pollutant Discharge Elimination System (NPDES) program. In California, the State Water Resources Control Board (SWRCB) oversees the program which is administered by Regional Water Quality Control Boards (RWQCBs). The NPDES program provides for both general permits (those that cover a number of similar or related activities) and individual permits.

The NPDES program covers municipalities, industrial activities, and construction activities. The NPDES program includes an industrial stormwater permitting component that covers ten categories of industrial activity that require authorization under a NPDES industrial stormwater permit for stormwater discharges. Construction activities, also administered by the SWRCB, are discussed later in this section. Section 402(p) of the CWA, as amended by the Water Quality Act of 1987, requires NPDES permits for stormwater discharges from municipal separate storm sewer systems (MS4s), stormwater discharges associated with industrial activity, and designated stormwater discharges, which are considered significant contributors of pollutants to waters of the United States.

On November 16, 1990, the USEPA published regulations (40 CFR Part 122), which prescribe permit application requirements for MS4s pursuant to CWA 402(p). On May 17, 1996, the USEPA published an Interpretive Policy Memorandum on Reapplication Requirements for MS4s, which provided guidance on permit application requirements for regulated MS4s. MS4 permits include requirements for post-construction control of stormwater runoff in what is known as Provision C.3. The goal of Provision C.3 is for the Permittees to use their planning authorities to include appropriate source control, site design, and stormwater treatment measures in new development and redevelopment projects to address both soluble and insoluble storm water runoff pollutant discharges and prevent increases in runoff flows from new development and redevelopment projects. This goal is to be accomplished primarily through the implementation of low impact development (LID) techniques.

Section 404 establishes a permit program, administered by United States Army Corps of Engineers (USACE), to regulate the discharge of dredge or fill materials into waters of the United States, including wetlands. Activities in waters of the United States that are regulated under this program include fills for development, water resource projects (such as dams and levees), infrastructure development (such as highways and airports), and conversion of wetlands to uplands for farming and forestry. CWA Section 404 permits are issued by USACE.

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National Pollutant Discharge Elimination System
The CWA was amended in 1987 to include urban and stormwater runoff, which required many cities to obtain an NPDES permit for stormwater conveyance system discharges. Section 402(p) of the Clean Water Act prohibits discharges of pollutants contained in storm water runoff, except in compliance with a NPDES permit.

United States Department of Energy (Energy Policy Act of 2005) The United States Department of Energy (DOE) is the federal agency responsible for establishing policies regarding energy conservation, domestic energy production and infrastructure. The Federal Energy Regulatory Commission (FERC) is an independent federal agency, officially organized as part of the DOE which is responsible for regulating interstate transmission of natural gas, oil and electricity, reliability of the electric grid and approving of construction of interstate natural gas pipelines and storage facilities. The Energy Policy Act of 2005 has also granted FERC with additional responsibilities of overseeing the reliability of the nation’s electricity transmission grid and supplementing state transmission siting efforts in national interest electric transmission corridors.

FERC has authority to oversee mandatory reliability standards governing the nation’s electricity grid. FERC has established rules on certification of an Electric Reliability Organization (ERO) which establishes, approves and enforces mandatory electricity reliability standards. The North American Electric Reliability Corporation (NERC) has been certified as the nation’s ERO by FERC to enforce reliability standards in all interconnected jurisdictions in North America. Although FERC regulates the bulk energy transmission and reliability throughout the United States, the areas outside of FERC’s jurisdictional responsibility include state-level regulations and retail electricity and natural gas sales to consumers which falls under the jurisdiction of state regulatory agencies.

Federal Communications Commission
The Federal Communications Commission (FCC) requires all new cellular tower construction to be approved by the state or local authority for the proposed site and comply with FCC rules involving environmental review. Additionally, the Telecommunications Act of 1996 requires construction of new cellular towers to comply with the local zoning authority.

State
California Porter-Cologne Water Quality Control Act
The Porter-Cologne Water Quality Control Act established the SWRCB and divided the state into nine regional basins, each with a RWQCB. SWRCB is the primary state agency responsible for protecting the quality of the state's surface and groundwater supplies, while the regional boards are responsible for developing and enforcing water quality objectives and implementation plans. The Planning Area is located within the jurisdiction of Los Angeles RWQCB.

The Act authorizes SWRCB to enact state policies regarding water quality in accordance with CWA Section 303. In addition, the act authorizes SWRCB to issue Waste Discharge Requirements (WDRs) for projects that would discharge into state waters. The Porter-Cologne Water Quality

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Control Act requires that SWRCB or Los Angeles RWQCB adopt water quality control plans (basin plans) for the protection of water quality. A basin plan must:
• Identify beneficial uses of waters to be protected;
• Establish water quality objectives for the reasonable protection of the beneficial uses; and • Establish a program of implementation of achieving the water quality objectives.

Basin plans also provide the technical basis for determining waste discharge requirements, taking enforcement actions, and evaluating clean water grant proposals. Basin plans are updated and reviewed every three years in accordance with Article 3 of the Porter-Cologne Water Quality Control Act and Section 303(c) of the CWA.

State Updated Model Landscape Ordinance
The state’s Updated Model Landscape Ordinance (AB 1881) required cities and counties to adopt landscape water conservation ordinances by January 31, 2010. In 2015, Executive Order B-29-15 tasked the California DWR with revising the 2010 Model Water Efficient Landscaping Ordinance to increase water efficiency standards for new and retrofitted landscapes. Increased water efficiency can be achieved through efficient irrigation systems, graywater usage, and on-site stormwater capture, and by limiting the portion of landscapes that can be covered in turf. Projects in the city that are subject to the Model Water Efficient Landscaping Ordinance requirements must submit a landscape design plan as part of the submittal process with the City. 29 California Urban Water Management Planning Act
The California Urban Water Management Planning Act (Water Code, Section 10610, et seq.) addresses several state policies regarding water conservation and the development of water management plans to ensure the efficient use of available supplies. The California Urban Water Management Planning Act also requires Urban Water Suppliers to develop Urban Water Management Plans (UWMPs) every five years to identify short-term and long-term demand management measures to meet growing water demands during normal, dry, and multiple-dry years. Urban Water Suppliers are defined as water suppliers that either serve more than 3,000 customers or provide more than 3,000 acre-feet per year (AFY) of water to customers.

California Emergency Graywater Regulations
In 2009, as part of the Governor's declared State of Emergency, Chapter 16A "Non-potable Water Reuse Systems" was incorporated into the 2007 California Plumbing Code. Chapter 16A establishes minimum requirements for the installation of graywater systems in residential occupancies regulated by the California Department of Housing and Community Development, providing guidance and flexibility designed to encourage the use of graywater. The standards allow small graywater systems to be installed in homes without a construction permit, substantially reducing the barriers to installing small residential graywater systems in California.

The purpose of the regulations is to conserve water by facilitating greater reuse of laundry, shower, sink, and similar sources of discharge for irrigation and/or indoor use; to reduce the

29 Culver City Municipal Code, Section 5.08.045.

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number of noncompliant graywater systems by making legal compliance easily achievable; to provide guidance for avoiding potentially unhealthful conditions; and to provide an alternative way to relieve stress on private sewage disposal systems.

Senate Bill 610, Senate Bill 221, and Senate Bill 7
Two of the state laws addressing the assessment of water supply necessary to serve large-scale development projects, SB 610 and SB 221, became effective January 1, 2002. SB 610, codified in Water Code Sections 10910–10915, specifies the requirements for water supply assessments (WSAs) and their role in the California Environmental Quality Act (CEQA) process, and defines the role UWMPs play in the WSA process. SB 610 requires that, for projects subject to CEQA that meet specific size criteria, the water supplier prepare WSAs that determine whether the water supplier has sufficient water resources to serve the projected water demands associated with the projects.

SB 610 provides specific guidance regarding how future supplies are to be calculated in the WSAs where an applicable UWMP has been prepared. Specifically, a WSA must identify existing water supply entitlements, water rights, or water service contracts held by the public water system, and prior years’ actual water deliveries received by the public water system. In addition, the WSA must address water supplies over a 20-year period and consider normal, single-dry, and multiple-dry year conditions. In accordance with SB 610, projects for which a WSA must be prepared are those subject to CEQA that meet any of the following criteria:
• Residential developments of more than 500 dwelling units; • Shopping centers or business establishments employing more than 1,000 persons or having more than 500,000 square feet of floor space;
• Commercial office buildings employing more than 1,000 persons or having more than 250,000 square feet of floor space;
• Hotels, motels, or both, having more than 500 rooms;
• Industrial, manufacturing, or processing plants, or industrial parks planned to house more than 1,000 persons, occupying more than 40 acres of land, or having more than 650,000 square feet of floor area
• Mixed-use projects that include one or more of the projects specified in this subdivision; or • Projects that would demand an amount of water equivalent to or greater than the amount of water required by a 500-dwelling-unit project. (Water Code Section 912, CEQA Guidelines Section 15155(a)).

The WSA must be approved by the public water supplier serving the project and incorporated into the CEQA document. The lead agency must then make certain findings related to water supply based on the WSA.

In addition, under SB 610, a water supplier responsible for the preparation and periodic updating of an UWMP must describe the water supply projects and programs that may be undertaken to meet the total project water use of the service area. If groundwater is identified as a source of water available to the supplier, the following additional information must be

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included in the UWMP: (1) a groundwater management plan; (2) a description of the groundwater basin(s) to be used and the water use adjudication rights, if any; (3) a description and analysis of groundwater use in the past five years; and (4) a discussion of the sufficiency of the groundwater that is projected to be pumped by the supplier.

SB 221 also addresses water supply in the land use approval process for large residential subdivision projects. Under SB 221, a water supplier must prepare and adopt a WSV indicating sufficient water supply is available to serve a proposed subdivision, or the local agency must make a specific finding that sufficient water supplies are or will be available prior to completion of a project, as part of the conditions for the approval of a final subdivision map. SB 221 specifically applies to residential subdivisions of 500 units or more. However, Government Code Section 66473.7(i) exempts “… any residential project proposed for a site that is within an urbanized area and has been previously developed for urban uses; or where the immediate contiguous properties surrounding the residential project site are, or previously have been, developed for urban uses; or housing projects that are exclusively for very low and low-income households.”
SB 7, enacted on November 10, 2009, mandates new water conservation goals for UWMPs, requiring Urban Water Suppliers to achieve a 20 percent per capita water consumption reduction by the year 2020 statewide, as described in the “20 x 2020” State Water Conservation Plan.
30 As such, each updated UWMP must now incorporate a description of how each respective urban water supplier will quantitatively implement this water conservation mandate, which requirements in turn must be taken into consideration in preparing and adopting WSAs under SB 610.

Senate Bill X7-7 – Water Conservation Act
SB X7-7 (Water Conservation Act of 2009), codified in California Water Code Section 10608, requires all water suppliers to increase water use efficiency. Enacted in 2009, this legislation sets an overall goal of reducing per capita urban water use, compared to 2009 use, by 20 percent by December 31, 2020. The State of California was required to make incremental progress towards this goal by reducing per capita water use by at least 10 percent on or before December 31, 2015. Monthly statewide potable water savings reached 25.1 percent in February 2017 as compared to that in February 2013.
31 Cumulative statewide savings from June 2015 through
February 2017 were estimated at 22.5 percent.32 Following a multi-year drought and improvements to hydrologic conditions, statewide potable water savings reached 14.7 percent in August 2017 as compared to August 2013 potable water production.33

30 California State Water Resources Control Board, 2010. 20 x 2020 Water Conservation Plan, February 2010. 31 State Water Resources Control Board, 2017a. Fact Sheet, February 2017 Statewide Conservation Data, February Conservation Summary, updated April 4, 2017.
32 State Water Resources Control Board, 2017b. Media Release, “Statewide Water Savings Exceed 25 Percent in February; Conservation to Remain a California Way of Life,” April 4, 2017. 33 State Water Resources Control Board, 2017c. Fact Sheet, August 2017 Statewide Conservation Data, August Urban Water Production Summary, updated October 3, 2017.

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Sustainable Groundwater Management Act of 2014
The Sustainable Groundwater Management Act (SGMA) of 2014,34 passed in September 2014, is a comprehensive three-bill package that provides a framework for the sustainable management of groundwater supplies by local authorities.35 The SGMA requires the formation of local groundwater sustainability agencies to assess local water basin conditions and adopt locally based management plans. Local groundwater sustainability agencies were required to be formed by June 30, 2017.

The SGMA provides 20 years for groundwater sustainability agencies to implement plans and achieve long-term groundwater sustainability, and protect existing surface water and groundwater rights. The SGMA provides local groundwater sustainability agencies with the authority to require registration of groundwater wells, measure and manage extractions, require reports and assess fees, and request revisions of basin boundaries, including establishing new subbasins. Furthermore, the SGMA requires governments and water agencies of high and medium priority basins to stop overdraft and bring groundwater basins into balanced levels of pumping and recharge. Under the SGMA, these basins should reach sustainability within 20 years of implementing their sustainability plans. For the basins that are critically over-drafted, the timeline is 2040. For the remaining high and medium priority basins, the deadline is 2042.

California Code of Regulations
Title 20
Title 20, Sections 1605.3 (h) and 1505(i) of the California Code of Regulations (CCR) establishes applicable state efficiency standards (i.e., maximum flow rates) for plumbing fittings and fixtures, including fixtures such as showerheads, lavatory faucets, and water closets (toilets).

Among the standards, the maximum flow rate for showerheads manufactured on or after July 1, 2018, is 1.8 gallons per minute (gpm) at 80 pounds per square inch (psi); and lavatory faucets manufactured after July 1, 2016, is 1.2 gpm at 60 psi. The standard for toilets sold or offered for sale on or after January 1, 2016, is 1.28 gallons per flush. 36 CALGreen Code
Part 11 of Title 24, the title that regulates the design and construction of buildings, establishes the California Green Building Standards (CALGreen) Code. The purpose of the CALGreen Code is to improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a reduced negative impact or a positive environmental impact and encouraging sustainable construction practices in the following categories: planning and design, energy efficiency, water efficiency and conservation, material conservation and resource efficiency, and environmental quality. The CALGreen Code includes both mandatory measures as well as voluntary measures. The mandatory measures establish minimum baselines that must be met in order for a building to be approved. The mandatory

34 Sustainable Groundwater Management Act [And Related Statutory Provisions from SB1168 (Pavley), AB1739 (Dickinson), and SB1319 (Pavley) as Chaptered], 2015 Amendments, effective January 1, 2019. 35 California Department of Water Resources, 2023. SGMA Groundwater Management. https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater-Management. Accessed April 2023.
36 California Code of Regulations, Title 20, Section 1605.3(h).

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measures for water conservation provide limits for fixture flow rates, which are the same as those for the Title 20 efficiency standards listed in the previous section. The voluntary measures can be adopted by local jurisdictions for greater efficiency.

Plumbing Code
Title 24, Part 5 of the CCR establishes the California Plumbing Code. The California Plumbing Code sets forth efficiency standards (i.e., maximum flow rates) for all new federally regulated plumbing fittings and fixtures, including showerheads and lavatory faucets. The 2019 California Plumbing Code, which is based on the 2018 Uniform Plumbing Code, has been published by the California Building Standards Commission and went into effect on January 1, 2020.

Executive Order B-37-16
In 2018 the California State Legislature enacted two policy bills: SB 606 and AB 1168 to establish a new foundation for long-term improvements in water conservation goals and drought planning to adapt to the longer and more intense droughts climate change is causing in California.

