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

4.19. Wildfire
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comply with the CBC, CFC, and local municipal codes which would reduce impacts associated with wildfires. The implementation of these standard requirements would reduce impacts associated with accidental ignitions emanating from project sites and would not 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.

Therefore, there would be no cumulatively considerable effect, and the cumulative impact would be less than significant.

Similar to the Planning Area, the surrounding city of Los Angeles and unincorporated areas of Los Angeles County are largely urbanized, generally outside the SRA and VHFHSZs and include roads and other fuel breaks, emergency water sources, emergency utilities and maintenance of other infrastructure that would reduce impacts from wildfires. However, some areas adjacent to the eastern boundary of the Planning Area are within a VHFHSZ, as noted above. All cumulative projects, including the installation and/or maintenance of associated infrastructure such as roads, fuel breaks, emergency water sources, power lines or other utilities, would be subject to jurisdiction-specific fire protection development standards and be required to comply with City of Los Angeles and Los Angeles County ordinances. Plan review by the local fire department to assist in protecting life and property in the event of a wildfire would also be required prior to approval of future development. Therefore, there would be no cumulatively considerable effect, and the cumulative impact would be less than significant.

Similar to the Planning Area, the surrounding city of Los Angeles and unincorporated areas of Los Angeles County are generally flat, largely urbanized and developed. However, some portions of the surrounding city and county contain steep, undeveloped areas. Post-fire impacts such as slope instability and downstream flooding are more typically associated with steep wildland areas that burn and then erode or slide onto downslope area.

If cumulative projects were to be developed in areas adjacent to steep wildland areas where wildfire could occur, those sloped areas could potentially erode onto the developed areas and create adverse effects. However, any development proposed in these areas would be subject to engineering and permit review as part of the jurisdiction’s approval process. Potential constraints associated with upslope areas or other factors would be evaluated at the time of application and appropriate design standards implemented prior to issuance of building permits.

Therefore, the Project would not contribute to a cumulatively significant impact regarding exposing 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, and the cumulative impact would be less than significant.

4. Environmental Impact Analysis

4.19. Wildfire
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General Plan 2045 and Zoning Code Update Project 5-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CHAPTER 5
Alternatives

5.1 Introduction
This chapter of the PEIR evaluates alternatives to the General Plan Update (Project) and analyzes the comparative environmental impacts associated with each alternative. Under CEQA, and as indicated in California Public Resources Code (PRC) Section 21002.1(a), the identification and analysis of alternatives to a project is a fundamental aspect of the environmental review process intended to consider ways to mitigate or avoid the significant environmental effects of a project.

Guidance regarding the definition of project alternatives is provided in CEQA Guidelines Section 15126.6(a) as follows:

An EIR shall describe a range of reasonable alternatives to the project, or to the location of the project, which would feasibly attain most of the basic objectives of the project but would avoid or substantially lessen any of the significant effects of the project and evaluate the comparative merits of the alternatives.

The CEQA Guidelines emphasize that the selection of project alternatives be based primarily on the ability to reduce significant impacts relative to the proposed project, “even if these alternatives would impede to some degree the attainment of the project objectives or would be more costly” (Section 15126.6(b)). The CEQA Guidelines further direct that the range of alternatives be guided by a “rule of reason,” such that only those alternatives necessary to permit a reasoned choice are analyzed (Section 15126.6(f)).

In selecting project alternatives for analysis, potential alternatives should be feasible. CEQA Guidelines Section 15126.6(f)(1) explains that:

Among the factors that may be taken into account when addressing the feasibility of alternatives are site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries (projects with a regionally significant impact should consider the regional context), and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.

The CEQA Guidelines require the analysis of a “no project” alternative and, depending on the circumstances, evaluation of alternative location(s) for the project, if feasible. Based on the alternatives analysis, an environmentally superior alternative is to be designated. In general, the environmentally superior alternative is the alternative with the least adverse impacts on the environment. If the environmentally superior alternative is the “no project” alternative, the EIR

5. Alternatives
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shall also identify another environmentally superior alternative among the other alternatives (Section 15126.6(e)(2)).

CEQA Guidelines Section 15126.6(d) states that alternatives analysis need not be presented in the same level of detail as the assessment of the proposed project. Rather, the EIR is required to provide sufficient information to allow meaningful evaluation, analysis, and comparison with the proposed project. If an alternative would cause one or more significant impacts in addition to those of the proposed project, analysis of those impacts is to be discussed, but in less detail than for the proposed project.

5.2 Project Objectives
As indicated in Chapter 2, Project Description, of this PEIR, the underlying purpose of the Project is to comprehensively update the General Plan to establish a long-range vision that reflects the unique needs of the city and provides clear direction to improve the quality of life for residents, businesses, and visitors. In addition, the purpose of the Project, which includes updates to portions of the City’s Municipal Code, is also to provide the amendments necessary to the Zoning Code to implement the General Plan Update. Core values include equity and inclusion; sustainability; innovation and creativity; and compassion and community. At the outset of the General Plan Update process, the following Guiding Principles were developed, which are specific and objective benchmarks that guided the development of the General Plan Update:
• Provide high-quality public services through an equitable, adaptive, transparent, accessible, and fiscally sustainable governing structure with intentional investments and regulatory measures;
• Advance racial, demographic, and socioeconomic diversity by supporting a range of housing types for different income levels, household compositions, stages of life, and disadvantaged populations, including persons experiencing homelessness, the elderly, and persons with disabilities;
• Create more opportunities to broaden and deepen civic engagement that bring more of Culver City’s diverse voices to the decision-making table; • Adopt innovative and equitable policies to eliminate greenhouse gas emissions (decarbonize buildings and industry), reduce energy and water use, encourage the purchase of 100 percent renewable, carbon-free electricity, foster the transition to zero-emission vehicles, and adapt to climate disruption, ensuring all residents, are resilient to climate hazards;
• Foster harmony between people and the environment through continued sustainability efforts, urban ecology, and stewardship of natural resources, like the Ballona Creek and Baldwin Hills, for the benefit of future generations;
• Cultivate social connections between residents, workers, businesses, and visitors through urban design that sustains and revitalizes the public realm, creates great places to gather, adapts to a changing climate, and promotes public safety;

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• Be a creative and proactive leader in solving regional, state, and national challenges around issues like housing, mobility, public safety, equity, climate change, and environmental pollution and disruption;
• Elevate community health and health equity through new, improved, and well-maintained public amenities that are accessible to all— like parks, sport courts and fields, gathering places, healthy and affordable food, natural resources, and community services— that allow people of all ages and abilities to thrive physically, socially, and mentally; • Sustain arts and culture in Culver City, including visual, performing, literary, and culinary arts. Support the continued preservation of historic and cultural resources in Culver City; • Support the continued growth of creative industries as the cornerstone of the renowned arts and cultural identity and unique regional economic role of Culver City, including digital media, architecture and interior design, and visual and performing arts; • Practice resilient and sustainable solutions to maintain and improve infrastructure, including water, road infrastructure, and broadband. Ensure these solutions are implemented equitably throughout the city. Embrace innovative and responsible use of technology to improve City operations, enhance public participation, and build smart, secure, and adaptable infrastructure systems;
• Build more active and shared modes of getting to, from, and through Culver City by providing more reliable, safe, affordable, clean, and connected carbon-free transportation and mobility options for people of all ages and abilities; • Support a diversified, adaptable, and sustainable economy with a balance of small and large businesses across a range of industries that provide employment, commercial, and experiential opportunities. Ensure the economy is resilient to shocks and stresses, like pandemics, seismic events, flooding, wildfires and other natural and human made disasters.

5.3 Alternatives Considered and Rejected
As discussed above, CEQA Guidelines Section 15126.6(c) provides that an EIR should identify alternatives that were considered for analysis but were rejected and briefly explain the reasons for their rejection. Among the factors described by CEQA Guidelines Section 15126.6 in determining whether to exclude alternatives from detailed consideration in an EIR are failure to meet most of the basic objectives of a project, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts.

Feasibility is defined in CEQA as “capable of being accomplished in a successful manner within a reasonable period of time, taking into account economic, environmental, social, and technological factors” (PRC Section 21061.1). CEQA Guidelines Section 15126.6(f)(1) specifies factors that may be taken into account when addressing the feasibility of alternatives; these factors include site suitability, economic viability, availability of infrastructure, general plan consistency, other plans or regulatory limitations, jurisdictional boundaries and whether the proponent can reasonably acquire, control or otherwise have access to the alternative site.

5. Alternatives
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Finally, alternatives that would neither avoid nor substantially lessen any of the significant unavoidable environmental effects of the project need not be evaluated in an EIR. 1 Such alternatives can therefore be considered infeasible. Due to the nature of the Project being a general plan update, which is specific to the jurisdiction it is prepared for, evaluation of an alternative location alternative is infeasible and therefore, is not included below.

As discussed in Chapter 1, Introduction, the City initiated the General Plan Update process in 2019 with a series of community outreach events and launch of the project website (pictureculvercity.com). The planning process was guided by a General Plan Advisory Committee (GPAC) and technical advisory committees (TACs) with several meetings of the Planning Commission and the City Council at key stages.

As a result of input received on the key issues and community needs, potential land use approaches for the General Plan Update were developed. On June 23, 2021, three land use alternatives were considered in a joint session held with the City Council and Planning Commission to determine the preferred alternative. The three land use alternatives considered represented different land use scenarios that could achieve the City’s community vision over the next 25 years.

The three land use alternatives considered different land use and urban design patterns in order to illustrate the trade-offs between policy questions for the General Plan Update, which helped the City to make informed decisions about how the General Plan Update would guide growth into the future. The three land use alternatives were Concentrated Growth, Dispersed Infill, and Dispersed Densification. Figure 5-1, Land Use Alternatives Conceptual Comparison, illustrates the conceptual differences between the three alternatives. Based on input from the City Council and Planning Commission, the Dispersed Infill Alternative was selected as the basis for the Project. The Concentrated Growth Alternative that was developed in the process is evaluated as an alternative in Section 5.5 below.

The following is a discussion of the Dispersed Densification Alternative considered during the planning process and the reasons why it was not selected for detailed analysis in this Draft PEIR.

The City also considered and rejected a Reduced Buildout Alternative, which is also discussed below.

5.3.1 Dispersed Densification Alternative
The Dispersed Densification Alternative distributes new growth across the city but at higher densities than the Project. Under this alternative, identified opportunity sites would accommodate high-density mixed-use development. The larger mixed-use developments on opportunity sites would activate the street frontage to encourage pedestrian activity. While the focus would be commercial uses, there would also be residential infill. Development along the commercial corridors would be allowed a greater mix and intensity of uses compared to the Project.

1 See, e.g., City of Maywood v. Los Angeles Unified School District (2012) 208 Cal.App.4th 362, 419.

Culver City General Plan 2045
Figure 5-1
Land Use Alternatives Conceptual Comparison
SOURCE: General Plan 2045 Culver City, 2023D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator

Dispersed Inﬁll
Selected as the basis for the Project
Dispersed DensiﬁcationConcentrated Growth

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In addition, under this alternative, incremental and moderate densification2 would occur in the single-family and low-density residential areas. Lot consolidation would be encouraged in existing low and medium density multifamily areas in order to achieve larger lot sizes. In addition, an increase in lot sizes and increase in building heights would be needed to accommodate more dense development. It would be expected that low-density, single-family areas would evolve over time with incremental densification of up to 8 units on a lot. The increase in height and densification would alter the existing character, particularly in the single- family neighborhoods.

The increased residential densities proposed for low- to medium-density residential areas was considered to be too intense for the existing character of these areas. In addition, this alternative was considered to conflict with the Project’s objective of guiding future development that would preserve and enhance community character and environmental resources. The increased densities in the low to medium residential areas would be inconsistent with existing development in those areas. Since this alternative would be in conflict with the goal of the City’s General Plan to provide a long-range vision for the city which balances growth and development with community needs and desires, the Dispersed Densification alternative is eliminated from further consideration in this PEIR.

5.3.2 Reduced Buildout Alternative
A Reduced Buildout Alternative, whereby residential and non-residential growth would be assumed to occur at reduced intensities and densities compared to the Project was considered.

Under a Reduced Buildout Alternative, the changes in land use and zoning designations would not be able to fully accommodate the anticipated growth within the city over the next two decades. The Reduced Buildout Alternative could impact the City’s ability to meet future Regional Housing Needs Allocation (RHNA) cycles through 2045, which could result in the City potentially being non-compliant with State housing laws.

In addition, if full buildout was achieved prior to the 2045 horizon year, future requests to process General Plan and zoning amendments on a project-by-project basis might result, leading to land use changes on a parcel-level rather than through a comprehensive, long-term plan. In addition, if separate General Plan and/or zoning amendments were to occur on a project-by- project basis, this could result in a longer planning process for each project since streamlining through this General Plan Update process may not be feasible. Under the Reduced Buildout Alternative, future development may be displaced to surrounding jurisdictions, which are also developed, urban environments.

Overall, a Reduced Buildout Alternative would not fully achieve the Project’s objectives, as the City may not be able to accommodate its RHNA allocations through the 2045 planning horizon and would not be able to support the anticipated growth within the Planning Area or the region over the next few decades. Specifically, this alternative would not achieve the following

2 “Incremental Densification” is defined as development that would occur incrementally throughout the plan horizon of 2045, with residential areas developing at densities up to six units on a lot, and most development requiring demolitions of existing buildings to accommodate new development.

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objectives to the same extent as the Project due to its reduced development potential: 1) support a diversified, adaptable, and sustainable economy with a balance of small and large businesses across a range of industries that provide employment, commercial, and experiential opportunities; 2) be a creative and proactive leader in solving regional, state, and national challenges around issues like housing, mobility, public safety, equity, and climate pollution and disruption; and 3) advance continued racial, demographic, and socioeconomic diversity by supporting a range of housing types for different income levels, household compositions, stages of life, and marginalized populations, including persons experiencing homelessness, the elderly, and persons with disabilities. Therefore, the City eliminated the Reduced Buildout Alternative from further consideration in this PEIR.

5.4 Alternatives Selected for Analysis
As described above, based on CEQA Guidelines Section 15126.6(a) the purpose of analyzing project alternatives is to identify alternatives that “… would avoid or substantially lessen any of the significant effects of the project.” According to Section 15126.6(e) an EIR alternatives analysis should include the analysis of a No Project Alternative to allow decision makers to compare the impacts of approving a proposed project with the impacts and foreseeable future of not approving that project.

As indicated in Chapter 4, Environmental Impact Analysis, of this PEIR, Project impacts would be less than significant or less than significant with mitigation incorporated for the majority of the environmental topics evaluated. The Project would, however, have significant unavoidable impacts associated with air quality, cultural resources (historical resources), noise, transportation (VMT), and water supply. The alternatives evaluated in this chapter have been formulated to reduce the magnitude of the Project’s environmental impacts and to inform the decision-making process. The alternatives analyzed in this PEIR include:
• Alternative 1 – No Project Alternative
• Alternative 2 – Concentrated Growth Alternative
• Alternative 3 – Modified Mixed Use High Designation
In accordance with CEQA Guidelines Section 15126.6(d), each alternative is evaluated in sufficient detail to determine whether the overall environmental impacts would be less than, similar to, or greater than the corresponding impacts of the Project. In addition, each alternative is evaluated to determine whether the Project objectives would be substantially attained by the alternative. The evaluation of each of the alternatives includes the following components:
• A description of the alternative.
• An assessment of the impacts of the alternative for each environmental issue area evaluated in the EIR.
• An analysis of how the impacts of the alternative for each environmental issue area compares to the impacts of the Project. Where the impact of the alternative would be clearly less than the impact of the Project, the comparative impact is said to be “less.” Where the alternative’s net impact would clearly be more than the Project, the comparative

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General Plan 2045 and Zoning Code Update Project 5-8 SCH No. 2022030144 City of Culver City March 2024
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impact is said to be “greater.” Where the impacts of the alternative and Project would be roughly equivalent, the comparative impact is said to be “similar.” • The comparative analysis of the impacts is followed by a general discussion of the extent to which the Project Objectives could be attained by the alternative.

The three alternatives are analyzed and described in more detail below. Table 5-1, Comparison of Population, Housing Units, and Jobs, compares key characteristics for the Project and each alternative.

TABLE 5-1

COMPARISON OF POPULATION, HOUSING UNITS, AND JOBS

Existing
Baseline Project
Alternative 1:

No Projecta
Alternative 2:

Concentrated Growth
Alternative 3:

Modified Mixed Use
High Designation
Population 40,800b (2020) 62,400 41,550 59,530 61,170
Housing Units 17,000 (2019) 28,310 18,020 27,200 27,340 Jobs 68,040 (2019) 84,300 64,040 83,200 84,090
a The No Project Alternative growth projections are based on the socio-economic data (SED) assumptions from the Southern California Association of Governments (SCAG) 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), as presented in Fehr & Peers, Culver City General Plan Update CEQA Transportation Analysis, Table 2. b Baseline population numbers are from 2020 (source: U.S. Census Bureau, Decennial Census 2020) SOURCES: Culver City, 2022. City Council/Planning Commission Joint Session Memorandum; Fehr & Peers, Transportation Analysis, 2024.

5.5 Impact Analysis of the Alternatives

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

Under the No Project Alternative, the current land use designations in the adopted General Plan as amended to date and existing goals and policies would remain in place. Future development in the Planning Area would continue to be subject to existing policies, regulations, development standards, and land use designations of the adopted General Plan. No amendments would occur to areas identified for change under the Project. The No Project Alternative is depicted in Figure 2-4, Existing General Plan Land Use Map, in Chapter 2, Project Description. Policies concerning topics such as transportation, economic development, parks, open space, the environment, climate change, environmental justice, health, and housing would also remain unchanged.

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

The 1996 General Plan projected approximately 41,330 residents and approximately 56,743 jobs by the planning horizon of 2010.
4 Since the planning horizon of 2010 has passed, the No Project Alternative growth projections (see Table 5-1) are based on the socio-economic data (SED) assumptions from the Southern California Association of Governments (SCAG) 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS). SCAG developed demographic and economic forecasts of population, households, and employment at the regional and county levels and then incorporated local land use data and existing housing and employment data to allocate growth at the jurisdiction (e.g., city) and Transportation Analysis Zone (TAZ) levels. SCAG worked with the individual jurisdictions during this process to ensure accurate projections for each jurisdiction using their current General Plans and land use maps.

The SCAG 2045 forecast for Culver City is a population of 41,550 residents with a total of 18,020 households and 64,040 jobs.
5 Environmental Impacts
Aesthetics
Scenic Vistas
As discussed in Section 4.1, Aesthetics, of this Draft PEIR, the Project would not have a substantial adverse effect on a scenic vista, as land use designations under the proposed General Plan Update focus development toward portions of the Planning Area that are already developed, and thus would relieve pressure to develop in open space and natural areas. In addition, the Project includes several policies that would regulate scenic quality and resources.

For these reasons, this impact would be less than significant. In addition, the Zoning Code Update, which is the implementation mechanism, would provide requirements for future development consistent with the General Plan goals and policies. The Zoning Code Update would provide the zoning districts associated with each of the land use designations in the General Plan Update and the specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and building heights. As such, the Zoning Code Update would not result in a substantial adverse effect on a scenic vista. Future development would be reviewed by the City for compliance with applicable requirements and the mitigation measures referenced in other sections of this Draft PEIR. Therefore, impacts related to scenic vistas would be less than significant.

3 City of Culver City Housing, October 2021–2029, Appendix B, Table B-5. 4 Note that the existing 1996 General Plan does not project households. 5 Fehr & Peers, Culver City General Plan Update CEQA Transportation Analysis, Table 2. 2024.

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Similar to the Project, development under Alternative 1 would also be directed toward portions of the Planning Area that are already developed and thus would relieve pressure to develop in open space and natural areas. In addition, the existing General Plan includes several policies that also regulate scenic quality and resources. Therefore, under Alternative 1 the impact with respect to scenic vistas would remain less than significant, similar to the Project. However, the severity of this impact would be greater under Alternative 1 since the policies contained in the existing General Plan would not regulate scenic quality and resources to the same degree as the policies contained in the proposed General Plan Update. Specifically, proposed General Plan Update policies address context-specific development standards that provide clear guidance for height limitations and bulk and massing controls for future development (Policy LU-6.1); compatibility standards to maintain smooth transitions in scale, form, and character (Policy LU-

13.7); and implementation of the City View Preservation Ordinance (Policy LU-14.3).

Consistency with Applicable Zoning and Regulations Governing Scenic Quality While the Project would result in an increase in densities and intensities of land uses, the majority of the proposed changes would occur within Culver City, with limited land use changes occurring within the Sphere of Influence (SOI). Proposed policies in the General Plan Update are intended to complement and improve the existing scenic quality and resources in the city as well as to implement the City’s vision for the future character of the city. The Zoning Code Update would provide specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and building heights consistent with the General Plan Update. As such, the Zoning Code Update would not conflict with the General Plan Update and other regulations governing scenic quality. Therefore, impacts would be less than significant.

Development that would occur under Alternative 1 would also adhere to applicable zoning and other regulations and plans governing scenic quality in urbanized areas, including the General Plan and the Culver City Municipal Code (CCMC). In addition, the existing General Plan includes several policies that regulate scenic quality and resources. Therefore, the impact with respect to consistency with applicable zoning and other regulations governing scenic quality would remain less than significant, similar to the Project. However, Alternative 1 would result in a greater severity of this impact, as policies contained in the existing General Plan would not regulate scenic quality and resources to the same degree as the policies contained in the proposed General Plan Update. Specifically, the General Plan Update includes policies intended to reduce impacts to visual character in and around the Planning Area and promote cohesive and visually appealing development consistent with the character of the city. Proposed policies aim to maintain design standards that provide clear guidance of bulk and massing controls for future development (Policy LU-6.1) and require compliance with location-specific design guidelines (Policy LU-17.8).

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increase in ambient nighttime light conditions would not be substantial and would not be out of character with the urban environment. In addition, the General Plan Update includes policies related to buffering between uses and avoiding light spill and glare onto residential properties and sensitive habitats. Future development would be required to comply with applicable lighting regulations and standards in the CCMC. Therefore, impacts regarding light and glare that could affect day or nighttime views in the area would be less than significant.

Development allowed under Alternative 1 would also be required to comply with provisions within the CCMC that would limit light and glare from new non-residential and residential development. Therefore, the impact with respect to light and glare would remain less than significant, similar to the Project, although the severity of this impact would be less since less growth would occur under Alternative 1 compared to the Project.

Air Quality
Air Quality Plan
As discussed in Section 4.2, Air Quality, of this Draft PEIR, Culver City continues to coordinate with the South Coast Air Quality Management District (SCAQMD) and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the operation of future development under the proposed General Plan and Zoning Code Update would not conflict with or obstruct the implementation of the applicable air quality plan. Nonetheless, the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would be significant. Implementation of Mitigation Measures MM AQ-1 through MM AQ-5 would serve to reduce the severity of the impacts to emissions of criteria pollutants associated with future development and projected growth from future development under the Project. However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, impacts would remain significant and unavoidable.

The construction and operation of individual development projects allowed under Alternative 1 would also be required to follow existing state and local rules and regulations to minimize short- term and long-term emissions. In addition, the growth projections contained in Alternative 1 were included in the latest adopted Air Quality Management Plan (AQMP), and thus, as long as future growth in the city is consistent with the existing General Plan, it would not conflict with the applicable air quality plan. Similar to the Project, future development under Alternative 1 would be required to comply with applicable AQMP construction and operational control strategies. Therefore, the impact with respect to a conflict with the applicable air quality plan during construction and operation would be less than significant. Further, since the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City, impacts under Alternative 1 would be less than the Project.

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significance thresholds. Even with the implementation of mitigation measures (MM AQ-1 and MM AQ-5), this impact would be significant and unavoidable.

It is possible that Alternative 1 could result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment for the same reason as the Project.

However, future development under Alternative 1 would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the Project to reduce construction phase and operational emissions. Therefore, this impact would also remain significant and unavoidable, similar to the Project, although the severity of this impact would be less since less growth would occur under Alternative 1 compared to the Project, resulting in less traffic and VMT, which would result in fewer emissions of criteria pollutants from motor vehicles.

Substantial Pollutant Concentrations
The Project could expose sensitive receptors to substantial pollutant concentrations as the construction and operation of individual future projects would generate emissions of nitrogen oxides (NO
X,) carbon monoxide (CO), particulate matter 10 micrometers and smaller (PM10), and particulate matter 2.5 micrometers and smaller (PM2.5) that could exceed localized significance thresholds (LST) established by the SCAQMD. In addition, the construction and operation of individual future projects could expose nearby sensitive receptors to levels of toxic air contaminants that could result in a potential increase in cancer, acute, and/or chronic risk.

Even with the implementation of MM AQ-6 and MM AQ-7, this impact would be significant and unavoidable.

Alternative 1 could also expose sensitive receptors to substantial pollutant concentrations during construction and operation for the same reasons as the Project. Future development in the city would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the Project to reduce localized air quality and health risk impacts. However, even with implementation of mitigation measures, impacts could exceed the significance thresholds.

Therefore, similar to the Project, this impact would remain significant and unavoidable, although the severity of this impact would be less, as less growth would occur under Alternative 1 compared to the Project.

Biological Resources
Special-Status Species
As discussed in Section 4.3, Biological Resources, of this Draft PEIR, the Project could have a substantial adverse effect on special-status plant and wildlife species that occur within the Planning Area. However, with adherence to proposed General Plan policies related to the protection of biological resources; compliance with all applicable laws, regulations, and ordinances related to the protection of special-status plant and wildlife species; and implementation of mitigation measures (MM BIO-1 and MM BIO-2), this impact would be reduced to a less-than-significant level.

Development allowed under Alternative 1 could also have a substantial adverse effect on special-status plant and wildlife species that occur within the Planning Area. As with the Project, development under Alternative 1 would be required to comply with existing regulations related

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to the protection of biological resources. Therefore, the impact to special-status plant and wildlife species under Alternative 1 is expected to be reduced to a less-than-significant level, similar to the Project.

Riparian Habitat or Sensitive Natural Habitat
Given the lack of any sensitive natural communities, including lack of riparian habitat, within the Planning Area, the Project would have no effect on these resources. Therefore, the Project would not result in a substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations or by the California Department of Fish and Wildlife (CDFW) or the U.S. Fish and Wildlife Service (USFWS). The Project would have no impact.

Development allowed under Alternative 1 would also not have a substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations or by the CDFW or USFWS for the same reason as the Project. Therefore, as is the case for the Project, no impact would occur.

State or Federally Protected Wetlands
The Project would not have a substantial adverse effect on state or federally protected wetlands, as there are no wetlands present within the Planning Area. As a result, no impact would occur. In addition, the planned Ballona Creek Revitalization Project would enhance the restoration and use of Ballona Creek. Restoration activities may require Clean Water Act permits from the U.S. Army Corps of Engineers (USACE) and the Los Angeles Regional Water Quality Control Board (RWQCB) and/or a streambed alteration agreement from CDFW, which would be obtained prior to any work, and permit conditions would be implemented. Impacts would be less than significant.

Development allowed under Alternative 1 would also not have a substantial adverse effect on state or federally protected wetlands for the same reason as the Project. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Wildlife Corridors or Wildlife Nursery Sites
There are no wildlife corridors present within the Planning Area. Therefore, the Project would have no effect on wildlife corridors. In addition, nesting birds and/or nesting bird habitat have been recorded within the Planning Area, where implementation of the General Plan Update could directly or indirectly impact these biological resources. Compliance with the General Plan Update goals and policies, the Zoning Code Update, the Migratory Bird Treaty Act (MBTA), and mitigation measure MM BIO-2 would ensure that impacts to nesting birds would be reduced to less than significant. Based on review of available information, no known non-avian wildlife nursery sites occur within the Planning Area.

As with the Project, development under Alternative 1 would not have a substantial adverse effect on wildlife corridors or non-avian wildlife nursery sites. Therefore, as is the case for the Project, no impact would occur.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Development under Alternative 1 could also have a substantial adverse effect on nesting birds and/or nesting bird habitat that occur within the Planning Area. However, development allowed under the existing General Plan would be required to comply with applicable regulations related to the protection of nesting birds. Therefore, similar to the Project, the impact to nesting birds under Alternative 1 would be reduced to a less-than-significant level.

Conflict with Tree Preservation Policy or Ordinance
Future development facilitated by the Project would be subject to the City and County’s tree preservation ordinances, and the County’s oak woodland management policies, as applicable, which includes adherence to tree management and trimming procedures. In addition, proposed General Plan Update policies would serve to promote a strong urban forest across public and private properties and enhance tree health and appearance of streets and other public spaces through the regular maintenance as well as tree and landscaping planting and care of the existing canopy. Consistency with these policies would further ensure the impacts of the General Plan Update to existing and proposed tree resources would be minimized. Therefore, conflicts with local policies or ordinances protecting biological resources would not occur, and impacts would be less than significant.

Development allowed under Alternative 1 would also not conflict with a tree preservation policy or ordinance for the same reason as the Project. Therefore, the impact would be less than significant, similar to the Project.

Cultural Resources
Historic Resources
As discussed in Section 4.4, Cultural Resources, of this Draft PEIR, future development under the General Plan Update may include construction, demolition, or alteration of historic buildings/structures/objects/landscape features that have the potential to cause a substantial adverse change to historical resources as defined by CEQA Guidelines Section 15064.5. Even with adherence to the existing City Historic Preservation Ordinance, which outlines a designation process, criteria, and procedures for altering or modifying designated cultural resources; proposed General Plan policies related to the protection of cultural resources; and implementation of MM CUL-1, this impact would be significant and unavoidable.

Development allowed under Alternative 1 could also cause a substantial adverse change in the significance of a historical resource pursuant to CEQA Guidelines Section 15064.5. As with the Project, this impact would be significant and unavoidable even with adherence to the existing City Historic Preservation Ordinance, although the severity of this impact would be less, as less growth would occur under Alternative 1, and thus there would be less potential to negatively affect historic resources.

Archaeological Resources
The Project could cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. Adherence to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction,

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
implementation of MM CUL-2, and implementation of applicable policies in the General Plan Update would reduce the impact to a less-than-significant level.

Development allowed under Alternative 1 could also cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. As with the Project, adherence to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction would reduce the impact to a less-than-significant level. The severity of this impact would be less than the Project since less growth would occur under Alternative 1. Therefore, the potential to negatively affect archaeological resources would be less under Alternative 1 compared with the Project.

Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources Under the Project, energy use for construction of new developments would be for on-site activities and to transport construction materials and demolition debris as needed. In addition, idling restrictions and the use of cleaner, energy-efficient equipment and fuels would result in less fuel combustion and energy consumption, and thus minimize construction-related energy use. Therefore, construction of new developments that could occur under the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy, and this impact would be less than significant. With respect to operation, future development would be required to comply with applicable electric, natural gas, and transportation fuels control strategies, efficiency requirements, and regulations. Therefore, future development under the Project would result in a less-than-significant impact related to the wasteful, inefficient, or unnecessary consumption of energy resources during operation.

Similar to the Project, Alternative 1 would not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during construction for the same reasons as the Project. As a result, the impact with respect to the wasteful, inefficient, or unnecessary consumption of energy resources during construction would remain less than significant, similar to the Project, although the severity of this impact would be less, as less construction would occur under Alternative 1.

With respect to operation, Alternative 1 would not implement land use and transportation strategies aimed at reducing vehicle trips and energy efficiency strategies to the same degree as the Project. While it is reasonable to expect the rate of energy and fuel demand from future development anticipated by the existing General Plan would decline over time due to regulatory initiatives and technical innovations, it would not decline at the same rate as the Project given that Alternative 1 would not implement land use, transportation, and energy-related efficiency strategies to the same degree as the Project. Therefore, the impact with respect to the wasteful, inefficient, or unnecessary consumption of energy resources during operation would be less than significant, similar to the Project, but the severity of this impact would be greater compared to the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Conflict with State or Local Renewable Energy Plan
Construction of development permitted by the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency as individual projects would utilize construction contractors who must demonstrate compliance with applicable regulations. In addition, truck fleet operators must upgrade their fleets with vehicles that meet adopted fuel- efficiency standards for medium- and heavy-duty trucks. With respect to operation, future development that could occur under the Project would be designed in a manner consistent with the policies contained in the proposed General Plan Update that are designed to encourage development that results in the efficient use of energy resources. Additionally, new development would comply with Title 24 requirements and CALGreen to reduce energy consumption by implementing energy efficient building designs, pre-wiring residences with electric vehicle charging ports, implementing solar-ready rooftops, reducing indoor and outdoor water demand, and installing energy-efficient appliances and equipment. Therefore, impacts would be less than significant.