Collectively, these efforts provide a road map for all Californians to work together to ensure there is sufficient water now and in the future. The 2018 legislation applies to the actions of DWR, SWRCB, and water suppliers. DWR and SWRCB will work closely together to develop new standards for:
• Indoor residential water use standard will be 55 gallons per capita daily until January 2025; the standard will become stronger over time, decreasing to 50 gallons per capita daily in January 2030. For the water use objective, the indoor use is aggregated across population in an urban water supplier’s service area, not each household; • Outdoor residential water use standard will be based on land cover [landscaping], climate, and other factors, i.e., geography, pastures and other irrigated lands, or open space determined by the DWR and the SWRCB. The SWRCB will adopt the outdoor standard by June 2022;
• Commercial, industrial, and institutional water use for landscape irrigation with dedicated meters; and
• System water losses, formerly known as unaccounted for water.

Urban water suppliers must stay within annual water budgets based on these standards for their service areas. The 2018 legislation also supports drought planning. In urban areas, drought plans will be primarily led by local water suppliers. DWR and SWRCB will develop recommendations to strengthen drought planning in rural areas and areas served by small water systems by coordinating with counties and other stakeholders.

Executive Order B-40-17
Executive Order B-40-17 was issued on April 7, 2017. Cities and water districts throughout the state are required to report their water use each month and ban wasteful practices, including hosing off sidewalks and running sprinklers when it rains.

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Executive Order N-10-21
On July 8, 2021, Executive Order N-10-21 was issued calling for voluntary cutbacks of water usage by 15 percent from 2020 usage levels. The Order lists common sense measures Californians can undertake to achieve water usage reduction goals and identifies the SWRCB for tracking of monthly reporting on the state’s progress.

Executive Order 7-77
On March 28, 2022, Governor Newsom issued Executive Order No. 7-77, meant to provide guidance on emergency drought relief. The Order states that the “21st century to date has been characterized by record warmth and predominantly dry conditions, and the 2021 meteorological summer in California and the rest of the western United States was the hottest on record” and “the ongoing drought will have significant, immediate impacts on communities with vulnerable water supplies, farms that rely on irrigation to grow food and fiber, and fish and wildlife that rely on stream flows and cool water.”
Within the Order, the Governor directed SWRCB to evaluate the adoption of regulations and the relaxations of permitting for drought positive measures. These regulations include banning irrigation of “non-functional” turf (or grass), such as decorative grass adjacent to large industrial and commercial buildings. The ban would not include residential lawns or grass used for recreation, such as school fields, sports fields and parks. Further, the Order asks SWRCB to prepare municipal water agencies for drought restrictive measures. More specifically, SWRCB asks these urban water suppliers to prepare to activate, at a minimum, Level 2 of their customized Water Shortage Contingency Plans. These plans are developed by local water agencies to navigate extreme drought and each plan is customized based on an agency’s unique infrastructure and management. Triggering Level 2 of these plans involves implementing water conservation actions to prepare for a water shortage level of up to 20 percent.

California Integrated Waste Management Act
The California Integrated Waste Management Act of 1989 (AB 939), as amended, was enacted to reduce, recycle, and reuse solid waste generated in the state. AB 939 requires city and county jurisdictions to divert 50 percent of the total waste stream from landfill disposal. AB 939 also requires each city and county to promote source reduction, recycling, and safe disposal or transformation. AB 939 further requires each city and county to conduct a Solid Waste Generation Study and to prepare a Source Reduction and Recycling Element to describe how it would reach these goals. The Source Reduction and Recycling Element contains programs and policies for fulfillment of the goals of AB 939, including the previously noted diversion goals, and must be updated annually to account for changing market and infrastructure conditions. As projects and programs are implemented, the characteristics of the waste stream, the capacities of the current solid waste disposal facilities, and the operational status of those facilities are upgraded, as appropriate. California cities and counties are required to submit annual reports to CalRecycle to update their progress toward the AB 939 goals. 37 CalRecycle is a department
within the California Environmental Protection Agency (CalEPA) that administers and provides

37 California Public Resources Code Section 41821.

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oversight for all of California’s State-managed non-hazardous waste handling and recycling programs.

California Solid Waste Reuse and Recycling Access Act
The California Solid Waste Reuse and the Recycling Access Act of 1991 (AB 1327) is codified in PRC Sections 42900–42911. As amended, AB 1327 requires each local jurisdiction to adopt an ordinance requiring commercial, industrial, or institutional building, marina, or residential buildings having five or more living units to provide an adequate storage area for the collection and removal of recyclable materials. The size of the required storage areas is to be determined by the appropriate jurisdiction’s ordinance.

Construction and Demolition Waste Materials Diversion Requirements Signed in 2002, the Construction and Demolition Waste Materials Diversion Requirements (SB 1374) were codified in PRC Section 42919. SB 1374 requires that jurisdictions include in their annual AB 939 report a summary of the progress made in diverting construction and demolition waste. The legislation also required that CalRecycle adopt a model ordinance for diverting 50 to 75 percent of all construction and demolition waste from landfills. The model ordinance was adopted by CalRecycle on March 16, 2004.
38 Organic Recycling
AB 1826 requires jurisdictions to implement an organic waste recycling program for businesses, including outreach, education, and monitoring of affected businesses. Additionally, each jurisdiction is to identify a multitude of information, including barriers to siting organic waste recycling facilities, as well as closed or abandoned sites that might be available for new organic waste recycling facilities. AB 1826 defines “organic waste” as food waste, green waste, landscape and pruning waste, non-hazardous wood waste, and food-soiled paper waste that is mixed in with food waste. It also defines a “business” as a commercial or public entity, including, but not limited to, a firm, partnership, proprietorship, joint stock company, corporation, or association that is organized as a for-profit or nonprofit entity, or a multifamily residential dwelling consisting of five or more units. As of January 1, 2017, businesses that generate four cubic yards or more of organic waste per week are subject to this requirement. Commencing January 1, 2019, businesses that generate four cubic yards or more of commercial solid waste per week also were required to arrange for organic waste recycling services. In October 2021, CalRecycle reduced this threshold to two cubic yards of solid waste (i.e., total of trash, recycling, and organics) per week generated by covered businesses. 39 Zero Waste California
Zero Waste California is a state program launched by CalRecycle in 2002 to promote a new vision for the management of solid waste by maximizing existing recycling and reuse efforts, while ensuring that products are designed for the environment and have the potential to be

38 California Department of Resources Recycling and Recovery, 2023a. Senate Bill 1374 (2002). https://www.calrecycle.ca.gov/lgcentral/library/canddmodel/instruction/sb1374. Accessed April 2023. 39 California Department of Resources Recycling and Recovery, 2023b. Mandatory Commercial Organics Recycling. www.calrecycle.ca.gov/recycle/commercial/organics/. Accessed March 2023.

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repaired, reused, or recycled. The Zero Waste California program promotes the goals of market development, recycled product procurement, and research and development of new and sustainable technologies.

California’s 75-Percent “Recycling” Goal
AB 341, signed on February 10, 2011, directed that no less than 75 percent of solid waste generated in California be source reduced,40 recycled, or composted by 2020, and required CalRecycle to provide a report to the Legislature that recommends strategies to achieve the policy goal by January 1, 2014. AB 341 also mandated local jurisdictions to implement commercial recycling by July 1, 2012.

Disposal Measurement System Act of 2008
SB 1016 maintains the 50 percent diversion rate requirement established by AB 939, while establishing revised calculations for those entitles who did not meet the 50 percent diversion rate. SB 1016 also established a per capita disposal measurement system to make the process of goal measurement, as established by AB 939, simpler, timelier, and more accurate. The new disposal-based indicator— the per capita disposal rate— uses only two factors: a jurisdiction's population (or in some cases employment) and its disposal as reported by disposal facilities.

Organic Waste Reduction
Effective September 2016, SB 1383 established two organic waste disposal reduction targets tied to the 2014 baseline of 23 million tons of organic waste disposal and must be achieved by 2020 and 2025. The target is set for 2020 at 50 percent organic waste reduction from 2014 baseline (11.5 million tons allowed landfill disposal of organic waste), and for 2025 at 75 percent organic waste reduction from 2014 baseline (5.75 million tons allowed landfill disposal of organic waste). The law grants CalRecycle the regulatory authority required to achieve the organic waste disposal reduction targets and establishes an additional target that not less than 20 percent of currently disposed edible food is recovered for human consumption by 2025.

California Independent System Operator
The California Independent System Operator (ISO) is an independent public benefit corporation responsible for operating California’s long-distance electric transmission lines. California ISO is led by a five-member board appointment by the Governor and is also regulated by FERC. While transmission owners and private electric utilities own their lines, California ISO operates the transmission system independently to ensure that electricity flows comply with federal operational standards. California ISO analyzes current and future electrical demand and plans for any needed expansion or upgrade of the electric transmission system.

40 Source reduction refers to activities designed to reduce the volume, mass, or toxicity of products throughout their life cycle. It includes the design and manufacture, use, and disposal of products with minimum toxic content, minimum volume of material, and/or a longer useful life.

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California Public Utilities Commission
CPUC establishes policies and rules for electricity and natural gas rates provided by private utilities in California such as SCE and SoCalGas. Public owned utilities such as LADWP do not fall under CPUC’s jurisdiction.

CPUC is overseen by five commissioners appointed by the Governor and confirmed by the state senate. CPUC’s responsibilities include regulating electric power procurement and generation, infrastructure oversight for electric transmission lines and natural gas pipelines, and permitting of electrical transmission and substation facilities.

California Energy Commission
The California Energy Commission (CEC) is a planning agency which provides guidance on setting the state’s energy policy. CEC’s responsibilities include forecasting electricity and natural gas demand, promoting and setting energy efficiency standards throughout the state, developing renewable energy resources and permitting thermal power plants 50 megawatts and larger. CEC also has specific regulatory authority over publicly owned utilities to certify, monitor and verify eligible renewable energy resources procured.

Senate Bill 1389
SB 1389 (Public Resources Code [PRC] Sections 25300–25323), adopted in 2002, requires the development of an integrated plan for electricity, natural gas, and transportation fuels. Under the bill, CEC must adopt and transmit to the Governor and Legislature an Integrated Energy Policy Report every two years. The 2021 Integrated Energy Policy Report, the latest report published by CEC, provides the results of CEC’s assessments related to energy sector trends, building decarbonization and energy efficiency, zero-emission vehicles, energy equity, climate change adaptation, electricity reliability in Southern California, natural gas assessment, and electricity, natural gas, and transportation energy demand forecasts. 41 Title 24, California Code of Regulations, Part 6: Energy Efficiency Standards for Buildings
Title 24, Part 6, of the California Code of Regulations contains the CEC’s Energy Efficiency Standards for Residential and Nonresidential Buildings. Title 24 was first established in 1978, in response to a legislative mandate to reduce California’s energy consumption. Since that time, Title 24 has been updated periodically to allow for consideration and possible incorporation of new energy efficiency technologies and methods.

Assembly Bill 1890
CPUC regulates investor-owned electric power and natural gas utility companies in the State of California. AB 1890, enacted in 1996, deregulated the power generation industry, allowing customers to purchase electricity on the open market. Under deregulation, the production and distribution of power that was under the control of investor-owned utilities (e.g., SCE) was decoupled. All new construction in the State of California is subject to the energy conservation standards set forth in Title 24, Part 6, Article 2 of the California Administrative Code. These are

41 California Energy Commission, 2022. 2021 Integrated Energy Policy Report, February 22, 2022.

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prescriptive standards that establish maximum energy consumption levels for the heating and cooling of new buildings. The utilization of alternative energy applications in development projects, while encouraged, is not required as a development condition. Such applications may include installation of photovoltaic solar panels, active solar water heating systems, or integrated pool deck water heating systems, all of which serve to displace consumption of conventional energy sources (i.e., electricity and natural gas). Incentives, primarily in the form of state and federal tax credits, as well as reduced energy bills, provide a favorable basis.

Regional
Metropolitan Water District 2020 Urban Water Management Plan As discussed in detail below, MWD is a primary source of water supply within Southern California. Based on the water supply planning requirements imposed on its member agencies and ultimate customers, MWD has adopted a series of official reports on the state of its water supplies. In response to recent developments in the Sacramento Delta, MWD has developed plans intended to provide solutions that, when combined with the rest of its supply portfolio, will ensure a reliable long-term water supply for its member agencies, including Culver City and the City of Los Angeles.

MWD’s 2020 UWMP (MWD UWMP) addresses the future of MWD’s water supplies and demand through the year 2045.
42 Evaluations are prepared for average year conditions, single dry year conditions, and multiple dry year conditions. The analysis for multiple dry year conditions, i.e., under the most challenging weather conditions such as drought and service interruptions caused by natural disasters, is presented in Table 2-5 of the 2020 UWMP. 43 The analysis in the
2020 UWMP concluded that reliable water resources would be available to continuously meet demand through 2045.
44 In the 2020 UWMP, the projected 2045 demand water during multiple dry year conditions is 1,564,000 AFY, whereas the expected and projected 2045 supply is 2,239,000 AFY based on current programs, for a potential surplus in 2045 of 675,000 AFY. 45 MWD has comprehensive plans for stages of actions it would undertake to address up to a 50 percent reduction in its water supplies and a catastrophic interruption in water supplies through its Water Surplus and Drought Management and Water Supply Allocation Plans. MWD has also developed an Emergency Storage Requirement to mitigate against potential interruption in water supplies resulting from catastrophic occurrences within the Southern California region and is working with the State to implement a comprehensive improvement plan to address catastrophic occurrences that could occur outside of the Southern California region. MWD is also working with the State on the Delta Risk Management Strategy to reduce the impacts of a seismic event in the Delta that would cause levee failure and disruption of SWP deliveries. In addition, MWD has plans for supply implementation and continued development

42 Metropolitan Water District of Southern California, 2021. 2020 Urban Water Management Plan, June 2021. 43 Metropolitan Water District of Southern California, 2021. 2020 Urban Water Management Plan, June 2021, p. 2-19.
44 Metropolitan Water District of Southern California, 2021. 2020 Urban Water Management Plan, June 2021, p. 2-19.
45 Metropolitan Water District of Southern California, 2021. 2020 Urban Water Management Plan, June 2021, p. 2-19.

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of a diversified resource mix, including programs in the Colorado River Aqueduct, SWP, Central Valley transfers, local resource projects, and in-region storage that enables the region to meet its water supply needs.
2015 Integrated Resources Plan
MWD prepares an Integrated Water Resources Plan (IRP) that provides a water management framework with plans and programs for meeting future water needs. It addresses issues that can affect future water supply such as water quality, climate change, and regulatory and operational changes. The most recent IRP (2015 IRP) was adopted in January 2016. 46 It
establishes a water supply reliability mission of providing its service area with an adequate and reliable supply of high-quality water to meet present and future needs in an environmentally and economically responsible way. Among other topics, the 2015 IRP discusses water conservation, local and imported water supplies, storage and transfers, water demand, and adaptation to drought conditions.

The 2015 IRP reliability targets identify developments in imported and local water supply, and in water conservation that, if successful, would provide a future without water shortages and mandatory restrictions under planned conditions. For imported supplies, MWD would make investments to maximize Colorado River Aqueduct deliveries in dry years. MWD would make ecologically-sound infrastructure investments to the SWP so that the water system can capture sufficient supplies to help meet average year demands and to refill the MWD storage network in above-average and wet years.