Individual projects under Alternative 1 would also not conflict with or obstruct a state or local plan for renewable energy or energy efficiency for the same reasons as the Project. However, Alternative 1 does not incorporate policies contained in the proposed General Plan Update that are designed to encourage development that results in the efficient use of energy resources.

Therefore, while the impact with respect to a conflict with a state or local plan for renewable energy or energy efficiency during construction and operation would be less than significant, similar to the Project, the severity of this impact would be greater, as policies contained in the proposed General Plan Update that are designed to encourage development that results in the efficient use of energy resources would not be implemented.

Geology and Soils
Geologic Hazards
Future development under the Project would be required to comply with all applicable design, engineering, and construction standards and requirements of the California Building Code (CBC), the CMCC and policies contained in the proposed General Plan Update that are designed to minimize seismic-related geologic hazards. Therefore, the Project would not cause risk of loss, injury, or death associated with seismic hazards, including fault rupture, strong ground shaking, seismic-related ground failure, including liquefaction, or seismic-related landslides and slope instability. As a result, implementation of the Project would result in a less-than-significant impact related to risk of seismic-related geologic hazards.

Development allowed under Alternative 1 would also be required to comply with all applicable design, engineering, and construction standards and requirements of the CBC and the CMCC that address seismic-related geologic hazards. Therefore, the impact with respect to risk of seismic-related geologic hazards would be less than significant, similar to the Project, and the severity of the impact would be similar.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Pollution Discharge Elimination System (NPDES) permit, which would include implementation of BMPs and preparation of a storm water pollution prevention plan (SWPPP), which would include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. In addition, the proposed General Plan Update includes policies that encourage the use of BMPs to control soil erosion during and after ground-disturbing activities and the preparation of site-specific geotechnical investigations for projects requiring grading permits. As a result, this impact would be less than significant.

As with the Project, development that would occur under Alternative 1 would be subject to compliance with an NPDES permit, including the preparation of a SWPPP and associated BMPs.

Therefore, the impact with respect to soil erosion or loss of topsoil would be less than significant, similar to the Project, and the severity of the impact would be similar.

Unstable and Expansive Soils
The Project would have a less-than-significant impact with respect to unstable soils, such as on- or off-site landslide, lateral spreading, subsidence, liquefaction, or collapse, and expansive soils.

These potential hazards would be addressed largely through the integration of geotechnical information in the planning and design process in accordance with standard industry practices and state and local requirements. As a result, this impact would be less than significant.

As with the Project, development allowed under Alternative 1 would be required to comply with all applicable design, engineering, and construction standards and requirements that address unstable or expansive soils. Therefore, the impact with respect to risk of unstable or expansive would be less than significant, similar to the Project, and the severity of the impact would be similar.

Paleontological Resources
Future development under the Project would not result in adverse impacts to paleontological resources, as the City’s standard conditions of approval require specific steps to be taken to avoid damage and promote preservation of paleontological resources. In addition, proposed policies included in the General Plan Update promote public knowledge and protection of paleontological resources. Furthermore, MM GEO-1 would serve to further reduce impacts to paleontological resources by requiring that applicable future projects within the city would be subject to project-specific paleontological studies. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also be required to comply with specific procedures in the City’s entitlement process to avoid damage to paleontological resources and promote their preservation. Therefore, impacts to paleontological resources would be less than significant, similar to the Project. However, the severity of this impact could be greater under Alternative 1, as development under Alternative 1 would not be subject to MM GEO-1 that is included in the General Plan Update.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Greenhouse Gas Emissions
Emissions
The Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during construction, as future projects developed under the Project would be required to comply with applicable federal, state, and local regulations that would reduce the amount of GHG emissions generated by construction equipment and activities. With respect to operation, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, as the net change in operational emissions from existing conditions compared to existing plus buildout under the Project would be negative compared to existing conditions. For these reasons, this impact would be less than significant.

Alternative 1 would also not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during construction for the same reasons as the Project.

Therefore, the impact with respect to the generation of GHG emissions during construction would remain less than significant, similar to the Project, and the severity of this impact would be similar. With respect to operation, as less growth would occur under No Project Alternative, less traffic would be generated and less building space would be constructed, and thus fewer GHG emissions would be generated from motor vehicles and the heating and cooling of buildings. As the net change in operational emissions from existing conditions compared to buildout of the Project would be negative compared to existing conditions, the net change in operational emissions from existing conditions compared to buildout of Alternative 1 would also be negative. Therefore, the impact with respect to the generation of GHG emissions during operation would remain less than significant, similar to the Project, although the severity of this impact would be less, as less traffic would be generated and less development would occur under Alternative 1, thus resulting in fewer GHG emissions compared to the Project.

Conflict with Greenhouse Gas Reduction Plans, Policies, and Regulations The Project would not conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs as development that would occur under the Project would be consistent with applicable climate change scoping plan GHG reduction strategies. In addition, it is reasonable to expect the GHG emissions from future development anticipated by the Project would decline over time due to regulatory initiatives and technical innovations, and thus development permitted by the proposed General Plan Update would not conflict with or interfere with the ability of the state to achieve its GHG reduction goal of 80 percent below 1990 levels by 2050 as stated in Executive Order S-3-05. In addition, the Project would be consistent with applicable SCAG 2020–2045 RTP/SCS (Connect SoCal) actions and strategies, which work to reduce GHG emissions generated by the transportation sector by aligning transportation, land use, and housing strategies. Finally, the development that would occur under the Project would be required to be consistent with the proposed Greenhouse Gas Reduction Element and with the City’s Green Building Program. For these reasons, this impact would be less than significant.

Development permitted under Alternative 1 would implement applicable climate change scoping plan GHG reduction strategies, but not to the same degree as the Project, as the existing General Plan was prepared and adopted before many of these strategies were adopted.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
However, it is reasonable to expect the GHG emissions from future development anticipated under Alternative 1 would decline over time due to regulatory initiatives and technical innovations. In addition, it is also reasonable to expect the future development under Alternative 1 would be designed to be consistent with SCAG 2020–2045 RTP/SCS (Connect SoCal) actions and strategies and the City’s Green Building Program. Therefore, while the impact with respect to a conflict with respect to GHG reduction plans, policies, and regulations would likely remain less than significant, similar to the Project, the severity of this impact would be greater as growth under Alternative 1 would not implement land use and transportation strategies aimed at reducing vehicle trips and energy efficiency strategies contained in the General Plan Update and would not implement applicable climate change scoping plan GHG reduction strategies to the same degree as the Project.

Hazards and Hazardous Materials
Routine Use, Transportation, Disposal, or Accidental Release of Hazardous Materials As discussed in Section 4.8, Hazards and Hazardous Materials, of this Draft PEIR, the Project would not create a significant hazard to the public or the environment through the routine use, transport, disposal, or accidental release of hazardous materials, as the construction and operation of future development allowed under the Project would adhere to applicable federal, state, and local regulations governing the transportation, use, handling, and disposal of hazardous materials. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also not create a significant hazard to the public or the environment through the routine use, transport, disposal, or accidental release of hazardous materials during construction and operation for the same reason as the Project.

Therefore, the impact with respect to the transportation, use, handling, and disposal of hazardous materials would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Emit Hazardous Materials Within One-Quarter Mile of a School The Project would not result in hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school site, as existing and future development under the Project in the vicinity of an existing or proposed school site would adhere to applicable federal, state, and local regulations governing the transportation, use, handling, and disposal of hazardous materials. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also not result in hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school site for the same reason as the Project. Therefore, the impact with respect to the transportation, use, handling, and disposal of hazardous materials would remain less than significant, similar to the Project, and the severity of this impact would be similar.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Hazardous Materials Sites
The Project would not create a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 as future development under the Project would adhere to applicable federal, state, and local regulations that provide procedures for the testing, handling, disposal, and remediation of hazardous materials. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also not create a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 for the same reason as the Project.

Therefore, the impact with respect to creating a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Emergency Response Plan
The Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s Multi-Jurisdictional Hazard Mitigation Plan (MJHMP), and policies contained in the General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would be required by existing regulations, including the MJHMP, to ensure emergency access to each project site. As a result, the impact with respect to the impairment or interference with an adopted emergency response plan or emergency evacuation plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Wildland Fire Hazards
While the majority of the Planning Area is not within a Very High Fire Hazard Severity Zone (VHFHSZ), the California Department of Forestry and Fire Prevention (CAL FIRE) classifies the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within West Los Angeles College and the Inglewood Oil Field (IOF), as a VHFHSZ.

Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development. Future development allowed under the Project could include the development of additional residential uses in these neighborhoods, which could expose additional people and structures to wildland fire hazards. The General Plan Update contains policies to minimize the risk of fire hazards. With adherence to applicable building codes and review by the Culver City Fire Department (CCFD) to reduce fire hazards, the Project would not expose people or structures to substantial wildfire hazards, and impacts would be less than significant.

Development allowed under Alternative 1 would also be required to adhere to applicable building codes and review by the CCFD to reduce fire hazards. As a result, the impact with

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
respect to wildland fire hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Hydrology and Water Quality
Water Quality
As discussed in Section 4.9, Hydrology and Water Quality, of this Draft PEIR, the Project would not result in the violation of any water quality standards or waste discharge requirements or otherwise substantially degrade water quality, as future development under the Project would comply with applicable federal, state, and local regulations pertaining to water quality. In addition, the Project contains policies that promote improved water quality in the city and continued compliance with federal, state, and local water quality regulations, which would ensure that water quality is protected to the maximum extent practicable. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also adhere to applicable federal, state, and local regulations pertaining to water quality. Therefore, the impact with respect to water quality would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Groundwater
The City’s water providers, Los Angeles Department of Water and Power (LADWP) and the Golden State Water Company (GSWC), use a combination of groundwater and surface water.

There are limits on the amount of groundwater each provider can pump for potable water supplies, and the potential for overdraft is limited. These water providers would be able to utilize other sources of potable water to supplement a decrease in the amount of available groundwater, if needed. With regard to groundwater recharge, the General Plan Update establishes land use designations that encourage mixed uses and infill development, while maintaining existing parks and open space resources and expanding these resources. The Project would not result in substantial increases of impervious surfaces such that groundwater recharge would be hindered. For these reasons, the Project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge. As a result, this impact would be less than significant.

Development allowed under Alternative 1 would also not substantially deplete groundwater supplies for the same reasons as the Project. Development under the current General Plan would adhere to existing regulations that govern water quality and groundwater sustainability and would not result in substantial increases of impervious surfaces such that groundwater recharge would be hindered. As a result, the impact with respect to groundwater recharge would remain less than significant, similar to the Project, and the severity of this impact would be similar.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
construction and operational laws, regulations, and permits related to hydromodification and discharging into the city’s sewer system. For these reasons, the impact of the Project with respect to the alteration of drainage patterns would be less than significant.

Development under Alternative 1 also would not directly alter the course of Ballona Creek or any other streams or rivers. Development under the No Project Alternative would also 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. Therefore, the impact with respect to drainage would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Inundation
The Planning Area is located approximately 1.5 miles inland from nearby coastal areas and is located outside of tsunami inundation zones. In addition, there are no enclosed large water bodies within the Planning Area with potential for seiche effects or waves generated by failure of retaining structures. Furthermore, the majority of the Planning Area is located outside of a flood hazard zone. For these reasons, the risk of release of pollutants as a result of inundation from being located in a flood, tsunami, or seiche zone would be considered extremely low for the Planning Area. Additionally, future development facilitated under the Project would be required to comply with all applicable laws, regulations, and permits related to drainage and flooding hazards, which would reduce the risk of onsite flooding and release of pollutants.

Therefore, impacts associated with release of pollutants from inundation by flood, tsunami, or seiche would be less than significant.

As development allowed under Alternative 1 would also occur within the Planning Area, it would also not be subject to inundation from a tsunami or seiche. In addition, development anticipated under the No Project Alternative would also adhere to existing laws, regulations, and permits related to drainage and flooding hazards, which would reduce the risk of onsite flooding and release of pollutants. Therefore, the impact with respect to inundation would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Water Quality Plan or Sustainable Groundwater Management Plan Implementation of the Project would not degrade water quality due to compliance with all applicable federal, state, regional, and local water quality laws, regulations, and permits.

Moreover, the General Plan Update contains goals and policies that promote improved water quality and groundwater sustainability in the Planning Area, as well as continued compliance with state and local water quality regulations, which is intended to ensure that water quality and groundwater sustainability is managed to the maximum extent practicable. In addition, implementation of the Project would not interfere with or conflict with the Santa Monica Groundwater Subbasin Groundwater Sustainability Plan (GSP), since the City is a member of the Santa Monica Basin Groundwater Sustainability Agency (SMBGSA), and the Project includes various implementation actions that support the GSP. Furthermore, due to the developed nature of the city and the proposed land use distribution, impacts to groundwater supplies as a result of new impervious surfaces would be less than significant. Therefore, the Project would not conflict with the Santa Monica Subbasin GSP, and impacts would be less than significant.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Development allowed under Alternative 1 would also adhere applicable federal, state, and local regulations pertaining to water quality and groundwater sustainability. In addition, as growth anticipated under the No Project Alternative would be within the same Planning Area, it would also not conflict with the GSP. Therefore, the impact with respect to a water quality plan or sustainable groundwater management plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Land Use and Planning
Physically Divide a Community
The city is primarily built out with residential uses and only 0.6 percent is vacant land.

Implementation of the Project would improve connectivity and land use patterns within and between existing neighborhoods, thereby providing more linkages within the city and the region. The overall land use pattern would not change under the General Plan Update, and the changes focus density in areas that would not result in a division of a community. Therefore, future development allowed under the General Plan Update would not physically divide an established community, and the impact would be less than significant.

Development allowed under Alternative 1 would also not physically divide an established community as the Planning Area is largely built out and future development under the No Project Alternative would likely occur on existing lots served with existing infrastructure, and thus development under Alternative 1 would not necessitate new roads or other infrastructure that would physically divide an established community. Therefore, the impact with respect to physically dividing an established community would remain less than significant, similar to the Project, although the severity of this impact would be greater as policies contained in the proposed General Plan Update that improve connectivity and land use consistency within and between existing neighborhoods would not be implemented under Alternative 1.

Consistency with Applicable Land Use Plans
The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The proposed General Plan Update is intended to provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its SOI, through the planning horizon year of 2045. The Zoning Code Update is the mechanism to implement the land use changes proposed in the City’s General Plan Update. Implementation of the Project would not conflict with existing planning regulations and policies, including those included in California Government Code Section 65302, the California Complete Streets Act, the SCAG 2020–2045 RTP/SCS (Connect SoCal), the Culver City and Culver City Unified School District (CCUSD) Multi-Jurisdictional Hazard Mitigation Plan, the Culver City Bicycle & Pedestrian Action Plan, and the Culver City Urban Forest Master Plan.

For these reasons, this impact would be less than significant.

Development allowed under Alternative 1 would also not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect as the current General Plan generally complies with most regional and local plans. However, Alternative 1 would not provide sufficient land

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
capacity to fully meet the City’s allocation under the 6th cycle of the RHNA. All future growth under Alternative 1 must be consistent with the existing General Plan, and thus would be consistent with existing zoning and regional and local plans. In addition, all future growth in the City’s SOI must be consistent with the Los Angeles County General Plan and Los Angeles County zoning regulations. For these reasons, the impact with respect to consistency with applicable plans would remain less than significant, similar to the Project, although the severity of this impact would be greater as the existing General Plan does not integrate land use, housing, and transportation planning to the same degree as the Project and thus would not implement the SCAG 2020–2045 RTP/SCS (Connect SoCal) to the same degree.

Implementation of the Project would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation in a manner that would render the resources unavailable. As such, the Project would not result in the loss of a regionally and locally important mineral resource. Impacts related to oil and gas resources would be considered less than significant.