Planned actions to keep supplies and demands in balance include, among others, lowering regional residential per capita demand by 20 percent by the year 2020 (compared to a baseline established in 2009 state legislation), reducing water use from outdoor landscapes and advancing additional local supplies. IRP Table ES-1, 2015 IRP Update Total Level of Average-Year Supply Targeted (Acre-Feet), of the 2015 IRP, shows the supply reliability and conservation targets. As presented in the IRP, the total supply reliability target for each five-year increase between 2016 and 2040 would exceed the retail demand after conservation. In 2040, retail demand after conservation is estimated to be 4,273,000 acre-feet and the total supply reliability target is approximately 4,539,000 acre-feet, representing an excess of 266,000 acre-feet. 47 As of April 2023, the 2020 IRP planning process is in development. The 2020 IRP analyzes multiple scenarios that could plausibly unfold in the future due to climate change, economic growth, legislation and regulations affecting water sources and demands, and other variables.

With the variability of these impacts in mind, MWD is developing four scenarios to help understand the challenges of the future and effectively plan to ensure water reliability in the face of those challenges.

46 Metropolitan Water District of Southern California, 2016. Integrated Water Resources Plan – 2015 Update, Report No. 1518.
47 Metropolitan Water District of Southern California, 2016. Integrated Water Resources Plan – 2015 Update, Report No. 1518, 2016, p. VIII.

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Water Surplus and Drought Management Plan
In 1999, MWD incorporated the water storage contingency analysis that is required as part of any UWMP into a separate, more detailed plan, called the Water Surplus and Drought Management Plan (WSDM Plan). The overall objective of the WSDM Plan is to ensure that shortage allocation of MWD’s imported water supplies is not required. The WSDM Plan provides policy guidance to manage MWD’s supplies and achieve the goals laid out in the agency’s IRP.

The WSDM Plan separates resource actions into two major categories: Surplus Actions and Shortage Actions. The WSDM Plan considers the region to be in surplus only after MWD has met all demands for water, including replenishment deliveries. The Surplus Actions store surplus water, first inside then outside of the region. The Shortage Actions of the WSDM are separated into three subcategories: Shortage, Severe Shortage, and Extreme Shortage. Each category has associated actions that could be taken as part of the response to prevailing shortage conditions.

Conservation and water efficiency programs are part of MWD’s resource management strategy through all categories.
48 Long-Term Conservation Plan
The Long-Ter m Conservation Plan (LTCP) provides a framework of goals and strategies to reduce per capita water use through conservation and water use efficiency. The plan recognizes the challenges and uncertainties to achieving the IRP target. As a result, the LTCP uses adaptive management and strategies to adjust implementation approaches.

Water Supply Allocation Plan
While the WSDM Plan included a set of general actions and considerations for MWD staff to address during shortage conditions, it did not include a detailed water supply allocation plan or implementation approach. Therefore, in February 2008, MWD adopted a water supply plan called the Water Supply Allocation Plan (WSAP). The WSAP includes a formula for determining equitable, needs-based reductions of water deliveries, with the potential application of a surcharge, to member agencies during extreme water shortages in MWD's service area conditions (i.e., drought conditions or unforeseen interruptions in water supplies).

The WSAP allows member agencies the flexibility to choose among various local supply and conservation strategies to help ensure that demands on MWD stay in balance with limited supplies. The WSAP formula addresses shortages of MWD supplies, by taking into account growth, local investments, changes in supply conditions and the demand hardening aspects of non-potable recycled water use and the implementation of conservation savings programs. The allocation period covers 12 consecutive months from July of a given year through the following June.

West Basin Municipal Water District 2020 Urban Water Management Plan WBMWD was established in 1947 to mitigate over-pumping in the West Coast Subbasin.

WBMWD is the fourth-largest member agency of MWD and undertakes actions to protect groundwater supplies from seawater intrusion and augment the West Coast Subbasin supplies.

48 Metropolitan Water District of Southern California, 1999. Water Surplus and Drought Management Plan, Report No. 1150.

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WBMWD imports water from MWD and delivers these supplies to investor-owned utilities, municipalities, a county waterworks district, and a groundwater agency to supplement locally available supplies.

As described in its most recent 2020 UWMP, WBMWD has an approximately 185-square-mile service area and provides wholesale potable water to 17 cities through three investor-owned utilities, four municipal water departments and one county waterworks district, in southwest Los Angeles County. WBMWD supplies recycled water to over 450 metered connections for municipal, commercial, and industrial use as well as for injection into the West Coast Basin Seawater Barrier to halt seawater intrusion and replenish the WCGB aquifers. 49 WBMWD has been able to support the diversification of supplies available to its customer agencies by providing access to imported water supplies from MWD, as well as primarily through the development of recycled water supplies and conservation. These supplies are served directly to its customer agencies and indirectly as the replenishment supplies necessary to maintain groundwater production. WBMWD is projected to increase current recycled water supplies as well as invest in ocean water desalination supply.

County of Los Angeles Countywide Integrated Waste Management Plan Pursuant to AB 939, each County is required to prepare and administer a ColWMP, including preparation of an Annual Report. The ColWMP is to comprise of the various counties’ and cities’ solid waste reduction planning documents, plus an Integrated Waste Management Summary Plan (Summary Plan) and a Countywide Siting Element. The Summary Plan describes the steps to be taken by local agencies, acting independently and in concert, to achieve the mandated state diversion rate by integrating strategies aimed toward reducing, reusing, recycling, diverting, and marketing solid waste generated within the County. The County’s Department of Public Works is responsible for preparing and administering the Summary Plan and the Countywide Siting Element.

The County continually evaluates landfill disposal needs and capacity as part of the preparation of the CoIWMP Annual Report. Within each annual report, future landfill disposal needs over the next 15-year planning horizon are addressed in part by determining the available landfill capacity. The most recent annual report, the CoIWMP 2020 Annual Report, published in October 2021, provides disposal analysis and facility capacities for 2020, as well as projections to the CoIWMP’s horizon year of 2035. As stated within the CoIWMP 2020 Annual Report, the County is anticipating a solid waste disposal capacity shortfall within the next 15 years under current conditions. However, under other scenarios, including meeting CalRecycle’s statewide disposal target, meeting Senate Bill 1383 organic waste disposal reduction targets, and all solid waste management options considered become available, a shortfall in disposal capacity is not expected to occur during this scenario during the 15-year planning period.

49 West Basin Municipal Water District, 2021. Urban Water Management Plan, pg. ES-3. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F1728223502%2FWBMWD%20 2020%20UWMP_Final_2021-06-30.pdf. Accessed April 2023.

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SCE Wildfire Mitigation Plan
SCE’s Wildfire Mitigation Plan (WMP) is a comprehensive blueprint to address wildfire risk and Public Safety Power Shutoff (PSPS) impacts in SCE’s service area and was developed with the input of SCE regulators, public safety partners, local governments, community groups, fellow electrical corporations, and other stakeholders. The 2023-2025 WMP builds upon SCE’s 2020- 2022 WMP to maintain the risk reduction achieved to date and is intended to further reduce the significant wildfire risk and PSPS impacts that remain. 50 Local
Culver City Service Area Urban Water Management Plan
In accordance with the California Urban Water Management Planning Act, UWMPs are updated at 5-year intervals. GSWC approved the Culver City Service Area 2020 UWMP on June 15, 2021.

The 2020 UWMP describes GSWC’s water supply reliability under single dry year, multiple dry year, and average year conditions, with projected information in five-year increments for a minimum of 20 years.

It is also acknowledged that GSWC service areas are in Stage 2 of the Water Shortage Contingency and Staged Mandatory Water Conservation and Rationing plan. 51 In Stage 2,
customers are encouraged to voluntarily reduce usage by 20 percent (compared to 2020) and limit outdoor irrigation/watering to no more than two days per week between the hours of 5 p.m. and 9 a.m. Addresses ending in an even number must water only on: Sunday or Wednesday. Addresses ending in an odd number must water only on: Tuesday or Saturday.

Culver City Water Conservation Plan
The City’s Water Conservation Plan was developed to achieve targeted water reductions in City facilities, provide information and encouragement to residents seeking to reduce water consumption, and enable residents to adhere to mandatory water use restrictions. 52 The Plan
includes mandatory water use restrictions for businesses and residents, water saving measures for residents, and water saving measures for City facilities.

Culver City Municipal Code
Water
The City’s policies regarding water supply are set forth in Chapter 5.03, Water Conservation and Water Supply Shortage Program, of the City’s Municipal Code. The purpose of this chapter is to adopt and enforce a conservation and supply shortage program as necessary to manage the City’s potable water supply in the short- and long-term, and to avoid or minimize the effects of drought and shortage within the city. According to Chapter 5.03.C, careful water management that includes active water conservation measures not only in times of drought, but at all times,

50 Southern California Edison, 2023. 2023–2025 Wildfire Mitigation Plan. https://www.sce.com/safety/wild-fire- mitigation. Accessed March 2023.
51 Culver City, 2023c. Water Conservation. https://www.culvercity.org/City-Hall/Departments/Public-Works/Culver- City-Environmental-Initiatives/Water-Conservation. Accessed April 2023. 52 Culver City, 2015. Water Conservation Plan for Fiscal Year 2015/2016, 2015. https://www.culvercity.org/files/assets/public/documents/building-development/city- documents/culvercitywaterconservatio.pdf. Accessed April 2023.

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is essential to ensure a reliable minimum supply of water to meet current and future water supply needs.53
The water conservation and supply shortage program established under Chapter 5.03, is intended to reduce water consumption through conservation, and to enable effective water supply planning, assure reasonable and beneficial use of water, prevent waste of water, and maximize the efficient use of water within the City to avoid and minimize the effect and hardship of water shortage to the greatest extent possible.

Under Section 5.03.030, permanent water conservation requirements and prohibition against waste include limits on watering hours (Section 5.03.030.A), which prohibit watering or irrigating of lawn, landscape or other vegetated area with potable water between the hours of 8:00 a.m. and 7:00 p.m.; limit on watering duration (Section 5.03.030.B), which limit watering to no more than 10 minutes of watering per day, per station; prevention of excessive water flow or runoff (Section 5.03.030.C); and prohibition of washing down hard or paved surfaces (Section 5.03.030.D). Other measures (Section 5.03.030.E through O) include the obligation to fix leaks, breaks or malfunctions (Section 5.03.030.E); required re-circulation of water for decorative water fountains and decorative water features (Section 5.03.030.F), and prohibition of single-pass cooling systems (Section 5.03.030.J). The Code also requires that all pools and spas must be covered in a manner to reduce evaporation (Section 5.03.030.N) and prohibit irrigation of ornamental turf on public street medians Section 5.03.030.O).

Sections 5.03.035, 5.03.040, and 5.03.045, respectively, pertain to Level 1, Level 2, and Level 3 water supply shortage emergency conditions. The stages are cumulative and include permanent measures as well as measures from the preceding level. Level 1 water supply shortage requires additional water conservation measures including limits on water days; a 72-hour time limit on repairs of leak, breaks or malfunctions. Level 2 requires more stringent limits on watering days, a 48-hour time limit on repairs of leak, breaks or malfunction; prohibition on filling ornamental lakes or ponds (except under specified conditions); and limits on washing vehicles at commercial car washing facilities. The use of potable water to wash or clean a vehicle, whether motorized or not, is prohibited at a commercial car washing facility that does not utilize a re-circulating water system. Level 3 prohibits watering or irrigating, unless maintenance of vegetation, including trees and shrubs, are watered with a hand-held bucket or similar container or a hand-held hose equipped with a positive, self-closing, water-shut-off nozzle or device. Maintenance of existing landscape necessary for fire protection, erosion control, or protection of protected species or certain other landscaped areas, such as public parks and playing fields, is allowed provided that such irrigation does not exceed two days per week and is conducted in accordance with the time restrictions. Level 3 also requires that all leaks, breaks, or other malfunctions in the water user's plumbing or distribution system be repaired within 24 hours of notification. At present, Culver City is observing Level 1 water restrictions.

53 Culver City Municipal Code, Chapter 5.03.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.18-33 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Wastewater
The City’s Municipal Code sets specific wastewater collection and treatment facilities requirements. Section 5.02.005 of the City’s Municipal Code requires a City-issued connection permit to connect to the City’s wastewater collection system. Section 5.02.220 of the City’s Municipal Code establishes a Sewerage Facilities Charge for new connections to the Culver City wastewater collection system which represents the proportionate cost of providing service to the new development. The City Engineer may require a project applicant to submit plans and other information necessary to determine the applicable sewage facilities fees during plan check review, with the fees based on a standard formula that includes the proposed square footage and types of land uses. Section 5.02.035 of the City’s Municipal Code establishes a Sewer User Fee, which is collected annually from Culver City property owners, for the cost, maintenance, repair and improvement of that portion of the City of Los Angeles sewerage system (i.e., wastewater conveyance systems) used jointly by Culver City and the City of Los Angeles under the Amalgamated Agreement.

Solid Waste
The City’s Municipal Code addresses solid waste management in Chapter 5.01. Section 5.01.010 through 5.01.040 require that (1) only refuse containers provided or authorized by the City shall be utilized; (2) separate containers are to be provided for Class III solid waste, recyclables, and green waste; (3) new commercial construction must have refuse containers within an enclosed container area that is cement paved and enclosed with 6-foot-high masonry walls with a minimum 6-foot-wide opaque door for ready removal of the containers; and (4) solid and recycling waste material handling comply with the Environmental Programs and Operation Division’s exclusive franchise for services. Per Section 5.01.100, City Building and Demolition Permits are issued with the condition that the permittee agrees to abide by the provisions of Chapter 5.01.

Electric Power and Natural Gas
Culver City participates in an environmental recognition program, California Green Communities. The program helps cities develop strategies to reduce carbon emissions and increase energy efficiency in their community. In addition, the City has adopted green building ordinances to reduce GHG emissions for new development. Pursuant to Chapter 15.02.1005 of the City’s Municipal Code, the City requires 1 kilowatt (kw) of photovoltaic (PV) power installed per 10,000 square feet (sf) of new development. The City’s Municipal Code includes an option to pay an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2, Exceptions of the California Building Code. Under Chapter 17.320.035 of the City’s Municipal Code, the City goes beyond CALGreen Building Code standards and requires at least 20 percent electric vehicle (EV) capable parking spaces, 10 percent EV ready parking spaces, and 10 percent EV charging stations for both new residential and retail developments. 54 Additionally, Sections 4.408.1 and 5.408.1, Construction Waste Management, require the

54 Culver City Zoning Code, 2023. Title 17, Section 17.320, Off-Street Parking and Loading. https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-52279#JD_17.320.020. Accessed April 2023.

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Preliminary − Subject to Revision
recycle and/or salvage for reuse a minimum of 75 percent of nonhazardous construction and demolition waste.

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

Telecommunications
Section 11.20 of the City’s Municipal Code outlines rules and regulations related to telecommunications installation within Culver City. The intent of the Code is to:

1. To enable the City to discharge its public trusts in a manner consistent with rapidly evolving federal and state regulatory policies, industry competition, and technology development.

2. To authorize and to manage reasonable access to the City's public right-of-way and public property for telecommunications purposes on a competitively neutral and nondiscriminatory basis.

3. To obtain fair and reasonable compensation for the City and its residents for authorizing the private use of the public rights-of-way and public property, which are recognized to be valuable public assets, held in trust by the City.

4. To foster and to promote competition in telecommunications services, minimize unnecessary local regulation of telecommunications service providers, and encourage the delivery of advanced and competitive telecommunications services on the broadest possible basis to local government and to the businesses, institutions and residents of the City.

5. To establish clear local guidelines, standards and time frames for the exercise of local authority with respect to the regulation of telecommunication service providers, including establishment and enforcement of consumer service standards and technical standards.

6. To encourage the profitable deployment of advanced telecommunications infrastructures that satisfy local needs, deliver enhanced government services, and provide informed consumer choices in an evolving telecommunication market.

Culver City Clean Power Alliance
In February 2019 for residential customers and May 2019 for non-residential customers, CPA became the new electricity supplier for Culver City. With this change, CPA purchases the renewable energy resources for electricity and SCE delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent, or opt out of the CPA to remain with SCE as their provider.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-35 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Culver City Information Technology Department
The Culver City Information Technology Department (IT) is responsible for providing computing, telecommunications, and network service to all departments and divisions within the city. IT provides project management, systems planning, design, and programming support for the enhancement of existing and new systems.
55 IT also provides high-speed fiber-optic internet cables for Culver City businesses to promote economic development. Culver City's municipal fiber network, known as Culver Connect, has a

21.7-mile network backbone in three geographical network rings interconnected by “ring ties” of approximately 3.1 route miles of fiber. The network backbone is comprised of 576 strands of entirely undergrounded fiber. There are three hub facilities located in the city that house City- owned network electronics. The City leases two fiber connections to carrier hotels at One Wilshire in Los Angeles and Equinix (LA3) in El Segundo.

4.18.4 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 utilities and service systems if the project would:

Threshold UTL-1: Require or result in the relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction of relocation of which could cause significant environmental effects.

Threshold UTL-2: Have insufficient water supplies available to serve the project and reasonably foreseeable future development during normal, dry and multiple dry years.

Threshold UTL-3: Result in a determination by the wastewater treatment provider which serves or may serve the project that it does not have adequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments.

Threshold UTL-4: Generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

Threshold UTL-5: Not comply with federal, state, and local management and reduction statutes and regulations related to solid waste.

Methodology
The analysis in this section addresses impacts on public utilities and City infrastructure due to projected population growth that would result from the Project.

55 Culver City, 2023d. Technology. https://www.culvercity.org/City-Hall/Departments/IT. Accessed April 2023.

4. Environmental Impact Analysis

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Preliminary − Subject to Revision
Water
The Project’s demand for domestic water was assessed in relation to GSWC’s and LADWP’s ability to supply water pursuant to their 2020 UWMPs. Water demand was calculated based on LADWP projections of water unit use factors identified in the 2020 UWMP. The estimated water demand associated with projected growth under the General Plan Update was compared with the available supply.

Wastewater
Potential impacts of the Project on the existing public wastewater infrastructure are analyzed by comparing the estimated wastewater generation associated with projected growth under the General Plan Update with the calculated available capacity of the existing facilities.

Considerations for determination include a description of the existing wastewater systems within the Planning Area, including capacity and current flows; summary of adopted wastewater-related plans; and an evaluation of projected wastewater needs under the Project.

In order to evaluate treatment capacity, the Project’s estimated wastewater generation and projected peak flows were compared with the available treatment capacity within the HWRP and JWPCP. Cumulative wastewater generation was compared with the available capacity of the HWRP and JWPCP.

Electric Power, Natural Gas, and Telecommunications Facilities The analysis evaluates the potential impacts of the Project on existing energy infrastructure by identifying required regulations that would ensure Project energy demand could be met with available capacity. During construction of future development, energy would be consumed in the form of electricity associated with conveyance of water, lighting, and other construction activities necessitating electrical power. Construction activities typically do not involve the consumption of natural gas. Operational energy consumption would include electricity and natural gas from uses associated with future development such as heating/ventilation/air conditioning (HVAC); water heating, cooking, lighting, and use of electronics/appliances.

Solid Waste
The analysis of solid waste impacts addresses the amount of solid waste that would be generated by projected growth under the General Plan Update, and whether sufficient landfill capacity is available to accommodate the projected volumes of waste so as to not exceed state or local standards or otherwise impair the attainment of solid waste reduction goals. The existing and projected amount of solid waste generated is determined by using a per unit waste generation factor for the various uses, which is derived from relevant guidance documents from CalRecycle and the USEPA. The analysis focuses on waste generation rates rather than disposal rates, which are reduced significantly by state and local diversion programs, and thus provides a conservative analysis of the impacts on solid waste facilities that would be caused by the Project. The availability of landfill capacity is derived from the CoIWMP 2020 Annual Report. The Project’s net increase in waste is compared to existing and planned capacities to determine the Project’s potential impact.

4. Environmental Impact Analysis

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Preliminary − Subject to Revision
Subsequent environmental review at the project level may be required to determine whether a specific development project would result in a significant environmental effect regarding the capacity for utility and service systems to adequately serve the future project, including such impacts from the construction of water distribution lines, wastewater collect system components, storm drainage conveyance pipes or facilities, or disposal of solid waste. Project- level review, if necessary, will occur when proposed development plans are prepared.

Project Impact Analysis
New or Expanded Water, Wastewater Treatment, Stormwater Drainage, Electric Power, Natural Gas, or Telecommunications Facilities
Threshold UTL-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require or result in the relocation or construction of new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities, the construction o r relocation of which could cause significant environmental effects.

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

General Plan Update
The Project is projected to accommodate 21,600 new residents, 12,700 new housing units, 16,260 new jobs, and 6,696,800 new square feet of nonresidential building space through the 2045 horizon year. These increases would result in an increased demand for water, wastewater treatment, storm drainage, electric power, natural gas, and telecommunication services which may require the construction or relocation of facilities which could cause significant environmental impacts. Each service is discussed separately below.

Water
As noted below in Impact UTL-2, the City and local water providers have water conservation measures and programs to reduce water demand. Further, the General Plan Update includes policies that would reduce water demand of future development allowed under the Project.

Also described under Impact UTL-2, both GSWC and LADWP project sufficient water supply availability under normal, single dry and multiple dry years. While growth under the Project was not specifically accounted for in the 2020 UWMP for each local water provider, GSWC and LADWP would be required to account for this projected growth during the next UWMP update cycle in 2025. Thus, the UWMP would account for future development in the Planning Area in the planning process prior to the General Plan Update’s horizon year of 2045. In the event of a water supply shortage as described in the GSWC’s and LADWP’s 2020 UWMPs, GSWC and LADWP can

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.18-38 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
implement the respective Water Shortage Contingency Plans (WSCPs).56,57 The WSCPs require water response actions to six water shortage stages, which correspond to progressively severe water shortage conditions as compared to the normal reliability condition. In addition, most new development allowed under the Project is expected to be infill and would rely on the existing distribution network that has sufficient capacity to convey available water supplies.

Each individual project would be required to demonstrate the availability of water to service the development, as required and applicable, in the form of will-serve letters or, for larger projects, preparation of a WSA per SB 610. If additional facilities were to be constructed, separate environmental analysis would be required. The City currently complies with the statutory requirements listed in the regulatory section, and the General Plan Update ensures that the City would continue to comply with the state and federal regulatory requirements. Overall, the General Plan Update policies contain various methods of water conservation and water planning, such as expanding and enhancing existing water conservation measures, mandates, and strategies to optimize wise use of water (Policy INF-2.1); restricting and eliminating potable water use for primarily non-edible irrigated landscapes where alternative water sources are available (Policy INF-2.6); providing dual plumbing for all new public parks and landscape projects in anticipation of future water recycling or on-site water capture, treatment, and re-use infrastructure to be used for irrigation (Goal INF-4 and associated policies, Policy INF-2.8); and providing resources and guidance for conventional lawn conversion to drought tolerant landscaping (Policy INF-2.5), which would improve water management in the Planning Area.

It is anticipated that the City’s overall water infrastructure system would be improved over the next 25 years, particularly as redevelopment occurs and the system services additional residences and businesses. If future development under the General Plan Update would require the construction and operation of new or expanded water supply facilities, construction or expansion of such facilities would be subject to project-level environmental review in accordance with CEQA at the time it is proposed. This project-level review would identify any significant environmental impacts that could result from the construction and operation of such facilities and would identify project-specific mitigation measures to lessen or avoid any significant impacts as feasible. Individual infrastructure improvements that may occur under the applicable UWMPs would also be subject to individual CEQA review and clearance to determine whether any would have significant environmental impacts. Therefore, impacts would be less than significant.

Wastewater
As discussed under Impact UTL-3, the General Plan Update includes policies and actions that would reduce the demand for wastewater treatment. In accordance with City requirements, new development allowed under the Project would be subject to the latest adopted edition of the California Plumbing Code and CALGreen Code, including the provisions for water-efficient

56 Golden State Water Company, 2021. 2020 Urban Water Management Plan: Culver City Service Area, Chapter 6. https://www.gswater.com/urban-water-management-plan. Accessed March 2023. 57 Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan, pg. ES-26. May 2021. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F9314518570%2F1.%20LADWP %202020%20UWMP.pdf. Accessed April 2023.

4. Environmental Impact Analysis

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Preliminary − Subject to Revision
fixtures and toilets, which would reduce the amount of effluent entering the wastewater system. In addition, as discussed under Impact UTL-3, there is sufficient capacity at the HWRP and JWPCP to accommodate wastewater collection and treatment generated by the Project.

Future development allowed under the Project would be located within urban areas of the Planning Area and near existing wastewater infrastructure. In addition, the City would comply with applicable current and future statutory requirements. Therefore, the Project would not result in insufficient wastewater collection and treatment and no new or expanded wastewater treatment facilities would be needed. Impacts would be less than significant.

Stormwater Drainage
As discussed in Impact HYD-3 in Section 4.9, Hydrology and Water Quality, future development allowed under the Project 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 Municipal Separate Storm Sewer System Permit (Order No. R4-2021-0105, NPDES Permit No. CAS004004), Los Angeles County Low Impact Development Ordinance, Sections 5.05.010 and 5.05.040 of the City’s Municipal Code, and the City’s Standard Urban Stormwater Mitigation Plan and Stormwater Quality Master Plan.

In addition, the Conservation Element includes policies such as 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 INF-6.1, 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 (Policies S-6.6, S-6.7, S-6.8, S-6.9). City requirements and policies would ensure that runoff would not inundate existing storm drainage facilities such that new or expanded facilities would be required. Therefore, impacts would be less than significant.

Electric Power
It is possible that future development allowed under the General Plan Update could result in the provision of new electrical power facilities, including new or upgraded substations and/or transmission lines. However, all new development would be subject to the latest adopted edition of the CALGreen Code, which establishes mandatory energy efficiency measures for new residential and non-residential buildings. Compliance with current CALGreen requirements and proposed General Plan policies that promote renewable energy generation and energy efficiency would ensure that new development associated with the implementation of the General Plan Update would be energy efficient, thus reducing the need for new electrical power infrastructure (Goal GHG-2, Policy GHG-2.4). Should upgrades to new facilities be required, construction of those facilities could result in adverse environmental effects. Future facilities would be subject to environmental review under CEQA and required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. Therefore, Project-related electricity demand would not result in additional impacts related to the provision of electrical power infrastructure, and this impact would be less than significant.

4. Environmental Impact Analysis

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Preliminary − Subject to Revision
Natural Gas
It is possible that future development allowed under the General Plan Update could result in the provision of new natural gas facilities, including new and/or upgraded pipelines. SoCalGas projects that total gas demand in its service area would decline at an annual rate of 1 percent from 2020 to 2035 due to modest economic growth and CPUC-mandated energy efficiency standards and projects.58 Additionally, all new development would be subject to energy efficiency standards contained in the latest adopted edition of the CALGreen Code, thus reducing the need for new natural gas infrastructure. Should upgrades be required, construction of those facilities could result in adverse environmental effects. Future facilities would be subject to environmental review under CEQA and required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. Therefore, Project-related natural gas demand would not result in additional impacts related to the provision of natural gas infrastructure, and this impact would be less than significant.

Telecommunication
It is possible that future development allowed under the General Plan Update could result in the provision of new telecommunication facilities. Should upgrades to telecommunication infrastructure be required, construction of those facilities could result in adverse environmental effects. Future facilities would be subject to environmental review under CEQA and required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. Therefore, Project-related demand for new telecommunications services would not result in additional impacts related to the provision of telecommunication infrastructure, and this impact 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 in the development that would within the city over time.

Construction of new or expanded water, wastewater treatment, and stormwater drainage, electric power, natural gas, or telecommunications facilities that could occur as a result of growth under the Project would be reviewed by the City for compliance with applicable requirements and mitigation measures in this Draft PEIR. Therefore, the Zoning Code Update itself would not result in significant adverse effects and impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Infrastructure Element
Goal INF-2: Water conservation. Water conservation strategies are implemented and expanded citywide to meet sustainability targets and ensure future resiliency.

INF-2.1: Water conservation. Expand and enhance existing water conservation measures, mandates, and strategies to optimize wise use of water.

58 California Gas and Electric Utilities, 2020. 2020 California Gas Report. https://www.socalgas.com/ sites/default/files/2020-10/2020_California_Gas_Report_Joint_Utility_Biennial_Comprehensive_Filing.pdf.

Accessed April 2023.

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

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

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

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

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

INF-4.2: Repurposing of stormwater management infrastructure. Optimize the repurposing stormwater management infrastructure approaching the end of its service life to support city-wide stormwater management and water reuse programs in alignment with water conservation programs.

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

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

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

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.

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.

Greenhouse Gas Reduction Element
Goal GHG-2: Green buildings. Green and decarbonized buildings are the standard for new construction, major renovations, and existing building retrofits.

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

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

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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 new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities.

Water Supplies
Threshold UTL-2: The Project would have a significant impact if sufficient water supplies were not available to serve future development allowed by the General Plan Update, Zoning Code Update, and reasonably foreseeable future development during normal, single dry, and multiple dry years.

Impact Statement UTL-2: Sufficient water supplies to serve the Project and reasonably foreseeable future development during normal, single dry, and multiple dry years would not be available. Therefore, the Project would result in potentially significant impact related to water supplies.

General Plan Update
The Project is projected to accommodate 21,612 new residents, 12,760 new housing units, 16,804 new jobs, and 3,696,800 new square feet of nonresidential building space through the 2045 horizon year. This increase in development would result in an increased demand for potable water.

As discussed, Culver City is served by two water service providers: GSWC and LADWP. GSWC serves the Culver City service area through surface water purchased from Metropolitan. GSWC’s projected demands for potable and non-potable use within the Culver City service area are shown in Table 4.18-1, and LADWP’s projected demands for potable and non-potable use are shown in Table 4.18-2.

The water demand projections in GSWC’s 2020 UWMP and LADWP’s 2020 UWMP were developed based on SCAG’s 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) demographic projections. GSWC’s 2020 UWMP and LADWP’s 2020 UWMP identified water supplies to meet projected water demands through 2045. GSWC’s and LADWP’s water supply projections in their respective 2020 UWMPs are sufficient to meet the water demand for projects that are determined by the CEQA lead agency to be consistent with the 2020 RTP/SCS by SCAG. However, the Project would result in growth and an increase in intensity above these projections.