Development allowed under Alternative 1 would result in no impact to aggregate mineral resources for the same reason as the Project. Development allowed under Alternative 1 also would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation. Therefore, the impact with respect to oil and gas resources would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Noise and Vibration
Temporary or Permanent Increase in Ambient Noise Levels Construction of future development under the Project would require the use of heavy equipment during construction activities. The exact locations of future projects and construction that would occur under the Project are not known at this time, though it is assumed that some of the activities would take place in close proximity to sensitive receptors given that the City is generally built out. The severity of construction-related noise impacts depends on the proximity of construction activities to sensitive receptors, the presence of intervening barriers, the number and types of equipment used, and the duration and intensity of the activity. For future development projects requiring discretionary approval, a project-specific noise analysis would be prepared to determine significance and if necessary, recommend mitigation measures, in accordance with CEQA. Even with mandatory compliance with CCMC requirements, it is possible that some future development projects could be large in construction intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period noise levels could exceed the significance thresholds. Implementation

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of Mitigation Measure MM NOI-1 would help to reduce the potentially significant construction- related impacts. However, even with implementation of Mitigation Measure MM NOI-1, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

With respect to operation, it is possible that some future development under the Project could generate operational-period roadway traffic noise levels that exceed significance thresholds and result in a significant impact. There are no feasible mitigation measures to reduce traffic noise levels. While General Plan Update policies would serve to limit traffic noise exposure to sensitive receptors, these policies cannot ensure that noise levels would be reduced to levels below the City’s noise standards at all sensitive receptors. Therefore, traffic noise impacts under the Project would be significant and unavoidable.

Construction of future development allowed under Alternative 1, could also result in noise levels that could exceed significance thresholds, even with mandatory compliance with CCMC requirements. For discretionary projects requiring CEQA review, implementation of mitigation measures, in addition to CCMC compliance, would help to reduce the potentially significant construction-related impacts. However, even with implementation of mitigation measures, impacts could exceed significance thresholds. Therefore, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1 compared to the Project, and thus less construction noise would be generated.

As with the Project, future development under Alternative 1 could generate operational-period roadway traffic noise levels that exceed significance thresholds and result in a significant impact.

As is the case for the Project, there are no feasible mitigation measures to reduce traffic noise levels. Therefore, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1 compared to the Project, and thus less traffic noise would be generated.

Excessive Groundborne Vibration or Groundborne Noise
Some future development projects under the Project could generate construction-period groundborne vibration and groundborne noise levels that exceed the specified limits in the Federal Transit Administration (FTA) Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance and result in a significant impact. Even with implementation of Mitigation Measure MM NOI-2, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

With respect to operation, future development projects under the Project could generate groundborne vibration and groundborne noise from vehicle and truck traffic on roadways and from stationary mechanical equipment such as pumps and compressors. However, groundborne vibration and groundborne noise from operational sources would be characterized as typically low and would not be expected to exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance.

As a result, groundborne vibration and groundborne noise impacts during operation would be less than significant, and no mitigation is required.

5. Alternatives
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Future development projects under Alternative 1 could also generate construction-period groundborne vibration and groundborne noise levels that exceed thresholds. Therefore, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1 compared to the Project, and thus less construction-period groundborne vibration and groundborne noise levels would be generated.

As less growth would occur under the No Project Alternative, less groundborne vibration and groundborne noise impacts during operation would be generated. Therefore, the impact would remain less than significant, similar to the Project, although the severity of this impact would be less.

Population and Housing
Induce Unplanned Population Growth
As discussed in Section 4.13, Population and Housing, of this Draft PEIR, 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. 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.

Future development under Alternative 1 would be the continuation of growth in the city guided by the City’s adopted 1996 General Plan and the current Zoning Code. Enough development capacity remains under the existing General Plan that future growth allowed under Alternative 1 could be accommodated within the existing framework, and thus this future growth would not be substantial. Therefore, the impact with respect to the inducement of unplanned population growth would be less than significant, similar to the Project, although the severity of this impact would be less as all growth under Alternative 1 would be planned.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-27 SCH No. 2022030144 City of Culver City March 2024
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Housing Element 2021–2029 was certified by HCD on October 10, 2022.6 The proposed Land Use Element reflects the new land use designations that would allow greater residential densities 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.

Population growth under Alternative 1 would be less than under the Project. As discussed above, enough development capacity remains under the existing General Plan that future growth allowed under Alternative 1 could be accommodated. This growth would likely occur in places where properties could be developed at higher densities under existing zoning (i.e., underutilized parcels). While some redevelopment may occur and cause some displacement, adherence to state and County regulations that address the displacement of residents would mitigate these effects, and it is not expected that such development would impact substantial numbers. Therefore, the impact with respect to the construction of new housing would remain less than significant, similar to the Project although the severity of this impact would be less, as less growth would occur under Alternative 1 compared to the Project.

Public Services
Fire and Police Service
As discussed in Section 4.14, Public Services, of this Draft PEIR, the Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire and police service facilities, as future development would be concentrated in areas already well-served by existing fire and police facilities. In addition, the Project would promote compact development patterns through infill development, ensuring new development would be located within close proximity to existing fire stations and police stations. If new fire and police facilities are needed, the construction of these facilities would be subject to compliance with existing regulations, proposed General Plan policies, and mitigation measures identified in other sections of this Draft PEIR to minimize adverse physical effects. For these reasons, this impact would be less than significant.

As less growth would occur under Alternative 1 compared to the Project, demand for fire and police service would be less under the No Project Alternative than under the Project. If new or expanded fire and police facilities are required under Alternative 1, they would be subject to environmental review and associated mitigation requirements to minimize adverse physical

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

5. Alternatives
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effects. Therefore, the impact with respect to fire and police services would remain less than significant, similar to the Project, although the severity of this impact would be less, as less growth and less demand for these services would occur under Alternative 1 compared to the Project.

Schools
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. 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. The Culver City Unified School District (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 impacts of development on school facilities for purposes of CEQA per Senate Bill (SB) 50. For these reasons, this impact would be less than significant.

As less growth would occur under Alternative 1 compared to the Project, fewer students would be generated under Alternative 1. If new school facilities are required under Alternative 1, the construction of these facilities would also be subject to compliance with existing regulations, including payment of statutory fees that full mitigate the impacts of development on school facilities pursuant to CEQA. Therefore, the impact with respect to schools would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for schools under Alternative 1 compared to the Project.

Parks
A comparison of impacts to parks and recreation facilities between the Project and Alternative 1 is provided below under “Recreation.”
Other Public Facilities
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, such as libraries, as the construction of these facilities, if needed, would be subject to compliance with existing regulations, proposed General Plan policies, and mitigation measures identified in other sections of this Draft PEIR to minimize adverse physical effects. As a result, this impact would be less than significant.

As less growth would occur under Alternative 1 compared to the Project, demand for other public facilities, such as libraries, would be less under the No Project Alternative than under the Project. If new public facilities are required, they would be subject to environmental review and associated mitigation requirements to minimize adverse physical effects. Therefore, the impact with respect to public facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 1 compared to the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-29 SCH No. 2022030144 City of Culver City March 2024
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Recreation
Deterioration of Existing Recreational Facilities
As discussed in Section 4.15, Recreation, of this Draft PEIR, although the City is currently not meeting the park service ratio standard, the General Plan Update includes policies that 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.

Although less growth would occur under Alternative 1 compared to the Project, the City would continue to not meet the park service ratio standard under this alternative. Consequently, absent policies that would address the potential impact, Alternative 1 could result in a significant and unavoidable impact with respect to the deterioration of existing recreational facilities. As no feasible mitigation is available to reduce the impact to less than significant, the severity of this impact would be greater compared to the Project.

Construction or Expansion of Recreational Facilities
The Project would encourage the development of future recreational facilities in order to meet demand associated with anticipated population growth under the General Plan Update. The precise amount, type, and location of future parks and recreational facilities would be determined during the planning process for future development projects or master/specific plans. Future recreational facilities would be consistent with the proposed land use designations and policies and would be subject to additional environmental review under CEQA, as needed.

For these reasons, this impact would be less than significant.

Growth under Alternative 1 could also result in the development of new parks and recreational facilities. Like the Project, construction of new parks and recreational facilities would also be subject to CEQA requirements for environmental assessment. Therefore, the impact with respect to the construction or expansion of recreational facilities would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Transportation
Conflict with Adopted Circulation Program, Plan, Ordinance, or Policy As discussed in Section 4.16, Transportation, of this Draft PEIR, the Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway bicycle and pedestrian facilities due to the availability of non-vehicular transportation options for the community. In addition, policies included in the General Plan Update would balance the multimodal transportation network by providing alternatives to the automobile, improving transit service connections, and encouraging the use of alternative modes of transportation. As a result, this impact would be less than significant.

Future development under Alternative 1 would also not conflict with a program, plan, ordinance, or policy addressing the circulation system, as non-vehicular transportation options for the community would also be available under continued growth as permitted by the existing

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-30 SCH No. 2022030144 City of Culver City March 2024
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General Plan. In addition, while policies in the existing General Plan do not balance the multimodal transportation network as well as the Project, Alternative 1 does include policies that promote the use of alternative modes of transportation. As a result, the impact with respect to a conflict with an adopted circulation program, plan, ordinance, or policy would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Vehicle Miles Traveled
The Project would conflict or be inconsistent with CEQA Guidelines Section 15064.3, Subdivision (b) as total VMT per service population associated with growth under the General Plan Update would not achieve a 15 percent or more reduction compared to the baseline. Although policies promoting a reduction of VMT per capita are included in the General Plan Update, no feasible mitigation is available to reach the 15 percent or more reduction threshold. As a result, this impact would be significant and unavoidable.

As less growth would occur under Alternative 1 compared to the Project, less traffic would be generated along streets in the Planning Area, and thus less VMT would be generated under the existing General Plan. Although Alternative 1 would not encourage mixed use development, which serves to reduce VMT, to the extent of the Project, the reduction in growth would generate less trips. However, this reduction in VMT under Alternative 1 would not likely be enough to achieve a 15 percent or more reduction compared to the baseline. As a result, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less as less traffic would be generated under Alternative 1 compared to the Project.

Design Hazards
The Project would not substantially increase hazards due to a geometric design feature (e.g., sharp curves or dangerous intersections) or incompatible uses as access locations for future development would be designed to the City’s standards and would provide adequate sight distance. In addition, policies included in the General Plan Update that promote bicycle and pedestrian safety would help identify and address potential safety concerns. Therefore, this impact would be less than significant.

Future development under Alternative 1 would also be designed in compliance with the City’s standards for safety and would provide adequate sight distance. As a result, the impact with respect to design hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Emergency Access
Future development under the Project 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 ensure that future development under the Project would be consistent with these policies and would not hinder emergency access. For these reasons, the Project would not result in inadequate emergency access, and this impact would be less than significant.

5. Alternatives
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Future development under Alternative 1 would also not result in inadequate emergency access for the same reason as the Project. Therefore, the impact with respect to emergency access would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Tribal Cultural Resources
No tribal cultural resources have been identified within or adjacent to the Planning Area.

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 resources are uncovered during construction. Adherence to these regulations and implementation of General Plan policies would ensure that the Project’s impact with respect to tribal cultural resources would be less than significant.

Development under Alternative 1 may also result in the identification of unrecorded tribal cultural resources. As with the Project, future development under Alternative 1 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.

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 resources are uncovered during construction. Therefore, the impact to tribal cultural resources is expected to be reduced to a less-than-significant level, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1, and thus there would be less potential to negatively affect tribal cultural resources.

Utilities and Service Systems
New or Expanded Facilities
As discussed in Section 4.18, Utilities and Service Systems, of this Draft PEIR, the Project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities. However, future development under the Project could require or result in the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, and should upgrades to new facilities be required, the construction of those facilities could result in adverse environmental effects, which are considered throughout the technical sections of this Draft PEIR. In addition, future facilities would be required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. As a result, this impact would be less than significant.

5. Alternatives
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Preliminary − Subject to Revision
Development allowed under Alternative 1 could also require or result in the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities. If upgrades to facilities were to be required, the construction of those facilities could result in adverse environmental effects. Future facilities under the No Project Alternative, if required, would be required to comply with applicable CEQA review and mitigation of environmental impacts and the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. For these reasons, the impact with respect to new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1.

Water Supply
Culver City is served by two water service providers: the Golden State Water Company (GSWC) and Los Angeles Department of Water and Power (LADWP). GSWC’s 2020 Urban Water Management Plan (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 SCAG 2020–2045 RTP/SCS (Connect SoCal). However, as discussed in Section 4.18, the Project would result in growth and an increase in intensity above these projections. The General Plan Update includes policies and actions that would reduce water demand of future development allowed under the Project.

Furthermore, 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 CCMC Chapter 5.03, the City’s Water Conservation Plan, and policies in the General Plan Update aimed at reducing demand over time, sufficient water supply is not documented to be available at this time. No additional mitigation measures beyond these actions would be feasible. Thus, the water supply impact is considered significant and unavoidable.

As less growth would occur under Alternative 1 compared to the Project, demand for water would be less under the existing General Plan. As GSWC’s 2020 UWMP and LADWP’s 2020 UWMP identified water supplies to meet projected water demands through 2045, and projected growth under the existing General Plan is accounted for, sufficient water supplies exist to serve growth anticipated under Alternative 1. In addition, each individual development proposal under this alternative would also be required to address water supply as part of the entitlement process. Future development under Alternative 1 would comply with state and local regulations that promote water conservation. Finally, the water suppliers serving the city have water contingency plans that would be implemented in case of a water shortage event or drought.

Therefore, the impact with respect to water supply would be less than significant, and the Project’s significant-and-unavoidable impact related to water supply would be avoided under Alternative 1.

5. Alternatives
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Wastewater Service Capacity
The wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to future growth anticipated under the General Plan Update. In addition, policies in the proposed General Plan Update aim to conserve water by curbing demand for domestic and commercial purposes and promoting water conservation strategies, thus reducing demand for water, and in turn, the generation of wastewater. For these reasons, this impact would be less than significant.

As less growth would occur under Alternative 1 compared to the Project, less wastewater would be generated under the No Project Alternative. As the wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to the Project, sufficient capacity also exists to treat wastewater generated by growth anticipated under Alternative 1. In addition, future development under Alternative 1 would continue to adhere to existing regulations and policies that aim to conserve water, which in turn, would reduce the amount of wastewater generated. As a result, the impact with respect to wastewater service capacity would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less wastewater generated under Alternative 1 compared to the Project.

Solid Waste
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, as the landfills that currently serve the city have adequate capacity to dispose of the full increase in solid waste attributable to future growth anticipated under the Project. In addition, compliance with existing solid waste regulations and policies in the proposed General Plan Update would further address potential impacts. Therefore, this impact would be less than significant.

As less growth would occur under the No Project Alternative compared to the Project, less solid waste would be generated under Alternative 1. As the landfills serving the Planning Area currently have adequate capacity to dispose of the full increase in solid waste attributable to Project, sufficient capacity also exists to treat solid waste generated by growth anticipated under Alternative 1. In addition, future development under Alternative 1 would comply with solid waste regulations that aim to reduce solid waste. As a result, the impact with respect to solid waste disposal capacity would remain less than significant, similar to the Project, although the severity of this impact would be less, as less growth would occur, and there would be less solid waste generated under Alternative 1 compared to the Project.

Solid Waste Regulations
The Project would comply with applicable federal, state, and local management and reduction statutes and regulations related to solid waste. In addition, the policies in the proposed General Plan Update regarding solid waste disposal and associated public facilities would further ensure compliance with applicable regulations. As a result, this impact would be less than significant.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-34 SCH No. 2022030144 City of Culver City March 2024
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Development under Alternative 1 would comply with applicable federal, state, and local management and reduction statutes and regulations related to solid waste. As a result, the impact with respect to solid waste regulations would remain less than significant, similar to the Project.

Wildfire
Emergency Response or Evacuation Plans
As discussed in Section 4.19, Wildfire, and Section 4.8, Hazards and Hazardous Materials, of this Draft PEIR, the Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s MJHMP, and policies in the proposed General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant.

Exacerbate Wildfire Risks
While the majority of the Planning Area is not within a VHFHSZ, CAL FIRE classifies the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods as a VHFHSZ. Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development. Development associated with the Project 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. In addition, smoke from wildfires occurring in Los Angeles County and across the state has resulted in poor air quality within Culver City. 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. Compliance with the applicable requirements of the CBC, the California Fire Code (CFC), the CCMC, the policies of the General Plan Update, and site-specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant.

As development allowed under Alternative 1 would also occur within the Planning Area Alternative 1 could also exacerbate wildfire risks as identified for the Project. As with the Project, required compliance with the applicable requirements of the CBC, the CFC, the CCMC, and site-specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant. Therefore, the impacts related to exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1.