As discussed in Section 4.13, Population and Housing, the population, housing, and employment projections assumed for the General Plan Update are higher than SCAG’s 2045 estimates since the Project provides for additional population, housing, and employment capacity not anticipated by SCAG. As stated in GSWC’s 2020 UWMP, GSWC has reliable supplies to meet its retail customer demands in normal, single dry years, and five consecutive dry year conditions

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through 2045, and GSWC’s contract water from WBMWD is resilient during dry conditions.59 As a result, GSWC is not faced with shortages during normal or dry years through the year 2045. In addition, as stated in the LADWP’s 2020 UWMP, LADWP also has reliable supplies to meet demand under normal, single dry year, and five consecutive dry year conditions through the year 2045.60 However, growth under the Project was not specifically accounted for in the UWMP for each local water provider. As UWMPs are based on adopted land use forecasts and plans, GSWC and LADWP would be required to account for this growth during the next UWMP update cycle in 2025 and thus, would account for future development in the Planning Area in their planning process prior to the General Plan Update’s horizon year of 2045.

Table 4.18-9, General Plan Update 2045 Water Demand Projections, summarizes estimated water demand within the Planning Area under the General Plan Update. Although growth would be incremental, water demand associated with future development under the General Plan Update would be approximately 3,539,310 million gpd, or approximately 3,966 afy.

TABLE 4.18-9
GENERAL PLAN UPDATE 2045 WATER DEMAND PROJECTIONS
Land Use
Net Change (General Plan
2045 – Existing) Dwelling Units
or Jobs in Plan Area
Daily Water
Use Ratea
Daily Water
Demand (gpd)
Annual Water
Demand (afy)
Residential 12,760 units 189 (gpd/unit) 2,411,640 2,703 Commercialb 15,510 jobs 67 (gal/employee/day) 1,039,170 1,164 Industrialb 750 jobs 118 (gal/employee/day) 88,500 99
Total General Plan Update Water Demand (Year 2045) 3,539,310 3,966 NOTES:
a Based on water use factors identified in Exhibit 2L of the LADWP 2020 UWMP. b Job totals provided by Raimi + Associates, 2023
SOURCE: ESA, 2023

Individual development proposals that meet the definition of a project under CEQA would be required to address water supply as part of the CEQA process, and for qualifying projects, a WSA would be required pursuant to SB 610 for inclusion in the project’s CEQA analysis. The WSA discerns whether the expected demand from the development being proposed has been accounted for in the forecasted demands in the most recent UWMP. A Written Verification of Supply per SB 221 is prepared as a condition of approval for a subdivision map of 500 units or more. The Written Verification of Supply serves as a mechanism to provide sufficient evidence that adequate water supplies are available before construction begins and is prepared and adopted by the water supplier and approved by the land use authority. Depending on the project, one or both of these analyses may be required.

59 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. 60 Los Angeles Department of Water and Power, 2021. 2020 Urban Water Management Plan. May 2021. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F9314518570%2F1.%20LADWP %202020%20UWMP.pdf. Accessed April 2023.

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In the event of a water shortage, GSWC and LADWP would rely on their Water Shortage Contingency Plans (WSCPs), which are to be engaged in the case of a water shortage event, such as a drought or supply interruption. The WSCPs for both GSWC and LADWP include six levels to address shortage conditions ranging from up to 10 percent to greater than 50 percent shortage, identifies a suite of demand mitigation measures to implement at each level, and identifies procedures to annually assess whether or not a water shortage is likely to occur in the coming year. The WSCP requires water response actions to six water shortage stages, which correspond to progressively severe water shortage conditions (up to 10 percent, 20 percent, 30 percent, 40 percent, 50 percent, and greater than 50 percent shortage) as compared to the normal reliability condition. The following six (6) Stages list the shortage response actions:
• Stage 1 (0 to 10 percent shortage) – Stage 1 is a “Water Alert” where voluntary conservation is encouraged.
• Stage 2 (10 percent to 20 percent shortage) – Stage 2 is a “Moderate Shortage” and will be implemented if the Stage 1 restrictions are deemed insufficient to achieve necessary demand reductions due to water supply shortages.
• Stage 3 (20 percent to 30 percent shortage) – Stage 3 is a “Severe Shortage” that requires water allocations and mandatory conservation.
• Stage 4 (30 percent to 40 percent shortage) – Stage 4 is a “Critical Shortage” that includes all steps taken in prior stages regarding allocations and mandatory conservation. • Stage 5 (40 percent to 50 percent shortage) – Stage 5 is a “Shortage Crisis” that includes all steps taken in prior stages regarding allotments and mandatory conservation. This stage will be implemented in the event that the source of supply is severely curtailed to the level that requires each customer to restrict their water use for only human health and safety purposes.
• Stage 6 (50 percent or greater shortage) – Stage 6 is an “Emergency Shortage” condition that includes all steps taken in prior stages regarding allotments and mandatory conservation.

GSWC and LADWP also promote water conservation through rebates, conservation kits (which include high-efficiency showerheads and faucet aerators), and programs (which include turf replacement and free landscape training classes).

The City is taking steps to decrease its overall water demand. For example, the Water Conservation Plan includes mandated and voluntary water conservation measures for businesses and residents to achieve targeted water reductions and reduce water consumption.

The City also has a water conservation and supply shortage program as set forth in Chapter 5.03 of the City’s Municipal Code which is intended to reduce water consumption through conservation, and to enable effective water supply planning, assure reasonable and beneficial use of water, prevent waste of water, and maximize the efficient use of water within the City to avoid and minimize the effect and hardship of water shortage to the greatest extent possible.

The General Plan Update includes policies and actions, such as expanding and enhancing existing water conservation measures, mandates, and strategies; requiring and encouraging

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-45 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
water usage reduction strategies in landscaping design; and maintaining and increasing City groundwater well levels for emergency use and diverse future water supply opportunities, that would reduce water demand of future development allowed under the Project. Implementation of Policies INF-2.1 through INF-2.10 in the General Plan Update would reduce the overall existing and future water usage in the Planning Area by curbing demand for domestic and commercial purposes and promoting water conservation strategies. Goal INF-3 specifically addresses water security and groundwater recharge and Goal INF-4 addresses water reuse networks.

Furthermore, all new development would be subject to water conservation standards contained in the CALGreen Code. Compliance with current CALGreen requirements would ensure that future development allowed under the General Plan Update would establish water conservation features.

Although future development would be required to comply with Chapter 5.03 of the City’s Municipal Code, the City’s Water Conservation Plan, and General Plan Update’s policies aimed at reducing demand over time, sufficient water supply is not documented to be available at this time. Therefore, it is concluded that impacts would be potentially 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. As the City receives applications for subsequent development under the Project, the City would review the applications to ensure compliance with applicable requirements to ensure there are sufficient water supplies to serve the development. However, given that the Zoning Code Update implements the General Plan Update, and the projected growth would result in a potentially significant impact with regard to water supply, as with the General Plan Update, the Zoning Code Update would result in a potentially significant impact with regard to water supply.

INF-2.1: Water conservation. Expand and enhance existing water conservation measures, mandates, and strategies to optimize wise use of water.

INF-2.2: Water conservation rebate outreach. Increase citywide outreach and residential and commercial participation in LADWP, GSWC, West Basin Water District and other water conservation rebate and incentive programs (residential program rebates, high efficiency water conservation kits, multifamily and commercial/institutional programs, Water Savings Incentive Program, Large Landscape Survey Program, etc.).

INF-2.3: Water Conservation Plan. Continually revisit and revise the City’s Water Conservation Plan and ensure municipal and resident enforcement of the plan.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.18-46 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
INF-2.4: Dry weather runoff reduction. Reduce dry weather runoff, and track baseline runoff volumes at key facilities, including the reused Mesmer Station to monitor and capture dry weather flows and to divert them for treatment at the Hyperion Wastewater Treatment Reclamation Plant
INF-2.5: Drought-tolerant landscaping. Provide resources and guidance for conventional lawn conversion to drought tolerant landscaping.

NF-2.7: Information on irrigation and water treatment standards. Create and equitably share resources that provide information on appropriate irrigation methods and water treatment standards for both productive and non-productive landscapes.

INF-2.9: Mulching and composting. Expand mulching and composting activities on City- owned sites to promote healthy soils and retain water in irrigated landscapes.

INF-2.10: Healthy water and soils strategies. Integrate healthy water and soils strategies to support expansion of urban agriculture practices.

Goal INF-3: Water security and groundwater recharge. Culver City actively contributes to regional initiatives to improve security and diversify the water supply and groundwater recharge efforts.

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

Mitigation Measures
No feasible mitigation measures have been identified.

Level of Significance after Mitigation
Actions described above and the UWMP present a range of activities being undertaken by multiple agencies to ensure reliable water supplies that meet the future needs of the Planning Area. No additional mitigation measures beyond these actions would be feasible. Thus, the water supply impact is considered significant and unavoidable.

Wastewater Treatment
Threshold UTL-3: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would result in a determination by the wastewater treatment provider which serves or may serve the Project that it does not have adequate capacity to serve the Project’s projected demand in addition to the provider’s existing commitments.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-47 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Statement UTL-3: The existing wastewater treatment facilities serving the Project would have sufficient capacity to treat the projected wastewater demand generated by the Project. Therefore, the Project would result in a less-than-significant impact related to wastewater treatment.

General Plan Update
As discussed, implementation of the General Plan Update would result in 21,612 new residents, 12,760 new housing units, 16,804 new jobs, and 3,696,800 new square feet of nonresidential building space through the 2045 horizon year. Future development would result in an increase in the generation of wastewater and demand for wastewater treatment capacity. As the demand for wastewater treatment capacity increases, there may be a need to increase wastewater conveyance and treatment facilities, the construction of which could cause environmental impacts.

Table 4.18-10, Projected Wastewater Generation, shows that implementation of the General Plan Update could result in approximately 4.5 mgd (5,045 AFY). As mentioned in Section 4.18.2, Environmental Setting, wastewater in the Planning Area is treated at either the HWRP or the JWPCP. Based on a current ADFW of 275 mgd and capacity of 450 mgd at the HWRP and a current treatment of 260 mgd and capacity of 400 mgd at the JWPCP, there is a remaining capacity of 175 mgd and 140 mgd, respectively. Given that the Project would generate approximately 4.5 mgd, the remaining treatment capacity at the HWRP and the JWPCP would be sufficient to accommodate the increase in wastewater demand citywide, and no major improvements would be required.

TABLE 4.18-10

PROJECTED WASTEWATER GENERATION
Land Use
Quantity
(Units/Square Feet)
Wastewater Generation Factor
(gpd/unit)a
Total Wastewater Generation
(gpd)
Residential 12,700 units 260 gpd/unit 3,302,000 gpd
Commercial 5,968,000 sf 0.20 gpd/square foot 1,193,600 gpd Industrial 679,700 sf 0.025/square foot 16,993 gpd
Institutional 0 sf 0.2 gpd/square foot 0 gpd
Project Total 4,512,593 gpd
NOTES: sf = square feet; gpd = gallons per day.
a The wastewater generation factors are based on LACSD’s wastewater generation factors. Los Angeles County Sanitation Districts, 2023b. Loadings for Each Class of Land Use.

SOURCE: ESA, 2023.

No new major sewer upgrades are anticipated or proposed as part of the General Plan Update.

All new development in the city would be subject to sewer capacity considerations as part of the City review process. Improvements and upgrades to sewer lines are prioritized based on need.

Development fees are collected from each project and used to fund the highest priority improvements.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-48 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
The proposed land use changes associated with the General Plan Update and the increase in wastewater flows would not exceed the treatment capacity at the HWRP or the JWPCP.

Therefore, impacts related to wastewater would be less than significant.

In addition, the City would review applications for subsequent development for compliance with the applicable requirements to ensure there is sufficient wastewater treatment capacity to serve the development. Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
There are no goals or policies specifically related to wastewater management.

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 wastewater treatment.

Solid Waste
Threshold UTL-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals.

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

General Plan Update
As described in Section 4.18.2, Environmental Setting, all trash collection in the city is managed by the City’s EPO with all residential, commercial and industrial solid waste in the city collected by the EPO or its authorized agents. Once collected, the majority of solid waste is disposed of at County landfills.

The General Plan Update is projected to accommodate 21,612 new residents, 12,706 new housing units, 16,804 new jobs, and 3,696,800 new square feet of nonresidential building space by the 2045 horizon year. Development and growth in the city would increase the generation of solid waste (both construction and operational waste) which could exceed state or local

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-49 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
standards, exceed local infrastructure capacity, or otherwise impair the attainment of solid waste reduction goals.

Construction waste would be required to be diverted from landfills in accordance with Municipal Code Section 15.02.1140. As required, a minimum of 75 percent of the nonhazardous construction and demolition debris from new development or redevelopment would be recycled and/or salvaged for reuse. Construction-related waste including, but not limited to, soil, asphalt, wood, paper, glass, plastic, metals, and cardboard would be disposed of in one of a number of inert debris engineered fill operations that are located throughout the county. Any contaminated soil that is found during excavation would be assumed to be disposed of in a facility that could accept such waste.

As shown in Table 4.18-11, Estimated Solid Waste Generation, operationally, future development allowed under the Project would generate approximately 41,354.5 tons or 29,538.9 cubic yards of solid waste annually.

TABLE 4.18-11

ESTIMATED SOLID WASTE GENERATION
Category Net New
Disposal Ratea
(pounds/capita/day)
Solid Waste Generation (daily) Annual Solid Waste Generation Pounds/Capita/Day Tons Annual Tons Cubic Yardsb
Residents 21,612 6.6 142,639 71.3 26,024.5 18,588.9
Jobs 16,804 5.0 84,020 42.0 15,330.0 10,950.0
Total 226,659 113.3 41,354.5 29,538.9
NOTES:
a Disposal rate based on CalRecycle’s calculated disposal rate for 2021 (most recent available information). b One cubic yard = 1.4 tons
SOURCE: ESA, 2023.

For the solid waste that would be disposed of at landfills, the 10 Class III landfills in the county have a combined remaining capacity of approximately 142.67 million tons. The annual solid waste generated by the Project would represent approximately 0.3 percent of the remaining capacity of these landfills. Over the life of the General Plan Update, it is anticipated that 827,090 tons would be generated which is 0.5 percent of the remaining capacity. Therefore, the remaining capacity would be sufficient to accommodate the solid waste generated by future development that would occur from the implementation of the General Plan Update. In addition, all future development projects proposed in the City would be required to comply with federal, state, and local statutes and regulations related to solid waste, including the California Code of Regulations, California PRC, and Culver City General Plan and Municipal Code.

Therefore, the Project would not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or otherwise impair the attainment of solid waste reduction goals. Impacts would be less than significant.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-50 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 in 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 result in the generation of solid waste in excess of state or local standards or in excess of the capacity of local infrastructure. Furthermore, future development allowed under the Project would be reviewed by the City for compliance with applicable requirements. Therefore, potential Project impacts with respect to solid waste generation are considered less than significant.

Applicable Proposed General Plan Goals and Policies
There are no goals or policies specifically related to solid waste generation.

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 solid waste generation.

Solid Waste Regulations
Threshold UTL-5: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would not comply with federal, state , and local management and reduction statutes and regulations related to solid waste.

Impact Statement UTL-5: The Project would comply with applicable federal, state, and local management and reduction statutes and regulations related to solid waste and therefore, impacts would be less-than-significant impact.

General Plan Update
As discussed, development and growth in the Planning Area would increase the generation of solid waste (both during construction and operation) which could exceed state or local standards, exceed local infrastructure capacity, or otherwise impair the attainment of solid waste reduction goals.

In accordance with City requirements, future development allowed under the Project would be served with solid waste and recycling services provided by the City or its authorized agents (Municipal Code Section 5.01.01). In addition, a minimum of 75 percent of the nonhazardous construction and demolition debris from new development would be recycled and/or salvaged for reuse (Municipal Code Section 15.02.1140). Future development allowed under the Project would also be required to comply with statewide requirements, including AB 341, AB 939, SB 1016, and SB 1383, which require waste reduction, recycling, and diversion. Therefore, future development allowed under the Project would comply with federal, state, and local management and reduction statutes and regulations related to solid waste, and the impact would be less than significant.