5. Alternatives
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Infrastructure Which Could Exacerbate Fire Risk
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 Project, 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. However, If future development under the Project were to require the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, the construction or relocation of these facilities would be 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 Project 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. 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. For these reasons, impacts related to infrastructure which could exacerbate fire risk would be less than significant.

Development of new or expanded infrastructure under Alternative 1 would be subject to compliance with applicable CFC, CBC, CCFD, and environmental review requirements to ensure that fire risks are not exacerbated. Therefore, the impacts related to exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1.

Expose People or Structures to Significant Risks
Future development allowed under the Project would be subject to the applicable regulations and requirements of the CCMC 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 related to exposure of people or structures to significant wildfire risks would be less than significant.

As with the Project, development under Alternative 1 would be subject to the applicable regulations and requirements of the CCMC and applicable regulations 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 development under Alternative 1 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 related to exposure of people or structures to significant wildfire risks would be reduced to a less-than- significant level, similar to the Project, although the severity of this impact would be less, as less growth would occur under Alternative 1.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-36 SCH No. 2022030144 City of Culver City March 2024
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Relationship of the Alternative to the Project Objectives Alternative 1, the No Project Alternative, represents what would be reasonably expected to occur in the foreseeable future if the Project were not adopted and the City’s current General Plan and Zoning Code remain in effect. Future development under Alternative 1 would be the continuation of growth in the city guided by the adopted 1996 General Plan and the current Zoning Code. This alternative would not meet most of the Project objectives and would not meet the underlying purpose of the Project since Alternative 1 would not result in the adoption and implementation of a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Code to implement the General Plan Update. Under Alternative 1, none of the land use designations and policies in the proposed General Plan Update designed to foster a vibrant and sustainable community, respond to an increasingly diverse and aging population, and address a myriad of physical, environmental, and other challenges that the city faces would be implemented. Alternative 1 would not meet the key goals of the Project to promote mixed-use development, better integration of land uses, improved alternate modes of transportation, equity (housing and health), and sustainability.

Alternative 1 would not meet the specific Project objectives to provide high-quality public services through an equitable, adaptive, transparent, accessible, and fiscally sustainable governing structure with intentional investments and regulatory measures; advance racial, demographic, and socioeconomic diversity by supporting a range of housing types for different income levels, household compositions, stages of life, and disadvantaged populations; adopt innovative and equitable policies to eliminate greenhouse gas emissions, reduce energy and water use, encourage the purchase of 100 percent renewable, carbon-free electricity, foster the transition to zero-emission vehicles, and adapt to climate disruption; and practice resilient and sustainable solutions to maintain and improve infrastructure, including water, road infrastructure, and broadband. Consequently, Alternative 1 would not meet most of the Project objectives and would not meet the underlying purpose of the Project.

5.5.2 Alternative 2 – Concentrated Growth Alternative
Description of the Alternative
Alternative 2, the Concentrated Growth Alternative, would be similar to the Project but would result in a different land use distribution strategy than the Project. Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. Therefore, under Alternative 2, the goals, policies, and implementation actions contained within the proposed General Plan elements would be applicable. Alternative 2 also includes all of the mobility improvements as proposed for the Project throughout the planning horizon of 2045. As with the Project, a Zoning Code Update for Alternative 2 would provide the development standards to implement the General Plan Update.

As shown in Table 5-1, the Concentrated Growth Alternative is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045.

Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project.

5. Alternatives
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Preliminary − Subject to Revision
The overall land use pattern under Alternative 2 would be similar to that for the Project.

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

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

Environmental Impacts
Aesthetics
Scenic Vistas
The Project would not have a substantial adverse effect on a scenic vista, as land use designations under the proposed General Plan Update focus development toward portions of the Planning Area that are already developed, and thus would relieve pressure to develop in open space and natural areas. In addition, the Project includes several policies that would regulate scenic quality and resources. For these reasons, this impact would be less than significant. In addition, the Zoning Code Update, which is the implementation mechanism, would provide requirements for future development consistent with the General Plan goals and policies. The Zoning Code Update would provide the zoning districts associated with each of the land use designations in the General Plan Update and the specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and building heights.

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

Therefore, impacts related to scenic vistas would be less than significant.

As with the Project, development under Alternative 2 would be directed toward portions of the Planning Area that are already developed and thus would relieve pressure to develop in open space and natural areas. The overall land use pattern under Alternative 2 would be similar to that for the Project. However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless,

5. Alternatives
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Alternative 2 would include the same policies that regulate scenic quality and resources as are found in the Project. Therefore, the impact with respect to scenic vistas would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Consistency with Applicable Zoning and Regulations Governing Scenic Quality While the Project would result in an increase in densities and intensities of land uses, the majority of the proposed changes would occur within Culver City, with limited land use changes occurring within SOI. Proposed policies in the General Plan Update are intended to complement and improve the existing scenic quality and resources in the city as well as to implement the City’s vision for the future character of the city. The Zoning Code Update would provide specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and building heights consistent with the General Plan Update. As such, the Zoning Code Update would not conflict with the General Plan Update and other regulations governing scenic quality. Therefore, impacts would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies that regulate scenic quality and resources as are found in the Project. Therefore, the impact with respect to consistency with applicable zoning and other regulations governing scenic quality would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Light and Glare
The Planning Area is urban in nature and thus, future development under the Project would primarily occur on parcels that contain uses that currently generate light and/or glare. While future development would include additional lighting and/or materials that could cause glare, the addition of these light and glare sources would be consistent with the existing urban environment and would replace the previous onsite light and glare sources. Therefore, any increase in ambient nighttime light conditions would not be substantial and would not be out of character with the urban environment. In addition, the General Plan Update includes policies related to buffering between uses and avoiding light spill and glare onto residential properties and sensitive habitats. Future development would be required to comply with applicable lighting regulations and standards in the CCMC. Therefore, impacts regarding light and glare that could affect day or nighttime views in the area would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies related to buffering between development and sensitive habitats, and between future development and existing uses as are found in the Project. As is the case for the Project, adherence to design standards in the CCMC and policies in the General Plan Update would ensure that light and glare from future development and redevelopment projects facilitated under Alternative 2 would be minimized. Therefore, the impact with respect to light and glare

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-39 SCH No. 2022030144 City of Culver City March 2024
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that could affect day or nighttime views in the area would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Air Quality
Air Quality Plan
Culver City continues to coordinate with the SCAQMD and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the operation of future development under the proposed General Plan and Zoning Code Update would not conflict with or obstruct the implementation of the applicable air quality plan. Nonetheless, the growth projections under the Project would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would be significant. Implementation of Mitigation Measures MM AQ-1 through MM AQ-5 would serve to reduce the severity of the impacts to emissions of criteria pollutants associated with future development and projected growth from future development under the Project. However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, impacts would remain significant and unavoidable.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies that address air quality as are found in the Project. As shown in Table 5-1, Alternative 2 is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045. Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project.

Similar to the Project, the growth projections contained in Alternative 2 would exceed the current SCAG growth forecasts for Culver City, although, by a slightly reduced margin than the Project. Similar to the Project, future development under Alternative 2 would be required to comply with applicable AQMP construction and operational control strategies. Therefore, the impact with respect to a conflict with the applicable air quality plan during construction and operation would be significant and mitigation would be required. However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, the growth projections under the Alternative 2 would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would remain significant and unavoidable, similar to the Project.

Criteria Pollutants
The Project could result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment, as the construction and operation of individual future projects would generate emissions of criteria pollutants that could exceed regional significance thresholds. Even with the implementation of mitigation measures (MM AQ-1 and MM AQ-5), this impact would be significant and unavoidable.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-40 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Alternative 2 is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045. Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project. It is possible that Alternative 2 could result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment for the same reason as the Project.

However, future development under Alternative 2 would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the Project to reduce construction phase and operational emissions. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Substantial Pollutant Concentrations
The Project could expose sensitive receptors to substantial pollutant concentrations, as the construction and operation of individual future projects would generate emissions of nitrogen NO
X, CO, PM10, and PM2.5 that could exceed localized significance thresholds established by the SCAQMD. In addition, the construction and operation of individual future projects could expose nearby sensitive receptors to levels of toxic air contaminants that could result in a potential increase in cancer, acute, and/or chronic risk. Even with the implementation of MM AQ-6 and MM AQ-7, this impact would be significant and unavoidable.

Alternative 2 could also expose sensitive receptors to substantial pollutant concentrations during construction and operation for the same reasons as the Project. Future development in the city would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the Project to reduce localized air quality and health risk impacts. However, even with implementation of mitigation measures, impacts could exceed the significance thresholds.

Therefore, this impact would also remain significant and unavoidable, similar to the Project.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Development allowed under Alternative 2 could also have a substantial adverse effect on riparian habitat or other sensitive natural communities that occur within the Planning Area. As is the case for the Project, development allowed under Alternative 2 would adhere to proposed General Plan policies related to the protection of biological resources; compliance with all applicable laws, regulations, and ordinances related to the protection of special-status plant and wildlife species; and implementation of mitigation measures (MM BIO-1 and MM BIO-2). Therefore, the impact to riparian habitat or other

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-41 SCH No. 2022030144 City of Culver City March 2024
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sensitive natural communities under Alternative 2 is expected to be reduced to a less-than- significant level, similar to the Project, and the severity of this impact would be similar.

The Project would have no impact.

Development allowed under Alternative 2 would also not have a substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations or by the CDFW or USFWS for the same reason as the Project. Therefore, as is the case for the Project, no impact would occur.

State or Federally Protected Wetlands
The Project would not have a substantial adverse effect on state or federally protected wetlands, as there are no wetlands present within the Planning Area. As a result, no impact would occur. In addition, the planned Ballona Creek Revitalization Project would enhance the restoration and use of Ballona Creek. Restoration activities may require Clean Water Act permits from the USACE and the RWQCB and/or a streambed alteration agreement from CDFW, which would be obtained prior to any work, and permit conditions would be implemented. Impacts would be less than significant.

Development allowed under Alternative 2 would also not have a substantial adverse effect on state or federally protected wetlands for the same reason as the Project. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Wildlife Corridors or Wildlife Nursery Sites
As there are no wildlife corridors present within the Planning Area, the Project would have no effect on wildlife corridors. In addition, nesting birds and/or nesting bird habitat have been recorded within the Planning Area, where implementation of the General Plan Update could directly or indirectly impact these biological resources. Compliance with the General Plan Update goals and policies, the Zoning Code Update, the MBTA, and mitigation measure MM BIO-2 would ensure that impacts to nesting birds would be reduced to less than significant.

Based on review of available information, no known non-avian wildlife nursery sites occur within the Planning Area.

Development allowed under Alternative 2 would also not have a substantial adverse effect on wildlife corridors or non-avian wildlife nursery sites for the same reason as the Project.

Therefore, as is the case for the Project, no impact would occur.

Development allowed under Alternative 2 could also have a substantial adverse effect on nesting birds and/or nesting bird habitat that occur within the Planning Area for the same reasons as the Project. As is the case for the Project, compliance with the General Plan Update goals and policies, the Zoning Code Update, the MBTA, and mitigation measure MM BIO-2

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General Plan 2045 and Zoning Code Update Project 5-42 SCH No. 2022030144 City of Culver City March 2024
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would ensure that impacts to nesting birds under Alternative 2 would be reduced to less than significant. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 2 would also not conflict with a tree preservation policy or ordinance for the same reason as the Project. Therefore, the impact related to conflicts with local policies or ordinances protecting biological resources would not occur, and impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would also adhere to the existing City Historic Preservation Ordinance and would include the same policies and mitigation measures that address potential effects to cultural resources as are found in the Project. Even with adherence to the existing City Historic Preservation Ordinance and proposed General Plan policies related to the protection of cultural resources and implementation of Mitigation Measure MM CUL-1, the impact related to a substantial adverse change in the significance of a historical resource under Alternative 2 would not be reduced to a less-than- significant level. As a result, this impact would be significant and unavoidable, similar to the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-43 SCH No. 2022030144 City of Culver City March 2024
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Archaeological Resources
The Project could cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. Adherence to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction, implementation of MM CUL-2, and implementation of applicable policies in the General Plan Update would reduce the impact to a less-than-significant level.

The overall land use pattern under Alternative 2 would be similar to that for the Project. However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would also adhere to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction and would include the same policies and mitigation measures that address potential effects to archeological resources. Therefore, the impact related to archaeological resources would be less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies that address energy resources as are found in the Project. Alternative 2 would also not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during construction for the same reasons as the Project. As a result, the impact with respect to the wasteful, inefficient, or unnecessary consumption of energy resources during construction would remain less than significant, similar to the Project, and the severity of this impact would be similar. With respect to operation, future development under Alternative 2 would be required to comply with applicable electric, natural gas, and transportation fuels control strategies, efficiency requirements, and regulations. Therefore, future development under Alternative 2 would result in a less-than- significant impact related to the wasteful, inefficient, or unnecessary consumption of energy resources during operation, similar to the Project, and the severity of this impact would be similar.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-44 SCH No. 2022030144 City of Culver City March 2024
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Conflict with State or Local Renewable Energy Plan
Construction of development permitted by the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency as individual projects would utilize construction contractors who must demonstrate compliance with applicable regulations. In addition, truck fleet operators must upgrade their fleets with vehicles that meet adopted fuel- efficiency standards for medium- and heavy-duty trucks. With respect to operation, future development that could occur under the Project would be designed in a manner consistent with the policies contained in the proposed General Plan Update that are designed to encourage development that results in the efficient use of energy resources. Additionally, new development would comply with Title 24 requirements and CALGreen to reduce energy consumption by implementing energy efficient building designs, pre-wiring residences with electric vehicle charging ports, implementing solar-ready rooftops, reducing indoor and outdoor water demand, and installing energy-efficient appliances and equipment. For these reasons, this impact would be less than significant.

Individual projects under Alternative 2 would also not conflict with or obstruct a state or local plan for renewable energy or energy efficiency for the same reasons as the Project. For these reasons, the impact would be less than significant, similar to the Project, and the severity of the impact would be similar.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies that address potential effects related to geology and soils as are found in the Project. As is the case for the Project, future development under Alternative 2 would be required to comply with all applicable design, engineering, and construction standards and requirements of the CBC, the CMCC, and policies contained in the proposed General Plan Update that are designed to further minimize seismic-related geologic hazards. Therefore, the impact with respect to risk of seismic-related geologic hazards would be less than significant, similar to the Project, and the severity of the impact would be similar.

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General Plan 2045 and Zoning Code Update Project 5-45 SCH No. 2022030144 City of Culver City March 2024
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permit, which would include implementation of BMPs and preparation of a SWPPP, which would include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. In addition, the proposed General Plan Update includes policies that encourage the use of BMPs to control soil erosion during and after ground-disturbing activities and the preparation of site-specific geotechnical investigations for projects requiring grading permits. As a result, this impact would be less than significant.

As is the case for the Project, future development under Alternative 2 that disturbs more than one acre would be subject to compliance with an NPDES permit and SWPPP and policies included in the General Plan Update that address impacts related to soil erosion or loss of topsoil. Therefore, the impact with respect to soil erosion or loss of topsoil would be less than significant, similar to the Project, and the severity of the impact would be similar.

As is the case for the Project, development allowed under Alternative 2 would be required to comply with all applicable design, engineering, and construction standards and requirements that address unstable or expansive soils. Therefore, the impact with respect to risk of unstable or expansive would be less than significant, similar to the Project, and the severity of the impact would be similar.

As is the case for the Project, development allowed under Alternative 2 would be required to comply with specific procedures in the City’s entitlement process to avoid damage to paleontological resources and promote their preservation, as well as proposed General Plan policies that promote public knowledge and protection of paleontological resources, and the requirements of Mitigation Measure MM GEO-1. Therefore, impacts to paleontological resources would be less than significant, similar to the Project, and the severity of the impact would be similar.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-46 SCH No. 2022030144 City of Culver City March 2024
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Greenhouse Gas Emissions
Emissions
The Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during construction, as future projects developed under the Project would be required to comply with applicable federal, state, and local regulations that would reduce the amount of GHG emissions generated by construction equipment and activities. With respect to operation, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, as the net change in operational emissions from existing conditions compared to existing plus buildout under the Project would be negative compared to existing conditions. For these reasons, this impact would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

Therefore, the impact with respect to the generation of GHG emissions during construction under Alternative 2 would remain less than significant, similar to the Project, and the severity of this impact would be similar. With respect to operation, as is the case for the Project, Alternative 2 would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, as the net change in operational emissions from existing conditions compared to existing plus buildout of new development under Alternative 2 would be negative compared to existing conditions. For these reasons, this impact would be less than significant, similar to the Project, and the severity of this impact would be similar.

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General Plan 2045 and Zoning Code Update Project 5-47 SCH No. 2022030144 City of Culver City March 2024
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Development permitted under Alternative 2 would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs for the same reasons as the Project. For these reasons, this impact would be less than significant, similar to the Project, and the severity of this impact would be similar.

Hazards and Hazardous Materials
Routine Use, Transportation, Disposal, or Accidental Release of Hazardous Materials The Project would not create a significant hazard to the public or the environment through the routine use, transport, disposal, or accidental release of hazardous materials, as the construction and operation of future development allowed under the Project would adhere to applicable federal, state, and local regulations governing the transportation, use, handling, and disposal of hazardous materials. As a result, this impact would be less than significant.

Development allowed under Alternative 2 would also not create a significant hazard to the public or the environment through the routine use, transport, disposal, or accidental release of hazardous materials during construction and operation for the same reason as the Project.

Development allowed under Alternative 2 would also not result in hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school site for the same reason as the Project. Therefore, the impact with respect to the transportation, use, handling, and disposal of hazardous materials would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Hazardous Materials Sites
The Project would not create a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 as future development under the Project would adhere to applicable federal, state, and local regulations that provide procedures for the testing, handling, disposal, and remediation of hazardous materials. As a result, this impact would be less than significant.

Development allowed under Alternative 2 would also not create a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 for the same reason as the Project.

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Therefore, the impact with respect to creating a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Emergency Response Plan
The Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s MJHMP, and policies contained in the General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant.

Development allowed under Alternative 2 would be required to be consistent with existing regulations, including the MJHMP, and policies contained in the General Plan Update that further ensure adequate emergency access. As a result, the impact with respect to the impairment or interference with an adopted emergency response plan or emergency evacuation plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Wildland Fire Hazards
While the majority of the Planning Area is not within a VHFHSZ, CAL FIRE classifies the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within West Los Angeles College and the IOF, as a VHFHSZ. Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development.

Future development allowed under the Project could include the development of additional residential uses in these neighborhoods, which could expose additional people and structures to wildland fire hazards. The General Plan Update contains policies to minimize the risk of fire hazards. With adherence to applicable building codes and review by the CCFD to reduce fire hazards, the Project would not expose people or structures to substantial wildfire hazards, and impacts would be less than significant.

Development allowed under Alternative 2 would also be required to adhere to building codes and review by the CCFD to reduce fire hazards. As a result, the impact with respect to wildland fire hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Hydrology and Water Quality
Water Quality
The Project would not result in the violation of any water quality standards or waste discharge requirements or otherwise substantially degrade water quality, as future development under the Project would comply with applicable federal, state, and local regulations pertaining to water quality. In addition, the Project contains policies that promote improved water quality in the city and continued compliance with federal, state, and local water quality regulations, which would ensure that water quality is protected to the maximum extent practicable. As a result, this impact would be less than significant.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-49 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Development allowed under Alternative 2 would also adhere to applicable federal, state, and local regulations pertaining to water quality. Therefore, the impact with respect to water quality would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Groundwater
The City’s water providers, LADWP and GSWC, use a combination of groundwater and surface water. There are limits on the amount of groundwater each provider can pump for potable water supplies, and the potential for overdraft is limited. These water providers would be able to utilize other sources of potable water to supplement a decrease in the amount of available groundwater, if needed. With regard to groundwater recharge, the General Plan Update establishes land use designations that encourage mixed uses and infill development, while maintaining existing parks and open space resources and expanding these resources. The Project would not result in substantial increases of impervious surfaces such that groundwater recharge would be hindered. For these reasons, the Project would not substantially deplete groundwater supplies or interfere substantially with groundwater recharge. As a result, this impact would be less than significant.

Development allowed under Alternative 2 would also not substantially deplete groundwater supplies for the same reasons as the Project. As a result, the impact with respect to groundwater recharge would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Drainage
Implementation of the Project would not directly alter the course of Ballona Creek (a major drainage that flows through the Planning Area), or any other streams or rivers. In addition, future development 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. For these reasons, the impact of the Project with respect to the alteration of drainage patterns would be less than significant.

Development allowed under Alternative 2 also would not directly alter the course of Ballona Creek or any other streams or rivers and would also 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. Therefore, the impact with respect to drainage would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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General Plan 2045 and Zoning Code Update Project 5-50 SCH No. 2022030144 City of Culver City March 2024
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the Planning Area. Additionally, future development facilitated under the Project would be required to comply with all applicable laws, regulations, and permits related to drainage and flooding hazards, which would reduce the risk of onsite flooding and release of pollutants.

Therefore, impacts associated with release of pollutants from inundation by flood, tsunami, or seiche would be less than significant.

Development allowed under Alternative 2 would also not result in impacts associated with release of pollutants from inundation by flood, tsunami, or seiche for the same reasons as the Project. As a result, the impact would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Moreover, the General Plan Update contains goals and policies that promote improved water quality and groundwater sustainability in the Planning Area, as well as continued compliance with state and local water quality regulations, which is intended to ensure that water quality and groundwater sustainability is managed to the maximum extent practicable. In addition, implementation of the Project would not interfere with or conflict with the Santa Monica Groundwater Subbasin Groundwater Sustainability Plan (GSP), since the City is a member of the Santa Monica Basin Groundwater Sustainability Agency, and the Project includes various implementation actions that support the GSP. Furthermore, due to the developed nature of the city and the proposed land use distribution, impacts to groundwater supplies as a result of new impervious surfaces would be less than significant. Therefore, the Project would not conflict with the Santa Monica Subbasin GSP, and impacts would be less than significant.

Development allowed under Alternative 2 would not conflict with an applicable water quality plan or sustainable groundwater management plan for the same reasons as the Project.

Therefore, the impact with respect to a water quality plan or sustainable groundwater management plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Land Use and Planning
Physically Divide a Community
The city is primarily built out with residential uses and only 0.6 percent is vacant land.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Mixed-use development along corridors under

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-51 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Alternative 2 would foster more linkages and connectivity throughout the city. Moreover, the Planning Area is largely built out and new development would occur within areas that are already served by infrastructure, and thus development under Alternative 2 would not necessitate new roads or other infrastructure that would physically divide an established community. Therefore, the impact with respect to physically dividing an established community would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Implementation of the Project would not conflict with existing planning regulations and policies, including those included in California Government Code Section 65302, the California Complete Streets Act, the SCAG 2020–2045 RTP/SCS (Connect SoCal), the CCUSD Multi-Jurisdictional Hazard Mitigation Plan, the Culver City Bicycle & Pedestrian Action Plan, and the Culver City Urban Forest Master Plan. For these reasons, this impact would be less than significant.

Development allowed under Alternative 2 would also not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect for the same reasons as the Project. Therefore, the impact with respect to conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Mineral Resources
Implementation of the Project would not result in the loss of availability of a known non-fuel mineral resource that would be of value to the region and residents of the State, nor would it create the loss of availability of a locally important mineral resource recovery site. No impact to aggregate mineral resources would occur with implementation of the Project. While there is ongoing oil and gas production within the City’s portion of the IOF, the City adopted the Oil Termination Ordinance, which requires the closure of the City’s portion of the IOF. Implementation of the Project would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation in a manner that would render the resources unavailable. As such, the Project would not result in the loss of a regionally and locally important mineral resource.

Impacts related to oil and gas resources would be considered less than significant.

Development allowed under Alternative 2 would result in no impact to aggregate mineral resources for the same reason as the Project. Development allowed under Alternative 2 also would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation. Therefore, the impact with respect to oil and gas resources would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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Noise and Vibration
Temporary or Permanent Increase in Ambient Noise Levels Construction of future development under the Project would require the use of heavy equipment during construction activities. The exact locations of future projects and construction that would occur under the Project are not known at this time, though it is assumed that some of the activities would take place in close proximity to sensitive receptors given that the City is generally built out. The severity of construction-related noise impacts depends on the proximity of construction activities to sensitive receptors, the presence of intervening barriers, the number and types of equipment used, and the duration and intensity of the activity. For future development projects requiring discretionary approval, a project-specific noise analysis would be prepared to determine significance and if necessary, recommend mitigation measures, in accordance with CEQA. Even with mandatory compliance with CCMC requirements, it is possible that some future development projects could be large in construction intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period noise levels could exceed the significance thresholds. Implementation of Mitigation Measure MM NOI-1 would help to reduce the potentially significant construction- related impacts. However, even with implementation of Mitigation Measure MM NOI-1, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Nonetheless, Alternative 2 would include the same policies and mitigation measure that address impacts related to noise and vibration as are found in the Project. Construction of future development allowed under Alternative 2, including discretionary development projects subject to CEQA review, could also result in noise levels that could exceed significance thresholds, even with mandatory compliance with CCMC requirements, for the same reasons as the Project. Implementation of project-specific mitigation measures would help to reduce the potentially significant construction-related impacts.

However, even with implementation of mitigation measures, impacts could exceed significance thresholds. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Future development projects under Alternative 2 could also generate operational-period roadway traffic noise levels that exceed significance thresholds and result in a significant impact for the same reasons as the Project. As is the case for the Project, there are no feasible mitigation measures to reduce traffic noise levels. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

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Excessive Groundborne Vibration or Groundborne Noise
Some future development projects under the Project could generate construction-period groundborne vibration and groundborne noise levels that exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance and result in a significant impact. Even with implementation of Mitigation Measure MM NOI-2, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

As a result, groundborne vibration and groundborne noise impacts during operation would be less than significant, and no mitigation is required.

Future development projects under Alternative 2 could also generate construction-period groundborne vibration and groundborne noise levels that exceed thresholds, even with implementation of mitigation measures, for the same reasons as the Project. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Impacts related to groundborne vibration and groundborne noise impacts during operation would be less than significant for the same reasons as the Project. Therefore, the impact would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Population and Housing
Induce Unplanned Population Growth
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. 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.

As discussed above in Section 5.5.2, Alternative 2 – Concentrated Growth Alternative, the overall land use pattern under Alternative 2 would be similar to that for the Project. However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. As shown in Table 5-1, Alternative 2 is projected to result in

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approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045.

Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project. As is the case for the Project, Alternative 2 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. As such, Alternative 2 would not induce substantial unplanned population growth, either directly or indirectly. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Construction of New Housing
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 29 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 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. 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. 7 The proposed Land
Use Element reflects the new land use designations that would allow greater residential densities 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.

As previously discussed, the overall land use pattern under Alternative 2 would be similar to that for the Project. However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. As is the case for the Project, Alternative 2 would provide infill development opportunities in vacant and underutilized areas in the city, while seeking to preserve existing neighborhoods. As is the case for the Project, Alternative 2 would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. Therefore, the impact would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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

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Public Services
Fire and Police Service
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered fire and police service facilities, as future development would be concentrated in areas already well-served by existing fire and police facilities. In addition, the Project would promote compact development patterns through infill development, ensuring new development would be located within close proximity to existing fire stations and police stations. If new fire and police facilities are needed, the construction of these facilities would be subject to compliance with existing regulations, proposed General Plan policies, and mitigation measures identified in other sections of this Draft PEIR to minimize adverse physical effects. For these reasons, this impact would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. As shown in Table 5-1, Alternative 2 is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045. Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project. Nonetheless, as is the case for the Project, future development under Alternative 2 would be concentrated in areas already well-served by existing fire and police facilities, and if new fire and police facilities are required, the construction of these facilities would have minimal effects on the environment with compliance with existing regulations and proposed General Plan policies. In addition, as is the case for the Project, Alternative 2 promotes compact development patterns through infill development, ensuring new development would be located within close proximity to existing fire stations and police stations. For these reasons, this impact would be less than significant, similar to the Project, although the severity of this impact would be less, as less growth would occur, and there would be less demand for fire and police services under Alternative 2 compared to the Project.

Schools
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. 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. The 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 impacts of development on school facilities for purposes of CEQA per SB 50. For these reasons, this impact would be less than significant.

As less growth would occur under Alternative 2 compared to the Project, fewer students would attend local schools under Alternative 2 than under the Project. If new school facilities are required, the construction of these facilities would also have minimal effects on the environment with compliance with existing regulations and proposed General Plan policies under Alternative 2. In addition, all new development under Alternative 2 would also be required to pay school impact fees. Therefore, the impact with respect to schools would remain

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less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for schools under Alternative 2 compared to the Project.

Parks
A comparison of impacts to parks and recreation facilities between the Project and Alternative 2 is provided below under “Recreation.”
Other Public Facilities
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, such as libraries, as the construction of these facilities, if needed, would be subject to compliance with existing regulations, proposed General Plan policies, and mitigation measures identified in other sections of this Draft PEIR to minimize adverse physical effects. As a result, this impact would be less than significant.

As less growth would occur under Alternative 2 compared to the Project, demand for other public facilities, such as libraries, would be less under Alternative 2 than under the Project. If new public facilities are required, the construction of these facilities would also have minimal effects on the environment with compliance with existing regulations and policies and proposed General Plan policies under Alternative 2. Therefore, the impact with respect to public facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 2 compared to the Project.

Recreation
Deterioration of Existing Recreational Facilities
Although the City is currently not meeting the park service ratio standard, the General Plan Update includes policies that 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.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

As is the case for the Project, the General Plan Update under Alternative 2 includes policies that 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, Alternative 2 would not increase the use of existing neighborhood

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and regional parks or other recreational facilities such that substantial physical deterioration of the facility would occur or be accelerated. Therefore, the impact with respect to substantial deterioration of existing recreational facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 2 compared to the Project.

For these reasons, this impact would be less than significant.

As is the case for the Project, Alternative 2 encourages the development of future recreational facilities in order to meet demand associated with anticipated population growth under the General Plan Update. As is the case for the Project, 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 recreational facilities would be consistent with the proposed land use designations and policies and would be subject to additional environmental review under CEQA, as needed. Therefore, the impact with respect to construction or expansion of recreational facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 2 compared to the Project.

Transportation
Conflict with Adopted Circulation Program, Plan, Ordinance, or Policy The Project would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway bicycle and pedestrian facilities due to the availability of non-vehicular transportation options for the community. In addition, policies included in the General Plan Update would balance the multimodal transportation network by providing alternatives to the automobile, improving transit service connections, and encouraging the use of alternative modes of transportation. As a result, this impact would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Mixed-use development along corridors under Alternative 2 would foster more linkages and connectivity throughout the city. For the same reasons as the Project, Alternative 2 would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway bicycle and pedestrian facilities due to the availability of non-vehicular transportation options for the community. As is the case for the Project, Alternative 2 would include the same policies included in the General Plan that would balance the multimodal transportation network by providing alternatives to the

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automobile, improving transit service connections, and encouraging the use of alternative modes of transportation. Therefore, the impact with respect to conflict with adopted circulation program, plan, ordinance, or policy would remain less than significant, similar to the Project.

Although policies promoting a reduction of VMT per capita are included in the General Plan Update, no feasible mitigation is available to reach the 15 percent or more reduction threshold.

As a result, this impact would be significant and unavoidable.

As less growth would occur under Alternative 2 compared to the Project, less traffic would be generated along streets in the Planning Area, and thus less VMT would be generated under the existing General Plan. However, this reduction in VMT under Alternative 2 would not likely be enough to achieve a 15 percent or more reduction compared to the baseline. As a result, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less as less traffic would be generated under Alternative 2 compared to the Project.

Future development under Alternative 2 would also be designed in compliance with the City’s standards for safety and would provide adequate sight distance. As a result, the impact with respect to design hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Future development under Alternative 2 would also not result in inadequate emergency access for the same reason as the Project. Therefore, the impact with respect to emergency access would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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Tribal Cultural Resources
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 under the Project 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, if necessary, are implemented to reduce impacts on these resources. 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 resources are uncovered during construction. Adherence to these regulations and implementation of General Plan policies would ensure that the Project’s impact with respect to tribal cultural resources would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project although with greater amounts of mixed-use development throughout the city on corridors compared to the Project. Development under Alternative 2 may also result in the identification of unrecorded tribal cultural resources. However, future projects under Alternative 2 would also 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.