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-51 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Zoning Code Update
Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not conflict with applicable federal, state, and local management and reduction statutes and regulations related to solid waste. Therefore, potential Project impacts with respect to solid waste statutes and regulations are considered less than significant.

Applicable Proposed General Plan Goals and Policies
There are no goals or policies specifically related to solid waste.

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 solid waste statutes and regulations.

4.18.5 Cumulative Impacts Analysis
Water Supply
The geographic context for the analysis of cumulative impacts related to water supply includes the GSWC and LADWP service areas. Overall, as described in detail in Section 4.18.4, cumulative water demands could exceed planned levels of supply or which could potentially require building new water treatment facilities or expanding existing facilities beyond what is currently planned under normal, single dry, and multiple dry years. However, each individual project would be required to demonstrate the availability of water to service the development. Cumulative projects would be required to demonstrate compliance with the statutory requirements listed in the regulatory section, and the General Plan Update would ensure that cumulative development in the Planning Area would comply with the state and federal regulatory requirements. As discussed under Impact UTL-2, if the water service providers should experience a shortage of supply during a drought, a WSCP is in place to reduce water consumption. This measure would be implemented in conjunction with other state, county, and local water conservation requirements and water efficiency measures. When applicable, any additional new development within the Planning Area would be subject, on a project-by-project basis, to independent CEQA review as well as policies in the General Plan, the City’s Municipal Code, and compliance with current regulations, including and SB 610 and SB 221, which require WSAs for large development projects prior to approval. All cumulative projects would be subject to local, state, and federal permit requirements and would be required to comply with City/County ordinances and General Plan policies, as well as other regulations that address water supply.

While future development allowed under the General Plan Update would be required to follow water reduction policies outlined in the General Plan Update and the City’s Municipal Code, water supply projections would not be sufficient for projected water demand associated with future development allowed under the General Plan Update. Therefore, the Project’s contribution to cumulative impacts would be cumulatively considerable. Future development allowed under the General Plan Update would contribute to an increased cumulative demand for water supply, and the growth within the water purveyors’ service areas will need to be

4. Environmental Impact Analysis

4.18. Utilities and Service Systems
General Plan 2045 and Zoning Code Update Project 4.18-52 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
considered in the next cycle of UWMPs. Accordingly, impacts associated with future development allowed under the General Plan Update would be cumulatively considerable.

Growth associated with the 6th Cycle RHNA allocation of housing needs would increase demand and affect the water supply reliability throughout the region, and would result in a significant cumulative impact. For these reasons, future development allowed under the General Plan Update in conjunction with other cumulative projects would be cumulatively considerable and impacts would be potentially significant.

Wastewater
The geographic context for the analysis of cumulative impacts related to wastewater conveyance and treatment includes the LASAN and LACSD wastewater services areas. All cumulative projects would be required to comply with applicable City/County ordinances and General Plan policies, as well as other regulations related to wastewater collection and treatment. As described under Impact UTL-3, there is sufficient wastewater conveyance and treatment capacity available to serve the Project. As such, the Project’s contribution to wastewater impacts would not be cumulatively considerable.

While future development allowed under the General Plan Update would result in an increased demand for wastewater collection and treatment, such wastewater collection and treatment can be accommodated (see Impact UTL-3). In addition, future projects would be required to comply with the requirements of the applicable General Plan and the City’s Municipal Code that aim to reduce wastewater generation flows. For the reasons described, impacts of the Project related to wastewater conveyance and treatment in conjunction with other cumulative development is not cumulatively considerable. The Project’s contribution to cumulative impacts would be less than significant.

Solid Waste
The geographic context for the analysis of cumulative impacts associated with solid waste includes the jurisdictions that are served by the Los Angeles County landfills. Cumulative development within other jurisdictions would contribute to an incremental increase in solid waste delivered to these landfills. Other future projects within the cumulative geographic context would be required to comply with applicable federal, state, and local laws and policies, including AB 341, AB 939, SB 1016, and SB 1383, which require waste reduction, recycling, and diversion. While development and growth in the city under the Project would result in an increased generation of solid waste, the affected landfills would have enough capacity to serve the City (see Impact UTL-4). In addition, future development allowed under the Project would be required to comply with policies and programs of the General Plan and the regulations of the Municipal Code that aim to divert solid waste from landfills. As with the City, all jurisdictions within the region would be required to comply with existing as well as new federal, state, and local statutes and regulations related to solid waste. Therefore, cumulative impacts related to solid wase capacity and compliance with regulatory requirements would be less than significant.

4. Environmental Impact Analysis

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General Plan 2045 and Zoning Code Update Project 4.18-53 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Storm Drainage
The geographic context for analysis of cumulative impacts to storm drain facilities includes the area surrounding the Planning Area. Cumulative development contributes to an incremental increase in impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities requiring relocated or new facilities. All cumulative projects would be required to comply with City/County ordinances and General Plan policies, as well as other regulations that minimize stormwater runoff. For these reasons, cumulative impacts to storm drainage would be less than significant.

4. Environmental Impact Analysis

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4. Environmental Impact Analysis
General Plan 2045 and Zoning Code Update Project 4.19-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision

4.19 Wildfire

4.19.1 Introduction
This section provides an analysis of the potential local and regional environmental impacts on wildfire from implementation of the Project, including potential impacts related to emergency response or evacuation plans, exacerbating wildfire risks, installing or maintenance of associated infrastructure which exacerbate fire risk, and exposing people or structures to significant risks. The section provides context regarding the Planning Area’s existing fire protection responsibility, wildfire hazards, and emergency response and evacuation plans, as well as relevant federal, State, and local regulations and programs. Additional analysis related to fire risks with the Project is addressed in Section 4.8, Hazards and Hazardous Materials.

4.19.2 Environmental Setting
Culver City and its Sphere of Influence (SOI) (Planning Area) is a highly developed, urban environment located approximately five miles east of the Pacific Ocean, five miles north of Los Angeles International Airport, and eight miles west of downtown Los Angeles. Most of the land area within city limits is developed with urban and suburban development of differing types and densities. However, a few undeveloped or semi-open space areas remain, including Blair Hills, Culver City and Fox Hills Parks, Hillside Memorial and Holy Cross Cemeteries, and portions of the Inglewood Oil Field (IOF) and Kenneth Hahn State Recreation Area. Various habitats and vegetation communities are present within the Planning Area including Coastal Scrub, Coastal Scrub – Degraded, Channelized Streambed (Ballona Creek), Coast Live Oak Woodland, Non- native/Ornamental, Non-native Tree Stands, and Disturbed. Significant remnant patches of native vegetation, and to a lesser degree ornamental and landscaped vegetation, remain within the Planning area, particularly within the Kenneth Hahn State Recreation Area and the portion of the IOF located in the unincorporated County within the SOI.

Fire Protection Responsibility
The entirety of the Planning Area is designated as a Local Responsibility Area (LRA) by the California Department of Forestry and Fire Protection (CAL FIRE), where the local jurisdiction has the responsibility to provide fire protection services for the area. The same is true for the surrounding City of Los Angeles and unincorporated portions of Los Angeles County.

The Culver City Fire Department (CCFD) provides fire protection and emergency services to the entirety of the city. CCFD is made up of a total of 72 employees who are housed at three fire stations (headquartered at Fire Station# 1).
1 Each fire station is equipped with unique

1 Culver City Fire Department, 2019a. Culver City Fire Department Strategic Plan 2019-2024. https://www.culvercityfd.org/About-the-Department/Documents. Accessed May 2023.

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-2 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
equipment and personnel needed to serve the community, with at least 18 sworn personnel on duty at all times.2 The three stations located within Culver City include the following:
• Station #1 (Headquarters) at 9600 Culver Boulevard. This station houses an engine company with a crew of three people (captain, engineer, and firefighter), paramedic resources with a crew of two firefighter/paramedics with advance life support (ALS) certification, and a battalion chief command vehicle for the battalion chief. • Station #2 at 11252 Washington Boulevard. This station houses an engine company with a crew of three people (captain, engineer, and firefighter) and an ambulance with two emergency medical technicians (EMTs).
• Station #3 at 6030 Bristol Parkway. This station houses two engine companies with a crew of three people (captain, engineer, and firefighter) and a crew of four people (captain, engineer, and two firefighters) and paramedic resources with a crew of two firefighter/paramedics with ALS certification.

In addition to its own fire protection services, CCFD has entered into various cooperative and fire assistance agreements with other federal, State, and local jurisdictions within the region and state. Based upon these agreements, most wildfire events and other largescale incidents are responded to by multiple agencies operating under the varying levels of the incident command structure, which is a standardized approach to the command, control, and coordination of emergency response providing a common hierarchy within which responders from multiple agencies can be effective. In such instances, CCFD personnel and equipment could respond to incidents outside of the Department’s formal area of responsibility. Conversely, other emergency services organizations throughout the region and state could respond to incidents within CCFD’s area of responsibility if needed.

The Los Angeles County Fire Department (LACFD) provides fire protection and emergency medical services to the area within the City’s SOI. LACFD services about 2,300 square miles, including 60 cities and unincorporated communities, and serves approximately 4.1 million residents. There are 4,700 total personnel working within LACFD’s emergency and business operations bureaus, including firefighters, dispatchers, lifeguards, nurses, and administrative support. LACFD stations are located nearby in the City of Los Angeles and unincorporated Los Angeles County. The nearest LACFD stations to the Planning Area are Station #43 located at 3690 Motor Ave in the City of Los Angeles approximately one mile north of the Planning Area, and Station #94 located at 4470 Coliseum Street in the City of Los Angeles approximately one mile east of the Planning Area.

Wildfire Hazards
A wildland fire is a large destructive fire that can spread quickly through vegetative fuels.3 Wildfires can be caused by human error (such as campfires), intentionally by arson, by

2 Culver City Fire Department, 2019b. Community Risk Assessment, Standards of Cover. https://www.culvercityfd.org/files/sharedassets/fire/crasoc_website_20190618.pdf. Accessed May 2023. 3 Culver City, 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed May 2023.

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
mechanical sources of ignition (such as heaters and generators), and by natural events (such as lightning). Electrical equipment, such as power lines and transformers, can also cause a wildfire.

Wildfires often occur in forests or other areas with ample vegetation. In areas where structures and other human development meets or intermingles with wildland 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 more recent 2019 Getty Fire in Los Angeles, 2003 Padua Fire in Los Angeles County, and the 1993 Topanga Fire in Malibu).

There are three categories of WUI fire: 1) where well defined urban and suburban development presses up against open wildland areas; 2) where isolated homes characterize the mixed WUI (subdivisions and small communities situated predominantly in wildland settings); and 3) where islands of wildland vegetation occur inside a largely urbanized area. Southern California faces challenges with wildfire hazards from the increasing number of houses being built in the WUI.

Every year the growing population has expanded further into the hills and mountains, including into forest lands. The increased interface between urban/suburban areas and the open spaces created by this expansion has produced a significant increase in threats to life and property from fires and has pushed existing fire protection systems beyond original or current design and capability.

Certain conditions must be present for significant interface fires to occur. The most common conditions include hot, dry and windy weather; the inability of fire protection forces to contain or suppress the fire; the occurrence of multiple fires that overwhelm committed resources; and a large fuel load (dense vegetation). Once a fire has started, several conditions influence its behavior, including fuel topography, weather, drought, and development.

Locally, the WUI is present in the eastern portion of the Planning Area. 4 Wildlands located within
Los Angeles County are directly adjacent to the Blair Hills and Culver Crest neighborhoods within the city. CAL FIRE prepares fire hazard severity maps including mapping areas of significant fire hazards based on fuels, terrain, weather, and other relevant factors, referred to as Fire Hazard Severity Zones (FHSZs). In 2011, CAL FIRE developed a FHSZ map, which identified the eastern portion of the Planning Area in a Very High FHSZ (VHFHSZ), as shown in Figure 4.19-1, Wildfire Hazard Severity Zones. The VHFHSZ area in the Planning Area includes the eastern portion of the Culver Crest neighborhood, the Blair Hills neighborhood, and areas within the IOF. CAL FIRE has made subsequent updates to their FHSZ map, which removed the Blair Hills neighborhood and areas within the IOF. However, based on the recommendation of the CCFD and City staff, Culver City still utilizes the 2011 Cal Fire FHSZ map for wildfire planning efforts.

4 Culver City, 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed 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 (2023); CalFire (2011); ESRI (2021).

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

Sepulveda Blvd.

OverlandAve.CulverBlvd.

S lauson Ave.

DuquesneAve.

National Blvd.

Bristol Pa rkw
ay
Washington Pl.

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

Washington Blvd.

Unincorporated
County
Venice Blvd.

La Cienega Blvd.

Venice Blvd.

Washington Blvd.

La Cienega Blvd.Sepulveda Blvd.

City Limits
Sphere of Influence
Metro Station
E Line (Expo)
Major Roads
Local Roads
Parks and Open Space
Waterbody
Local Responsibility Area
Very High Fire Hazard 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); CalFire (2011); 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
Local Responsibility Area
Very High Fire Hazard Zone
Culver City General Plan 2045
Figure 4.19-1
Wild/f_ire Hazard Severity Zones
SOURCE: City of Culver City, 2021; County of Los Angeles, 2023; CalFire, 2011; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

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Emergency Response and Evacuation Plans
As discussed in Section 4.8, Hazards and Hazardous Materials, emergency response plans include elements to maintain continuity of government, emergency functions of governmental agencies, mobilization and application of resources, mutual aid, and public information during an emergency. Emergency response plans are maintained at the federal, State, and local levels for all types of disasters, including human-made and natural. It is the responsibility of the government 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.
5 City staff have been designated to coordinate all State Emergency Management System (SEMS) functions. During the response phase, the Fire Station 1’s Emergency Operations Center (EOC) serves as the coordination and communication point, and the access to the Los Angeles County Operational Area.

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 Multi-Jurisdictional Hazard Mitigation Plan (MJHMP). 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.

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 Works Department, LACSD, and LACFD, three representative emergency scenarios have been identified which would require an evacuation of populations within select evacuation zones

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

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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. 6 Interstates 10 (I-10) and 405 (I-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.

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

Federal
National Fire Protection Association
The National Fire Protection Association (NFPA) is a non-profit organization with a mission to eliminate death, economic loss, and property damage from fire, electrical and associated hazards. The NFPA design, building and installation criteria includes 300 codes and standards which aim to minimize the risk of fire incidents.

NFPA 1710, Standard for the Organization and Deployment of Fire Suppression Operations, Emergency Medical Operations, and Special Operations to the Public by Career Fire Departments, establishes a recommended response time for dispatched incidents. NFPA recommends that fire departments respond to emergency calls within six minutes of receiving the call, 90 percent of the time.

State
California Department of Forestry and Fire Protection Threat Potential Mapping CAL FIRE has mapped fire threat potential throughout California, based on the availability of fuel and the likelihood of an area burning (based on topography, fire history, and climate). The threat levels include no fire threat, Moderate, High, and Very High fire threat. CAL FIRE produced a 2010 Strategic Fire Plan for California, which contains goals, objectives, and policies to prepare for and mitigate the effects of fire on California’s natural and built environments. CAL FIRE’s Office of the State Fire Marshal provides oversight of enforcement of the California Fire Code (CFC) as well as overseeing hazardous liquid pipeline safety.

California Health and Safety Code (Section 13000 et seq.) Section 13000 et seq. of the California Health and Safety Code outlines state fire regulations such as building standards, fire notification systems, fire protection devices (extinguishers and smoke alarms), high-rise building standards, and childcare facilities standards. The State Fire

6 Culver City and Culver City Unified School District, 2023. Evacuation Route Capacity and Viability Study.

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Marshall is responsible for enforcing the regulations and standards outlined in Section 13000 et seq. of the California Health and Safety Code.

Emergency Services Act
Under the Emergency Services Act, Government Code Section 8550, et seq., the State developed an emergency response plan to coordinate emergency services provided by federal, State, and local agencies. Rapid response to incidents involving wildfire and other natural and/or human- caused incidents is an important part of the plan, which is administered by the Governor’s Office of Emergency Services (OES). The office coordinates the responses of other agencies, including the California Environmental Protection Agency (Cal/EPA), California Highway Patrol (CHP), regional water quality control boards, air quality management districts, and county disaster response offices.

California Fire Code
The 2022 CFC, written by the California Building Standards Commission, is based on the 2021 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 California Code of Regulations (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 WUI and fire hazard areas. The CFC also provides regulations and guidance for local agencies in the development and enforcement of fire safety standards.

California Public Resources Code
Fire Hazards Severity Zones – Public Resources Code Sections 4201–4204 California Public Resources Code (PRC) Sections 4201 through 4204 require CAL FIRE to prepare FHSZ maps for all lands within State Responsibility Areas (SRAs), and to make recommendations for such zones in LRAs. Each zone is to embrace relatively homogeneous lands and is to be based on fuel loading, slope, fire weather, and other relevant factors present, including areas where winds have been identified as a major cause of wildfire spread. CAL FIRE adopted a FHSZ map for Culver City in 2011.

California Building Code
In January of 2008, California officially switched from the Uniform Building Code to the International Building Code (IBC). The IBC specifies construction standards to be used in urban interface and wildland areas where there is an elevated threat of fire.

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Assembly Bill 747
Assembly Bill (AB) 747 was adopted in 2019 and requires safety elements to be reviewed and updated as necessary to identify evacuation routes and their capacity, safety, and viability under a range of emergency scenarios. The law authorizes a city or county that has adopted a local hazard mitigation plan, emergency operations plan, or other document that fulfills commensurate goals and objectives to use that information in their Safety Element to comply with this requirement by summarizing and incorporating by reference that other plan or document in their Safety Element.

Senate Bill 99
SB 99 was adopted in 2019, and requires a city or county, upon the next revision of their Housing Element on or after January 1, 2020, to review and update the Safety Element to include information identifying residential developments in hazard areas that do not have at least two emergency evacuation routes.

Senate Bill 901
SB 901 mandates all electric utilities to prepare and submit wildfire mitigation plans that describe the utilities’ plan to prevent, combat, and respond to wildfires affecting their service territories. The California Public Utilities Commission (CPUC) will review and refine the plans before implementing and enforcing them.

Senate Bill 1241
In 2012, Senate Bill 1241 added Section 66474.02 to Title 7 Division 2 of the California Government Code, commonly known as the Subdivision Map Act. The statute prohibits subdivision of parcels designated very high fire hazard, or that are in an SRA, unless certain findings are made prior to approval of the tentative map. The statute requires that a city or county planning commission make three new findings regarding fire hazard safety before approving a subdivision proposal. The three findings are, in brief: (1) the design and location of the subdivision and its lots are consistent with defensible space regulations found in PRC Section 4290–91, (2) structural fire protection services will be available for the subdivision through a publicly funded entity, and (3) ingress and egress road standards for fire equipment are met per any applicable local ordinance and PRC Section 4290. The Occupational Safety and Health Act (29 Code of Federal Regulations [CFR] Parts 70 to 2400), which is implemented by the Federal Occupational Safety and Health Administration (OSHA), contains provisions with respect to hazardous materials handling. Federal OSHA requirements, as set forth in 29 CFR Section 1910 et seq., are designed to promote worker safety, worker training, and a worker’s right–to-know.

In California, OSHA has delegated the authority to administer OSHA regulations to the State of California.

Regional
2022 Los Angeles County Fire Department Strategic Fire Plan Los Angeles County is one of six contract counties that have executed a contract with the State of California to provide wildland fire protection on SRAs. The LACFD has the responsibility as

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part of a contract county to implement the State Strategic Fire Plan, and functionally operates as a unit of CAL FIRE and is responsible for Strategic Fire Plan activities in Los Angeles County. The 2022 LACFD Strategic Plan includes three goals: emergency operations, public service, and organizational effectiveness. The 2022 LACFD Strategic Fire Plan includes goals for LACFD related to analyzing the threat of wildfire to communities in the WUI; implementing fuel reduction projects; developing battalion specific asset maps, strategies, and tactics; and identifying fire prevention strategies that are consistent with LA County’s land use planning strategies. LACFD also includes goals to support local Fire Safe Councils and to work with communities to develop community wildfire protection plans.
7 Los Angeles County Fire Department Programs
LACFD has adopted the CFC for regulations and standards that are applied to new development in hazardous fire areas. These standards and requirements include the provision of access roads, adequate road widths, all-weather access, fire flow requirements, fire hydrant spacing, and vegetation clearance. Los Angeles County Fire Code (LACFC) Sections 325.2.1.2, 328,10, 11117.2.1, and 4908.1 require that projects in areas located in VHFHSZs complete and seek approval of a land development plan and a fuel modification plan. The Los Angeles County Code also includes restrictions, permit requirements, and requirements for fire suppression equipment for activities and housing in fire-prone areas. The LACFC includes provisions for the use and storage of hazardous, flammable, and combustible material. It also includes fire safety requirements for construction and demolition, construction requirements for buildings, as well as requirements for land uses such as energy systems and biomass facilities.

LACFD has instituted a variety of programs to reduce wildfire-related threats. These relate to pre-fire management and defensible space planning, vegetation management (focusing on the use of prescribed fire; hand crews; and mechanical, biological, and chemical means to address wildland fire fuel hazards in SRAs and LRAs) and brush clearance, 8,9 as well as fuel
modification.10 In addition to these programs, LACFD and the Los Angeles County Department of Public Works enforce fire and building codes related to development in FHSZs.

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

7 Los Angeles County Fire Department, 2022. 2022 Strategic Fire Plan. https://osfm.fire.ca.gov/media/ugwfw535/2022-los-angeles-county-unit-fire-plan.pdf. Accessed May 2023. 8 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.
9 Los Angeles County Fire Department, 2023a. Fire Hazard Reduction Programs. https://fire.lacounty.gov/fire- hazard-reduction-programs/. Accessed May 2023.
10 Los Angeles County Fire Department, 2023b. Forestry Fuel Modification. Available online at:
https://fire.lacounty.gov/forestry-fuel-modification/. Accessed May 2023.

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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 2020.11 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 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 the California Governor’s Office of Emergency Services (Cal OES) and the Federal Emergency Management Agency (FEMA) on June 1, 2017.

Culver City Municipal Code
Chapter 9.02, Fire Prevention, of the Culver City Municipal Code (CCMC) contains the City’s Fire Code, which incorporates by reference the IFC and CFC, with City amendments for additional requirements. The CCFD is responsible for implementing the City’s Fire Code as well as reviewing and approving building plans and permits to ensure compliance with applicable fire safety measures prior to the issuance of building permits.

11 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.

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Culver City Fire Code
CCFD 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. CCFD provides emergency services within Culver City, including for fire 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.

4.19.4 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 wildfire if the project would:

Threshold WF-1: Substantially impair an adopted emergency response plan or emergency evacuation plan.

Threshold WF-2: Due to slope, prevailing winds, and other factors, exacerbate wildfire risks, and thereby expose project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire.

Threshold WF-3: Require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Threshold WF-4: Expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Methodology
This evaluation focuses on whether implementation of the Project would result in changes to the physical environment that would cause or exacerbate adverse effects related to wildfires or whether future development allowed under the Project would be placed in a location susceptible to wildfire or post-wildfire conditions. The evaluation also includes a determination of whether changes to the physical environment caused by the Project would impair or interfere with emergency response plans, expose people to pollutant concentrations from a wildfire or uncontrolled spread of a wildfire, expose people/structures to downslope flooding or landslides, or include installation or maintenance of infrastructure that may exacerbate fire risk. The following analysis is based, in part, on information provided in the Environmental Background Report Existing Conditions Report and CAL FIRE website.

The potential for impacts related to wildfire was assessed by considering future development under the Project that could be constructed in fire hazard severity zones. Because future

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development could be located in or near SRAs or lands classified as very high hazard severity zones, all potential wildfire impacts are analyzed below.

Project Impacts Analysis
Emergency Response or Evacuation Plans
Threshold WF-1: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would substantially impair an adopted emergency response plan or emergency evacuation plan.

Impact Statement WF-1: The Project would not substantially impair an adopted emergency response or evacuation plan as development facilitated under the Project would be required to comply with all applicable regulations, plans, and policies related to emergency response plan or emergency evacuation plan. Therefore, the Project would result in a less than significant impact related to emergency response or evacuation plans.

General Plan Update
As discussed in Section 4.8, Hazards and Hazardous Materials, the continued growth and development associated with implementation of the General Plan Update could have the potential to interfere with an adopted emergency response or evacuation plan if the emergency response services and/or evacuation routes were to become overburdened by the increase in residents or intensity of new development associated with implementation of the General Plan Update.

As Culver City is largely built out, development anticipated as a result of implementation of the General Plan Update would primarily occur as redevelopment within the urbanized areas of the city which are already served by the local and regional transportation systems and have been accounted for in local and regional emergency response and evacuation plans. Through the City’s emergency response and evacuation planning efforts, evacuation routes in the city have been designed to accommodate future development through the Project’s horizon year (2045).

In the event of an evacuation, major freeways including I-10 and I-405 would be used as the main evacuation routes outside of the city. If access to these major freeways is not available, the City has identified alternative emergency evacuation routes, which include Venice Boulevard, Lincoln Boulevard, Jefferson Boulevard, and Sepulveda Boulevard. Evacuation routes as well as important emergency information would be communicated to residents and employers via Everbridge, the City’s Official Emergency Mass Notification System.

In addition to the City’s emergency response systems, 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, including Culver City. The City’s MJHMP also 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.

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In addition to the local and regional emergency response and evacuation plans, the General Plan Update also includes goals and policies, listed below, that aim to continually strengthen emergency response and evacuation services and systems within the Planning Area. Such goals and policies aim to continue updating emergency-related planning documents (including the MJHMP) every five years to ensure consistency with State and federal law, best practices, local conditions, and the most recent science; continue incorporating hazards and mitigation measures identified in the MJHMP into City emergency planning, capital projects, and programs; continue developing and maintaining 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. The Project also includes policies pertaining to evacuation route planning (Policy S-1.3 and Policy S-7.14) and emergency alert systems (Policy S-

3.5). Therefore, implementation of the General Plan Update would not overburden the existing local or regional transportation system, which in turn would interfere with an adopted emergency or evacuation plan.

Future development proposed within the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within the IOF, would be within land designated as a VHFHSZ. However, future development would primarily occur on parcels that already contain existing development. Relevant General Plan Update policies include continuing to enforce the CFC and Municipal Fire Code Amendments for new construction in fire hazard areas, including the use of sprinklers in residential structures (Goal S-7 and Policy S-7.1); developing stringent site design and maintenance standards for areas with high fire hazard or soil erosion potential (Policy S-7.10); 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; 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 (Policies S-1.3 and S-1.7); and requiring all development proposals to identify existing evacuation routes or establish new evacuation routes as needed (Policy S-7.14).

Furthermore, all development associated with implementation of the General Plan Update would be required to demonstrate compliance with applicable building and fire codes and regulations, including the CCMC, CFC, and IFC. Applicable requirements include but are limited to providing multiple points for access for certain types of development, minimum street widths, and maximum acceptable grades for new roads to allow for emergency access for fire apparatuses. Chapter 9.02 of the CCMC requires development to demonstrate compliance with applicable fire safety measures prior to the issuance of building permits. As such, new development associated with implementation of the General Plan Update would be reviewed and approved by CCFD for compliance with applicable Fire Code requirements that pertain to emergency access during the development review process. In addition, development would also be reviewed for consistency with the proposed policies and actions of the General Plan Update, which would further enhance emergency response and evacuation systems and services. By involving CCFD in the development review process, the City would ensure that development is designed to allow for adequate emergency vehicle access and would operate in a manner that minimizes fire hazards and is prepared for emergencies.

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Therefore, compliance with local and regional emergency response, evacuation plans, building regulations and requirements established in the CMCC, as well as consistency with applicable General Plan policies would ensure that the Project would not impede with an adopted emergency or evacuation plan. Thus, 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 in 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 impair an adopted emergency response or evacuation plan. Furthermore, applications would be reviewed by the City for compliance with applicable regulations, including the City’s Zoning Code Update and consistency with the policies of the General Plan Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not impair an adopted emergency response or evacuation plan, and impacts would be less than significant.

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: Evaluation 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.

S-1.7: Hazard risk evaluation. Regularly evaluate, identify and communicate new hazard risks and incorporate them into planning and programs.

Goal S-3: Community engagement. A community that is educated about and engaged in efforts related to reducing hazardous risks and climate change.

S-3.5: Emergency alert systems. Continue to use emergency alert systems, like Everbridge, and coordinate with CCARES and CERT members to notify community members when there is an imminent threat or a need to evacuate.

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

S-7.1: California Building Code and California Fire Code. Continue to adopt and enforce the most up-to-date California Building Code and California Fire Code, with local amendments as appropriate.

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S-7.10: Fire-safe landscapes. Encourage residents to plant and maintain drought- tolerant, 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-7.14: 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 emergency response and evacuation plans.

Exacerbate Wildfire Risks
Threshold WF-2: The Project wou ld have a significant impact if implementation of the General Plan Update and Zoning Code Update would exacerbate wildfire risks due to slope, prevailing winds, and other factors, and thereby expose residents and occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire.

Impact Statement WF-2: Future development that would occur as a result of the General Plan Update and Zoning Code Update would be required to comply with applicable regulations, plans, and policies in place to reduce the risks associated with wildland fires. Therefore, the Project would result in a less than significant impact related to exacerbating wildfire risks.

General Plan Update
As discussed in Chapter 2, Project Description, development associated with implementation of the General Plan Update would primarily occur as redevelopment on parcels that already contain some existing residences or businesses, which are less susceptible to wildland fires than open areas containing vegetation. If a fire were to occur in the more flat and urbanized areas of the Planning Area, the risk of the fire spreading rapidly would be less than in areas with steeper slopes. As shown in Figure 4.19-1, while the majority of the Planning Area is not located within a FHSZ, the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within the IOF, is designated as a VHFHSZ and is adjacent to land designated as a VHFHSZ. Therefore, since the eastern portion of the Planning Area contains slopes and/or steep topography, future development or improvements allowed under the General Plan Update within the eastern portion of the Planning Area could expose people or structures to wildfire spread. In addition, smoke from wildfires occurring in Los Angeles County and across the state have resulted in poor air quality within Culver City. 12 Future development under the Project
could exacerbate wildfire risks such that residents and occupants could be exposed to pollutant concentrations associated with smoke from a wildfire or the uncontrolled spread of wildfire.

12 Culver City, 2017. City of Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/Services/Public-Safety/Hazard-Mitigation-Plan. Accessed July 2023.