Utilities and Service Systems
New or Expanded Facilities
The Project would not require or result in the relocation or construction of new or expanded wastewater treatment facilities. However, future development under the Project could require or result in the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, and should upgrades to new facilities be required, the construction of those facilities could result in adverse environmental effects, which are considered throughout the technical sections of this Draft PEIR. In addition, future facilities would be required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. As a result, this impact would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

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by 2045. Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project.

Development allowed under Alternative 2 could also require or result in the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, and should upgrades to new facilities be required, the construction of those facilities could result in adverse environmental effects, which are considered throughout the technical sections of this Draft PEIR. In addition, future facilities would be required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. As a result, this impact would be less than significant. For these reasons, the impact with respect to new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities under Alternative 2 would remain less than significant, similar to the Project.

Water Supply
Culver City is served by two water service providers: GSWC and LADWP. 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 SCAG 2020–2045 RTP/SCS (Connect SoCal). However, as discussed in Section 4.18, the Project would result in growth and an increase in intensity above these projections. The General Plan Update includes policies and actions that would reduce water demand of future development allowed under the Project. Furthermore, 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 CCMC Chapter 5.03, the City’s Water Conservation Plan, and policies in the General Plan Update aimed at reducing demand over time, sufficient water supply is not documented to be available at this time. No additional mitigation measures beyond these actions would be feasible. Thus, the water supply impact is considered significant and unavoidable.

While Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project, Alternative 2 could result in growth above GSWC’s and LADWP’s water supply projections in their respective 2020 UWMPs. As with the Project, the General Plan Update under Alternative 2 includes policies and actions that would reduce water demand of future development. Furthermore, compliance with current CALGreen requirements would ensure that future development allowed under Alternative 2 would establish water conservation features. Although future development under Alternative 2 would be required to comply with CCMC Chapter 5.03, the City’s Water Conservation Plan, and policies in the General Plan Update aimed at reducing demand over time, sufficient water supply for Alternative 2 is not documented to be available at this time. No additional mitigation measures beyond these actions would be feasible. Thus, the water supply impact for Alternative 2 is considered significant and unavoidable, similar to the Project.

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Wastewater Service Capacity
The wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to future growth anticipated under the General Plan Update. In addition, policies in the proposed General Plan Update aim to conserve water by curbing demand for domestic and commercial purposes and promoting water conservation strategies, thus reducing demand for water, and in turn, the generation of wastewater. For these reasons, this impact would be less than significant.

As is the case for the Project, Alternative 2 would not result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments, as the wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to future growth anticipated under Alternative 2. In addition, policies in the proposed General Plan Update that would also be included under Alternative 2 aim to conserve water by curbing demand for domestic and commercial purposes and promoting water conservation strategies, thus reducing demand for water, and in turn, the generation of wastewater. As a result, the impact with respect to wastewater service capacity under Alternative 2 would remain less than significant, similar to the Project.

As is the case for the Project, Alternative 2 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, as the landfills that currently serve the city have adequate capacity to dispose of the full increase in solid waste attributable to future growth anticipated under Alternative 2. In addition, compliance with existing solid waste regulations and policies in the proposed General Plan Update that would also be included under Alternative 2 would further address potential impacts. As a result, the impact with respect to solid waste under Alternative 2 would remain less than significant, similar to the Project.

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Development allowed under Alternative 2 would also comply with federal, state, and local management and reduction statutes and regulations related to solid waste. As a result, the impact with respect to solid waste regulations would remain less than significant, similar to the Project.

Wildfire
Emergency Response or Evacuation Plans
The Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s MJHMP, and policies in the proposed General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant.

The overall land use pattern under Alternative 2 would be similar to that for the Project.

However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. As is the case for the Project, Alternative 2 would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s MJHMP, and policies in the proposed General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant, similar to the Project.

Exacerbate Wildfire Risks
While the majority of the Planning Area is not within a VHFHSZ, CAL FIRE classifies the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods as a VHFHSZ. Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development. Development associated with the Project 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. In addition, smoke from wildfires occurring in Los Angeles County and across the state has resulted in poor air quality within Culver City. 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. Compliance with the applicable requirements of the CBC, the CFC, the CCMC, the policies of the General Plan Update, and site- specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant.

As development allowed under Alternative 2 would occur within the Planning Area Alternative 2 could also exacerbate wildfire risks as identified for the Project. As with the Project, required compliance with the applicable requirements of the CBC, the CFC, the CCMC, and site-specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant. Therefore, the impacts related to

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exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project.

Infrastructure Which Could Exacerbate Fire Risk
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 Project, 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. However, If future development under the Project were to require the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, the construction or relocation of these facilities would be 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 Project 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. 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. For these reasons, impacts related to infrastructure which could exacerbate fire risk would be less than significant.

As is the case for the Project, development of new or expanded infrastructure under Alternative 2 would also be subject to 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. Therefore, the impacts related to exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project.

As is the case for the Project, development allowed under Alternative 2 would also be subject to the applicable regulations and requirements of the CCMC and applicable regulations 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 development allowed under Alternative 2 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,

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impacts related to exposure of people or structures to significant wildfire risks would be reduced to a less-than-significant level, similar to the Project.

Relationship of the Alternative to the Project Objectives As discussed above in Section 5.5.2, Alternative 2 – Concentrated Growth Alternative, the overall land use pattern under Alternative 2 would be similar to that for the Project. However, Alternative 2 would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. As shown in Table 5-1, Alternative 2 is projected to result in approximately 59,530 residents, 27,200 housing units, and 83,200 jobs in Culver City by 2045.

Thus, Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project. Alternative 2 would achieve all of the objectives for the Project. However, Alternative 2 would not meet future needs based on the projected population and job growth to the same degree as the Project.

5.5.3 Alternative 3 – Modified Mixed Use High Designation Description of the Alternative
Alternative 3, the Modified Mixed Use High Designation Alternative, would be similar to the Project but would result in a reduction of residential units and commercial uses in the areas designated as Mixed Use High compared with the Project. As shown in Table 5-1, the Modified Mixed Use High Designation Alternative is projected to result in approximately 61,170 residents, 27,340 housing units, and 84,090 jobs in Culver City by 2045. Thus, Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project.

Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. The overall land use pattern under Alternative 3 would be similar to that for the Project. As with the Project, Alternative 3 would accommodate growth through infill development and redevelopment with growth occurring along corridors. Alternative 3 would incorporate mixed-use development on opportunity sites and in the industrial areas. However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum floor area ratio (FAR) 8 would
decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. In addition, with the reduction of residences there would be a reduction in the amount of incidental commercial floor area, thereby resulting in the reduction of approximately 210 jobs compared with the Project.

Under Alternative 3, the goals, policies, and implementation actions contained within the proposed General Plan elements would be applicable. Alternative 3 would include all of the

8 Floor area ratio (FAR) is the ratio of a building's total floor area to the size of the piece of land upon which it is built. It is often used as one of the regulations in city planning and can refer to limits imposed on such a ratio through zoning.

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mobility improvements as proposed for the Project throughout the planning horizon of 2045. As with the Project, a Zoning Code Update for Alternative 3 would provide the development standards to implement the General Plan Update.

Environmental Impacts
Aesthetics
Scenic Vistas
As discussed in Section 4.1, Aesthetics, of this Draft PEIR, the Project would not have a substantial adverse effect on a scenic vista, as land use designations under the proposed General Plan Update focus development toward portions of the Planning Area that are already developed, and thus would relieve pressure to develop in open space and natural areas. In addition, the Project includes several policies that would regulate scenic quality and resources.

As with the Project, development under Alternative 3 would be directed toward portions of the Planning Area that are already developed and thus would relieve pressure to develop in open space and natural areas. The overall land use pattern under Alternative 3 would be similar to that for the Project. However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. Nonetheless, Alternative 3 would include the same policies that regulate scenic quality and resources as are found in the Project. Therefore, the impact with respect to scenic vistas would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Consistency with Applicable Zoning and Regulations Governing Scenic Quality While the Project would result in an increase in densities and intensities of land uses, the majority of the proposed changes would occur within Culver City, with limited land use changes occurring within SOI. Proposed policies in the General Plan Update are intended to complement and improve the existing scenic quality and resources in the city as well as to implement the City’s vision for the future character of the city. The Zoning Code Update would provide specific development standards, including permitted and conditional uses, densities, setbacks, lot coverage, and building heights consistent with the General Plan Update. As such, the Zoning

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Code Update would not conflict with the General Plan Update and other regulations governing scenic quality. Therefore, impacts would be less than significant.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Nonetheless, Alternative 3 would include the same policies that regulate scenic quality and resources as are found in the Project. Therefore, the impact with respect to consistency with applicable zoning and other regulations governing scenic quality would remain less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Nonetheless, Alternative 3 would include the same policies related to buffering between development and sensitive habitats, and between future development and existing uses as are found in the Project. As is the case for the Project, adherence to design standards in the CCMC and policies in the General Plan Update would ensure that light and glare from future development and redevelopment projects facilitated under Alternative 3 would be minimized. Therefore, the impact with respect to light and glare that could affect day or nighttime views in the area would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Air Quality
Air Quality Plan
As discussed in Section 4.2, Air Quality, of this Draft PEIR, Culver City continues to coordinate with the SCAQMD and SCAG to ensure citywide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. Therefore, the operation of future development under the proposed General Plan and Zoning Code Update would not conflict with or obstruct the implementation of the applicable air quality plan. Nonetheless, the growth projections under the Project would

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

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Nonetheless, Alternative 3 would include the same policies that address air quality as are found in the Project. As shown in Table 5-1, the Modified Mixed Use High Designation Alternative is projected to result in approximately 61,170 residents, 27,340 housing units, and 84,090 jobs in Culver City by 2045. Thus, Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project. Similar to the Project, the growth projections contained in Alternative 3 would exceed the current SCAG growth forecasts for Culver City, although, by a slightly reduced margin than the Project. Similar to the Project, future development under Alternative 3 would be required to comply with applicable AQMP construction and operational control strategies. Therefore, the impact with respect to a conflict with the applicable air quality plan during construction and operation would be significant and mitigation would be required.

However, even with implementation of Mitigation Measures MM AQ-1 through MM AQ-5, the growth projections under the Alternative 3 would exceed the current SCAG growth forecasts for Culver City; therefore, impacts would remain significant and unavoidable, similar to the Project.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Nonetheless, Alternative 3 would include the same policies that address air quality as are found in the Project. As shown in Table 5-1, the Modified Mixed Use High Designation Alternative is projected to result in approximately 61,170 residents, 27,340 housing units, and 84,090 jobs in Culver City by 2045. Thus, Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project. It is possible that Alternative 3 could result in a cumulatively considerable net increase of criteria pollutants for which the project region is non-attainment for the same reason as the Project. However, future development under Alternative 3 would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the

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Project to reduce construction phase and operational emissions. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Substantial Pollutant Concentrations
The Project could expose sensitive receptors to substantial pollutant concentrations, as the construction and operation of individual future projects would generate emissions of nitrogen NOX, CO, PM10, and PM2.5 that could exceed localized significance thresholds established by the SCAQMD. In addition, the construction and operation of individual future projects could expose nearby sensitive receptors to levels of toxic air contaminants that could result in a potential increase in cancer, acute, and/or chronic risk. Even with the implementation of MM AQ-6 and MM AQ-7, this impact would be significant and unavoidable.

Alternative 3 could also expose sensitive receptors to substantial pollutant concentrations during construction and operation for the same reasons as the Project. Future development in the city would be required to comply with applicable SCAQMD rules and to implement similar mitigation as the Project to reduce localized air quality and health risk impacts. However, even with implementation of mitigation measures, impacts could exceed the significance thresholds.

Therefore, this impact would also remain significant and unavoidable, similar to the Project.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. Development allowed under Alternative 3 could also have a substantial adverse effect on riparian habitat or other sensitive natural communities that occur within the Planning Area. As is the case for the Project, development allowed under Alternative 3 would adhere to proposed General Plan policies related to the protection of biological resources; compliance with all applicable laws, regulations, and ordinances related to the protection of special-status plant and wildlife species; and implementation of mitigation measures (MM BIO-1 and MM BIO-2). Therefore, the impact to riparian habitat or other sensitive natural communities under Alternative 3 is expected to be reduced to a less-than-significant level, similar to the Project, and the severity of this impact would be similar.

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Riparian Habitat or Sensitive Natural Habitat
Given the lack of any sensitive natural communities, including lack of riparian habitat, within the Planning Area, the Project would have no effect on these resources. Therefore, the Project would not result in a substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations or by CDFW or USFWS.

The Project would have no impact.

Development allowed under Alternative 3 would also not have a substantial adverse effect on any riparian habitat or other sensitive natural communities identified in local or regional plans, policies, or regulations or by the CDFW or USFWS for the same reason as the Project. Therefore, as is the case for the Project, no impact would occur.

State or Federally Protected Wetlands
The Project would not have a substantial adverse effect on state or federally protected wetlands, as there are no wetlands present within the Planning Area. As a result, no impact would occur. In addition, the planned Ballona Creek Revitalization Project would enhance the restoration and use of Ballona Creek. Restoration activities may require Clean Water Act permits from the USACE and the RWQCB and/or a streambed alteration agreement from CDFW, which would be obtained prior to any work, and permit conditions would be implemented. Impacts would be less than significant.

Development allowed under Alternative 3 would also not have a substantial adverse effect on state or federally protected wetlands for the same reason as the Project. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Wildlife Corridors or Wildlife Nursery Sites
There are no wildlife corridors present within the Planning Area. Therefore, the Project would have no effect on wildlife corridors. In addition, nesting birds and/or nesting bird habitat have been recorded within the Planning Area, where implementation of the General Plan Update could directly or indirectly impact these biological resources. Compliance with the General Plan Update goals and policies, the Zoning Code Update, the MBTA, and mitigation measure MM BIO-2 would ensure that impacts to nesting birds would be reduced to less than significant.

Based on review of available information, no known non-avian wildlife nursery sites occur within the Planning Area.

Development allowed under Alternative 3 would also not have a substantial adverse effect on wildlife corridors or non-avian wildlife nursery sites for the same reason as the Project.

Therefore, as is the case for the Project, no impact would occur.

Development allowed under Alternative 3 could also have a substantial adverse effect on nesting birds and/or nesting bird habitat that occur within the Planning Area for the same reasons as the Project. As is the case for the Project, compliance with the General Plan Update goals and policies, the Zoning Code Update, the MBTA, and mitigation measure MM BIO-2 would ensure that impacts to nesting birds under Alternative 3 would be reduced to less than

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significant. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would also not conflict with a tree preservation policy or ordinance for the same reason as the Project. Therefore, the impact related to conflicts with local policies or ordinances protecting biological resources would not occur, and impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. Nonetheless, Alternative 3 would also adhere to the existing City Historic Preservation Ordinance and would include the same policies and mitigation measures that address potential effects to cultural resources as are found in the Project. Even with adherence to the existing City Historic Preservation Ordinance and proposed General Plan policies related to the protection of cultural resources and implementation of Mitigation Measure MM CUL-1, the impact related to a substantial adverse change in the significance of a historical resource under Alternative 3 would not be reduced to a less-than-significant level. As a result, this impact would be significant and unavoidable, similar to the Project.

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Archaeological Resources
The Project could cause a substantial adverse change in the significance of an archaeological resource pursuant to CEQA Guidelines Section 15064.5. Adherence to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction, implementation of MM CUL-2, and implementation of applicable policies in the General Plan Update would reduce the impact to a less-than-significant level.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Nonetheless, Alternative 3 would also adhere to the City’s standard conditions of approval that require and specify steps to be taken to avoid damage and promote preservation of unknown archaeological resources uncovered during construction and would include the same policies and mitigation measures that address potential effects to archeological resources. Therefore, the impact related to archaeological resources would be less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. Nonetheless, Alternative 3 would include the same policies that address energy resources as are found in the Project. Alternative 3 would also not result in a potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources during construction for the same reasons as the Project. As a result, the impact with respect to the wasteful, inefficient, or unnecessary consumption of energy resources during construction would remain less than significant, similar to the Project, and the

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severity of this impact would be similar. With respect to operation, future development under Alternative 3 would be required to comply with applicable electric, natural gas, and transportation fuels control strategies, efficiency requirements, and regulations. Therefore, future development under Alternative 3 would result in a less-than-significant impact related to the wasteful, inefficient, or unnecessary consumption of energy resources during operation, similar to the Project, and the severity of this impact would be similar.