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Preliminary − Subject to Revision
Future development allowed under the General Plan Update would be required to comply with all applicable Culver City and CCFD regulations as well as Los Angeles County and LACFD regulations (within the SOI), plans, and policies in place to reduce the risks associated with wildland fires. These regulations, plans, and policies would reduce the potential for exposure to wildland fires through preventive and proactive measures to reduce fuel load (Goal S-7), maintain robust communications (Goal S-3, Policy S-3.4), ensure access to evacuation routes (Policy S-7.14), and ensure that future development projects meet fire protection and emergency access requirements. Compliance with the applicable regulations, plans, and policies would help to reduce the potential for wildfires to start, mitigate the spread of wildfire, and aid in safely evacuating persons affected by wildfires which would reduce the amount of people’s exposure to smoke and air pollution.

The General Plan Update includes goals and policies that would strengthen the City’s emergency services and systems, minimize the risks and hazards of wildfire, and minimize slope instability (Goal S-5, Policy S-5.2). The Safety Element includes various goals and policies that address wildfire risks by focusing on continuing to incorporate and implement the CBC and CFC (Goal S- 7, Policy S-7.1), increase fire awareness and cooperative fire protection and prevention services (Policies S-1.3 and S-1.7), promote fire-safe landscaping (Policy S-7.10), and avoid approving new development in areas susceptible to wildfire risks (Policy S-7.9). In addition, Policy S-7.9 of the Safety Element requires construction methods established in the CFC for areas within fire hazard severity zones to minimize wildfire exposure, hazardous vegetation and fuel management, as well as requires the creation of defensible space around all buildings and structures. Further, the General Plan Update identifies policies to protect the Blair Hills and Culver Crest neighborhoods from effects of geologic hazards associated with unstable slopes. Policies pertaining to site stability (Policy S-5.2), building safety (Policy S-5.3), and geologic hazard management (Policy S-

5.4 and Policy S-5.5) include compliance with standard City requirements, the Hillside Grading and Permitting Ordinance, the California Building Standards Code, and other regulations to reduce wildfire risks due to slope, and thereby expose residents and occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire.

Furthermore, the City would review and approve development facilitated under the General Plan Update on a project-by-project basis, where site conditions would be evaluated for their potential to exacerbate wildfire risks. For parcels located in the VHFSZ that have steep topography or slopes, all development would be required to comply with the CCMC, which includes various requirements for properties that contain slopes of 15 percent or more, including but not limited to preparation of a site-specific Slope Protection and Fire Prevention Landscape Plan and geotechnical and geologic report with detailed topographic survey, incorporation of slope stabilization measures approved by the Culver City Building and Safety Division, and submittal of a hillside grading plan to obtain a grading permit for sloped areas reviewed and issued by the Culver City Building and Safety Division.

Therefore, compliance with the CBC, CFC, and CCMC, the goal and consistency with policies of the General Plan Update, and site-specific recommendations identified prior to project approval would ensure impacts related to exacerbating wildfire risks would be considered less than significant. As a result, the degree of wildland fire hazard would not substantially change with

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
implementation of the General Plan Update, and thereby expose residents and occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire Therefore, impacts related to exacerbating wildfire risks 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 Project occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire due to slope, prevailing winds, or other factors. Furthermore, the City would review development applications for compliance with applicable regulations, the mitigation measures referenced in other sections of this Draft PEIR, and consistency with policies of the General Plan Update, the City’s Zoning Code Update, and. Therefore, future development under the Project would not expose residents and occupants to pollutant concentrations from a wildfire or the uncontrolled spread of wildfire, and impacts would be less than significant.

S-1.7: Hazard risk evaluation. Regularly evaluate, identify and communicate new hazard risks and incorporate them into planning and programs.

Goal S-3: Community engagement. A community that is educated about and engaged in efforts related to reducing hazardous risks and climate change.

S-3.4: Emergency communication policy. Maintain the City’s emergency communication policy and protocols and use City websites, media resources, emergency alert notification systems, social media, and program advertising to provide information and communicate with the community before, during, or after events that threaten community health, safety, and welfare.

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

S-5.2: Site stability. Continue to require the following, when determined necessary, through standards City requirements, the Hillside Granding and Permitting Ordinance, the California Environmental Quality Act (CEQA), and other regulations. • Preliminary geotechnical and geologic investigations in areas with high landslide potential;
• Evaluation of site stability and possible impact on adjacent properties, before final project design is approved, and

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
• Preparation of reports, investigations, and design recommendations for grading permits, building permits, and subdivision applications by a State-geotechnical engineer and State-certified engineering geologist.

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

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

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

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

S-7.1: California Building Code and California Fire Code. Continue to adopt and enforce the most up-to-date California Building Code and California Fire Code, with local amendments as appropriate.

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.

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
S-7.7: Building Code and Fire Code provisions. Enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions. Require additional standards for high-risk, high occupancy, dependent, and essential facilities where appropriate. This shall include assurance that structural and nonstructural architectural elements of the building are designed not to:
• Impede emergency egress for fire safety personnel, equipment, and apparatuses; and
• Hinder evacuation from fire, including potential blockage of stairways or fire doors.

S-7.9: Wildfire risk. If warranted, avoid approving new development in areas subject to wildfire risk. Enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions to reduce wildfire risk. For areas within fire hazard severity zones, the California Ride Code requires construction methods intended to mitigate wildfire exposure, hazardous vegetation and fuel management, and create defensible space around all buildings and structures.

S-7.10: Fire-safe landscapes. Encourage residents to plant and maintain drought- tolerant, 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-7.14: 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 exacerbating wildfire risks.

Installation or Maintenance of Associated Infrastructure Which Exacerbate Fire Risk
Threshold WF-3: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would require the installation or maintenance of associated infrastructure (such as roads, fuel breaks, emergency water sources, power lines or other utilities) that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

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

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
General Plan Update
As discussed above, future development associated with implementation of the General Plan Update would primarily occur as redevelopment on parcels that already contain some existing residences or businesses, which are less susceptible to wildland fires than open areas containing vegetation. As shown in Figure 4.19-1, while the majority of the Planning Area is not located within a FHSZ, the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within the IOF, is designated as a VHFHSZ and is adjacent to land designated as a VHFHSZ outside of the Planning Area.

The Planning Area is generally built-out and existing structures have been built in accordance with fire prevention and protection measures required by the CFC and CBC. Future development allowed under the General Plan Update, including private and public improvements throughout the city, would generally occur in urban and developed areas that contain existing defensible space, roadways, fuel breaks, water sources, power lines, and other utilities. As discussed in Impact UTIL-1, while implementation of the General Plan Update would not require or result in the relocation or construction of new or expanded water, wastewater treatment, and stormwater drainage facilities, it could require or result in the relocation or construction of new or expanded electric power, natural gas, and telecommunications facilities. However, the construction or relocation of these facilities would be subject to environmental review under CEQA and required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. In addition, development allowed under the General Plan Update would occur in urbanized and developed areas where existing infrastructure, including highways and roadways, is already in place. The existing roadway patterns would be retained. While some modifications would occur to accommodate alternate modes of transportation, no new roadways are proposed.

The General Plan Update includes goals and policies that would minimize the risks and hazards of wildfire associated with the installation or maintenance of infrastructure associated with future development under the Project. Policies include requirements to adopt and enforce the most up-to-date California Building Code and California Fire Code (Policy S-7.1); develop design standards and strengthen performance review and code enforcement programs to ensure proposed development incorporates fire prevention features (Policy S-7.4); require 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); enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions (Policy S-7.7); and if warranted, avoid approving new development in areas subject to wildfire risk (Policy S-7.9).

The City would review future development applications for compliance with the relevant policies in the General Plan Update. Furthermore, CCFD or LACFD would review the development plans for any City utilities or fire prevention and protection equipment, such as the installation and maintenance of fire access roadways, access walkways to and around buildings, and hydrant quantity and placement, to ensure compliance with the CFC and CBC. As discussed under Impact WF-2, compliance with CFC, CBC, and consistency with General Plan Update policies, as well as review of all new structures and private and public improvements by CCFD, would ensure that fire risks are not exacerbated. Therefore, the Project does not propose the

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
installation or maintenance of any new infrastructure that would substantially exacerbate fire risk, 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. In addition, the City would review development applications for compliance with applicable regulations, including the Zoning Code Update, and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development under the Project would not require the installation or maintenance of associated infrastructure that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment.

Given that the Zoning Code Update would be consistent with the General Plan Update, the Zoning Code Update would not require the installation or maintenance of associated infrastructure, such as roads, fuel breaks, emergency water sources, power lines or other utilities, that may exacerbate fire risk or that may result in temporary or ongoing impacts to the environment. Thus, impacts would be less than significant.

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

Policy S-7.1: California Building Code and California Fire Code. Continue to adopt and enforce the most up-to-sate California Building Code and California Fire Code, with local amendments as appropriate.

Policy 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.

Policy 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.

Policy S-7.7: Building Code and Fire Code provisions. Enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions. Require additional standards for high-risk, high occupancy, dependent, and essential facilities where appropriate. This shall include assurance that structural and nonstructural architectural elements of the building are designed not to:
• Impede emergency egress for fire safety personnel, equipment, and apparatuses; and
• Hinder evacuation from fire, including potential blockage of stairways or fire doors.

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Policy S-7.9: Wildfire risk. If warranted, avoid approving new development in areas subject to wildfire risk. Enforce the standards and guidelines of the City’s Building Code and Fire Code fire safety provisions to reduce wildfire risk. For areas within fire hazard severity zones, the California Ride Code requires construction methods intended to mitigate wildfire exposure, hazardous vegetation and fuel management, and create defensible space around all buildings and 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 the installation or maintenance of associated infrastructure which exacerbate fire risk.

Expose People or Structures to Significant Risks
Threshold WF-4: The Project would have a significant impact if implementation of the General Plan Update and Zoning Code Update would expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post -fire slope instability, or drainage changes.

Impact Statement WF-4: Future development allowed under the Project would be subject to the applicable regulations and requirements of the City’s Municipal Code as well as policies in the General Plan Update regarding development on unstable geologic soils and controlling stormwater runoff during and after construction. Furthermore, continued implementation of the City’s MJHMP as well as review of development plans by CCFD would ensure that the Project would not expose people or structures to significant risks including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. Therefore, impacts would be less than significant.

General Plan Update
As shown in Figure 4.19-1, the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within the IOF, is designated as a VHFHSZ and is adjacent to land designated as a VHFHSZ outside of the Planning Area. The Blair Hills (located near the Baldwin Hills) and Culver Crest neighborhoods contain sloping hillsides that are susceptible to landslides and flooding after fire has removed protective vegetative cover. These secondary hazards associated with wildfires are described in the City’s MJHMP. In a post-fire scenario, wildfires can cause secondary effects such as transmission line and road destruction as well as reservoir contamination. Slopes that have been stripped of vegetation are exposed to greater amounts of erosive runoff, which can weaken soils and cause slope failure. Major landslides can occur several years after a wildfire. Most wildfires burn hot and for long durations, which can bake soils, especially those high in clay content. This increases the ground imperviousness and runoff generated by storm events, thereby increasing the chance of flooding.

Within portions of the Planning Area with a relatively flat topography, the risk of flooding or landslides after a fire would be negligible due to development that reduces the amount of soil

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
exposed. As described under Impact WF-2, future development or improvements allowed under the General Plan Update within the eastern portion of the Planning Area could expose people or structures to wildfire spread. As discussed above, new development would primarily occur on parcels that already contain some existing homes or businesses.

As described in Section 4.6, Geology and Soils, and Section 4.9, Hydrology and Water Quality, future development allowed under the General Plan Update would be required to comply with all applicable requirements related to soil instability and water quality, including the regulations of the CCMC and policies in the General Plan Update regarding development on unstable geologic soils and controlling stormwater runoff during and after construction. The General Plan Update contains specific policies related to the prevention of flooding, landslides, and drainage changes, including policies that require ensuring prudent development and redevelopment within areas with high landslide potential during environmental and development review processes (Policy S-5.1); sufficiently removing dead, woody vegetation after a catastrophic fire (Policy S-5.6); and studying drainage systems in selected areas at the base of hills (specifically the Blair Hills and Culver Crest neighborhoods) to identify where drainage improvements may be necessary (Policy S-6.8). Combined with the continued implementation of the City’s MJHMP, as well as review of development plans by CCFD, these policies provide additional proactive measures to refine and enhance the resiliency of the Planning Area, as well as strengthening the City’s review of new applications for development to ensure that the Project would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. As such, 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. The City would review development applications for compliance with applicable regulations, including the City’s Zoning Code Update, and consistency with the policies of the General Plan Update and mitigation measures referenced in other sections of this Draft PEIR. Therefore, future development that would occur under the Zoning Code Update would not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes.

Impacts would be less than significant.

Applicable Proposed General Plan Goals and Policies
Safety Element
Goal S-5: Geologic Hazards. The Blair Hills and Culver Crest neighborhoods are protected from the social and economic effects of geologic hazards associated with unstable slopes.

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

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

4. Environmental Impact Analysis

4.19. Wildfire
General Plan 2045 and Zoning Code Update Project 4.19-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Goal S-6: Flood hazards. The community is resilient to flood and inundation hazards.

Policy S-6.8: Drainage systems at base of hills. Study drainage systems in selected areas at the base of hills (specifically the Blair Hill and Culver City Crest Neighborhoods) to identify where drainage improvements may be necessary.

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 exposing people or structures to significant risks.

4.19.5 Cumulative Impacts Analysis
The geographic context for the analysis of potential contributions to cumulative impacts on wildfire consists of the service area of the fire protection providers to the project area. CCFD provides fire protection to the Planning Area. CCFD is supported, when needed, through mutual aid agreements with the fire departments in the City of Los Angeles and Los Angeles County, with further assistance from the cities of Beverly Hills, Santa Monica, and West Hollywood.

Areas surrounding the Planning Area are also within a Very High Fire Hazard Severity Zone.

Construction of two or more projects that occur at the same time and use the same roads could interfere with an adopted emergency response plan or emergency evacuation plan. As discussed previously under WF-1, the City and adjacent jurisdictions have standard requirements in place to address potential impacts to emergency evacuation routes and traffic flow in general during construction. As with projects that would occur from implementation of the General Plan Update, cumulative projects would be assessed by local fire departments for compliance with applicable CFC requirements that pertain to emergency access to maintain traffic flow and prevent interference with emergency access. As such, as with the Project, any cumulative projects would not impair implementation of or physically interfere with an adopted emergency response or evacuation plan. Therefore, the Project would not contribute to a cumulatively significant impact regarding emergency response and evacuation, and the cumulative impact would be less than significant.

For cumulative projects that are within a VHFHSZ adjacent to the eastern boundary of the Planning Area in the City of Los Angeles and unincorporated areas of Los Angeles County, the development of housing or businesses could increase the risk of wildfire by introducing new sources of ignition (i.e., vehicles and residents) into those areas. However, as a condition of approval, and pursuant to the Fire Code of the jurisdictions, all development would be required to comply with requirements relating to emergency planning and preparedness, emergency access, water supply, defensible space and vegetation management, and specific requirements for specialized uses involving flammable and hazardous materials. In addition, the inclusion of fire service features, building services and systems, , fire and smoke protection features, building materials, and construction requirements would reduce impacts associated with development. Further, cumulative projects in surrounding jurisdictions would be required to

4. Environmental Impact Analysis

City Council Meeting AgendaAugust 26, 2024

City Council Meeting Agenda
August 26, 2024