Conflict with State or Local Renewable Energy Plan
Construction of development permitted by the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency as individual projects would utilize construction contractors who must demonstrate compliance with applicable regulations. In addition, truck fleet operators must upgrade their fleets with vehicles that meet adopted fuel- efficiency standards for medium- and heavy-duty trucks. With respect to operation, future development that could occur under the Project would be designed in a manner consistent with the policies contained in the proposed General Plan Update that are designed to encourage development that results in the efficient use of energy resources. Additionally, new development would comply with Title 24 requirements and CALGreen to reduce energy consumption by implementing energy efficient building designs, pre-wiring residences with electric vehicle charging ports, implementing solar-ready rooftops, reducing indoor and outdoor water demand, and installing energy-efficient appliances and equipment. For these reasons, this impact would be less than significant.

Individual projects under Alternative 3 would also not conflict with or obstruct a state or local plan for renewable energy or energy efficiency for the same reasons as the Project. For these reasons, the impact would be less than significant, similar to the Project, and the severity of the impact would be similar.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

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potential effects related to geology and soils as are found in the Project. As is the case for the Project, future development under Alternative 3 would be required to comply with all applicable design, engineering, and construction standards and requirements of the CBC, the CMCC, and policies contained in the proposed General Plan Update that are designed to further minimize seismic-related geologic hazards. Therefore, the impact with respect to risk of seismic-related geologic hazards would be less than significant, similar to the Project, and the severity of the impact would be similar.

Soil Erosion or Loss of Topsoil
The Project would not result in substantial soil erosion or the loss of topsoil, as future development that disturbs more than one acre would be required to comply with an NPDES permit, which would include implementation of BMPs and preparation of a SWPPP, which would include erosion prevention measures that have proven effective in limiting soil erosion and loss of topsoil. In addition, the proposed General Plan Update includes policies that encourage the use of BMPs to control soil erosion during and after ground-disturbing activities and the preparation of site-specific geotechnical investigations for projects requiring grading permits. As a result, this impact would be less than significant.

As is the case for the Project, future development under Alternative 3 that disturbs more than one acre would be subject to compliance with an NPDES permit and SWPPP and policies included in the General Plan Update that address impacts related to soil erosion or loss of topsoil. Therefore, the impact with respect to soil erosion or loss of topsoil would be less than significant, similar to the Project, and the severity of the impact would be similar.

As is the case for the Project, development allowed under Alternative 3 would be required to comply with all applicable design, engineering, and construction standards and requirements that address unstable or expansive soils. Therefore, the impact with respect to risk of unstable or expansive would be less than significant, similar to the Project, and the severity of the impact would be similar.

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subject to project-specific paleontological studies. As a result, this impact would be less than significant.

As is the case for the Project, development allowed under Alternative 3 would be required to comply with specific procedures in the City’s entitlement process to avoid damage to paleontological resources and promote their preservation, as well as proposed General Plan policies that promote public knowledge and protection of paleontological resources, and the requirements of Mitigation Measure MM GEO-1. Therefore, impacts to paleontological resources would be less than significant, similar to the Project, and the severity of the impact would be similar.

Greenhouse Gas Emissions
Emissions
As discussed in Section 4.7, Greenhouse Gas Emissions, of this Draft PEIR, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during construction, as future projects developed under the Project would be required to comply with applicable federal, state, and local regulations that would reduce the amount of GHG emissions generated by construction equipment and activities. With respect to operation, the Project would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, as the net change in operational emissions from existing conditions compared to existing plus buildout under the Project would be negative compared to existing conditions. For these reasons, this impact would be less than significant.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. As is the case for the Project, Alternative 3 would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment during construction for the same reasons as the Project. Therefore, the impact with respect to the generation of GHG emissions during construction under Alternative 3 would remain less than significant, similar to the Project, and the severity of this impact would be similar. With respect to operation, as is the case for the Project, Alternative 3 would not generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment, as the net change in operational emissions from existing conditions compared to existing plus buildout of new development under Alternative 3 would be negative compared to existing conditions. For these reasons, this impact would be less than significant, similar to the Project, and the severity of this impact would be similar.

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addition, it is reasonable to expect the GHG emissions from future development anticipated by the Project would decline over time due to regulatory initiatives and technical innovations, and thus development permitted by the proposed General Plan Update would not conflict with or interfere with the ability of the state to achieve its GHG reduction goal of 80 percent below 1990 levels by 2050 as stated in Executive Order S-3-05. In addition, the Project would be consistent with applicable SCAG 2020–2045 RTP/SCS (Connect SoCal) actions and strategies, which work to reduce GHG emissions generated by the transportation sector by aligning transportation, land use, and housing strategies. Finally, the development that would occur under the Project would be required to be consistent with the proposed Greenhouse Gas Reduction Element and with the City’s Green Building Program. For these reasons, this impact would be less than significant.

Development permitted under Alternative 3 would not conflict with any applicable plan, policy, or regulation adopted for the purpose of reducing the emissions of GHGs for the same reasons as the Project. For these reasons, this impact would be less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would also not create a significant hazard to the public or the environment through the routine use, transport, disposal, or accidental release of hazardous materials during construction and operation for the same reason as the Project.

Development allowed under Alternative 3 would also not result in hazardous emissions or the handling of hazardous or acutely hazardous materials, substances, or waste within 0.25 miles of an existing or proposed school site for the same reason as the Project. Therefore, the impact with respect to the transportation, use, handling, and disposal of hazardous materials would

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remain less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would also not create a significant hazard to the public or environment from a site which is included on a list of hazardous materials sites compiled pursuant to Government Code Section 65962.5 for the same reason as the Project.

Emergency Response Plan
The Project would not impair implementation of or interfere with an adopted emergency response plan or emergency evacuation plan, as future development under the Project would be required to be consistent with existing regulations, including the City’s MJHMP, and policies contained in the General Plan Update that further ensure adequate emergency access. As a result, this impact would be less than significant.

Development allowed under Alternative 3 would be required to be consistent with existing regulations, including the MJHMP, and policies contained in the General Plan Update that further ensure adequate emergency access. As a result, the impact with respect to the impairment or interference with an adopted emergency response plan or emergency evacuation plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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Development allowed under Alternative 3 would also be required to adhere to building codes and review by the CCFD to reduce fire hazards. As a result, the impact with respect to wildland fire hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would also adhere to applicable federal, state, and local regulations pertaining to water quality. Therefore, the impact with respect to water quality would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would also not substantially deplete groundwater supplies for the same reasons as the Project. As a result, the impact with respect to groundwater recharge would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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discharging into the city’s sewer system. For these reasons, the impact of the Project with respect to the alteration of drainage patterns would be less than significant.

Development allowed under Alternative 3 also would not directly alter the course of Ballona Creek or any other streams or rivers and would also 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. Therefore, the impact with respect to drainage would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Therefore, impacts associated with release of pollutants from inundation by flood, tsunami, or seiche would be less than significant.

Development allowed under Alternative 3 would also not result in impacts associated with release of pollutants from inundation by flood, tsunami, or seiche for the same reasons as the Project. As a result, the impact would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Moreover, the General Plan Update contains goals and policies that promote improved water quality and groundwater sustainability in the Planning Area, as well as continued compliance with state and local water quality regulations, which is intended to ensure that water quality and groundwater sustainability is managed to the maximum extent practicable. In addition, implementation of the Project would not interfere with or conflict with the Santa Monica Groundwater Subbasin Groundwater Sustainability Plan (GSP), since the City is a member of the Santa Monica Basin Groundwater Sustainability Agency, and the Project includes various implementation actions that support the GSP. Furthermore, due to the developed nature of the city and the proposed land use distribution, impacts to groundwater supplies as a result of new impervious surfaces would be less than significant. Therefore, the Project would not conflict with the Santa Monica Subbasin GSP, and impacts would be less than significant.

Development allowed under Alternative 3 would not conflict with an applicable water quality plan or sustainable groundwater management plan for the same reasons as the Project.

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Therefore, the impact with respect to a water quality plan or sustainable groundwater management plan would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Land Use and Planning
Physically Divide a Community
The city is primarily built out with residential uses and only 0.6 percent is vacant land.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

Consistency with Applicable Land Use Plans
The Project would not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. The proposed General Plan Update is intended to provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its SOI, through the planning horizon year of 2045. The Zoning Code Update is the mechanism to implement the land use changes proposed in the City’s General Plan Update. Implementation of the Project would not conflict with existing planning regulations and policies, including those included in California Government Code Section 65302, the California Complete Streets Act, the SCAG 2020–2045 RTP/SCS (Connect SoCal), the CCUSD Multi-Jurisdictional Hazard Mitigation Plan, the Culver City Bicycle & Pedestrian Action Plan, and the Culver City Urban Forest Master Plan. For these reasons, this impact would be less than significant.

Development allowed under Alternative 3 would also not cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect for the same reasons as the Project. Therefore, the impact with respect to conflict with any land use plan, policy, or regulation adopted for the

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purpose of avoiding or mitigating an environmental effect would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Development allowed under Alternative 3 would result in no impact to aggregate mineral resources for the same reason as the Project. Development allowed under Alternative 3 also would not remove the existing IOF oil and gas resources nor change the City’s IOF land use designation. Therefore, the impact with respect to oil and gas resources would remain less than significant, similar to the Project, and the severity of this impact would be similar.

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receptors, these policies cannot ensure that noise levels would be reduced to levels below the City’s noise standards at all sensitive receptors. Therefore, traffic noise impacts under the Project would be significant and unavoidable.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

Construction of future development allowed under Alternative 3, including discretionary development projects subject to CEQA review, could also result in noise levels that could exceed significance thresholds, even with mandatory compliance with CCMC requirements, for the same reasons as the Project. Implementation of project-specific mitigation measures would help to reduce the potentially significant construction-related impacts. However, even with implementation of mitigation measures, impacts could exceed significance thresholds.

Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Future development projects under Alternative 3 could also generate operational-period roadway traffic noise levels that exceed significance thresholds and result in a significant impact for the same reasons as the Project. As is the case for the Project, there are no feasible mitigation measures to reduce traffic noise levels. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

Excessive Groundborne Vibration or Groundborne Noise
Some future development projects under the Project could generate construction-period groundborne vibration and groundborne noise levels that exceed the specified limits in the FTA Transit Noise and Vibration Impact Assessment Manual for potential structural damage and/or human annoyance and result in a significant impact. Even with implementation of Mitigation Measure MM NOI-2, impacts could exceed the significance thresholds and impacts would be significant and unavoidable.

As a result, groundborne vibration and groundborne noise impacts during operation would be less than significant, and no mitigation is required.

Future development projects under Alternative 3 could also generate construction-period groundborne vibration and groundborne noise levels that exceed thresholds, even with

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implementation of mitigation measures, for the same reasons as the Project. Therefore, this impact would also remain significant and unavoidable, similar to the Project.

As discussed above in Section 5.5.3, Alternative 3 – Modified Mixed Use High Designation, the overall land use pattern under Alternative 3 would be similar to the Project but would result in a reduction of residential units and commercial uses in the areas designated as Mixed Use High compared with the Project. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. As shown in Table 5-1, the Modified Mixed Use High Designation Alternative is projected to result in approximately 61,170 residents, 27,340 housing units, and 84,090 jobs in Culver City by 2045.

Thus, Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project. As is the case for the Project, Alternative 3 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. As such, Alternative 3 would not induce substantial unplanned population growth, either directly or indirectly. Impacts would be less than significant, similar to the Project, and the severity of this impact would be similar.

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residential uses in more areas of the city, including within industrial areas of the city. 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, 2022.9 The proposed Land Use Element reflects the new land use designations that would allow greater residential densities 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.

As previously discussed, the overall land use pattern under Alternative 3 would be similar to that for the Project. However, Alternative 3 would result in a reduction of residential units and commercial uses in the areas designated as Mixed Use High compared with the Project. As is the case for the Project, Alternative 3 would provide infill development opportunities in vacant and underutilized areas in the city, while seeking to preserve existing neighborhoods. As is the case for the Project, Alternative 3 would not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere. Therefore, the impact would remain less than significant, similar to the Project, and the severity of this impact would be similar.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and

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

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the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. Nonetheless, as is the case for the Project, future development under Alternative 3 would be concentrated in areas already well-served by existing fire and police facilities, and if new fire and police facilities are required, the construction of these facilities would have minimal effects on the environment with compliance with existing regulations and proposed General Plan policies. In addition, as is the case for the Project, Alternative 3 promotes compact development patterns through infill development, ensuring new development would be located within close proximity to existing fire stations and police stations. For these reasons, this impact would be less than significant, similar to the Project, although the severity of this impact would be less, as less growth would occur, and there would be less demand for fire and police services under Alternative 3 compared to the Project.

Schools
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered school facilities. 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. The 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 impacts of development on school facilities for purposes of CEQA per SB 50. For these reasons, this impact would be less than significant.

As less growth would occur under Alternative 3 compared to the Project, fewer students would attend local schools under Alternative 3 than under the Project. If new school facilities are required, the construction of these facilities would also have minimal effects on the environment with compliance with existing regulations and proposed General Plan policies under Alternative 3. In addition, all new development under Alternative 3 would also be required to pay school impact fees. Therefore, the impact with respect to schools would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for schools under Alternative 3 compared to the Project.

Parks
A comparison of impacts to parks and recreation facilities between the Project and Alternative 3 is provided below under “Recreation.”
Other Public Facilities
The Project would not result in substantial adverse physical impacts associated with the provision of new or physically altered government facilities, such as libraries, as the construction of these facilities, if needed, would be subject to compliance with existing regulations, proposed General Plan policies, and mitigation measures identified in other sections of this Draft PEIR to minimize adverse physical effects. As a result, this impact would be less than significant.

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As less growth would occur under Alternative 3 compared to the Project, demand for other public facilities, such as libraries, would be less under Alternative 3 than under the Project. If new public facilities are required, the construction of these facilities would also have minimal effects on the environment with compliance with existing regulations and policies and proposed General Plan policies under Alternative 3. Therefore, the impact with respect to public facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 3 compared to the Project.

Recreation
Deterioration of Existing Recreational Facilities
As discussed in Section 4.15, Recreation, of this Draft PEIR, although the City is currently not meeting the park service ratio standard, the General Plan Update includes policies that 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.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

As is the case for the Project, the General Plan Update under Alternative 3 includes policies that 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, Alternative 3 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. Therefore, the impact with respect to substantial deterioration of existing recreational facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 3 compared to the Project.

For these reasons, this impact would be less than significant.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-86 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
As is the case for the Project, Alternative 3 encourages the development of future recreational facilities in order to meet demand associated with anticipated population growth under the General Plan Update. As is the case for the Project, 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 recreational facilities would be consistent with the proposed land use designations and policies and would be subject to additional environmental review under CEQA, as needed. Therefore, the impact with respect to construction or expansion of recreational facilities would remain less than significant, similar to the Project, although the severity of this impact would be less, as there would be less growth and less demand for these facilities under Alternative 3 compared to the Project.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. For the same reasons as the Project, Alternative 3 would not conflict with a program, plan, ordinance, or policy addressing the circulation system, including transit, roadway bicycle and pedestrian facilities due to the availability of non-vehicular transportation options for the community. As is the case for the Project, Alternative 3 would include the same policies included in the General Plan that would balance the multimodal transportation network by providing alternatives to the automobile, improving transit service connections, and encouraging the use of alternative modes of transportation. Therefore, the impact with respect to conflict with adopted circulation program, plan, ordinance, or policy would remain less than significant, similar to the Project.

Although policies promoting a reduction of VMT per capita are included in the General Plan Update, no feasible mitigation is available to reach the 15 percent or more reduction threshold.

As a result, this impact would be significant and unavoidable.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-87 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
As less growth would occur under Alternative 3 compared to the Project, less traffic would be generated along streets in the Planning Area, and thus less VMT would be generated under the existing General Plan. However, this reduction in VMT under Alternative 3 would not likely be enough to achieve a 15 percent or more reduction compared to the baseline. As a result, this impact would remain significant and unavoidable, similar to the Project, although the severity of this impact would be less as less traffic would be generated under Alternative 3 compared to the Project.

Future development under Alternative 3 would also be designed in compliance with the City’s standards for safety and would provide adequate sight distance. As a result, the impact with respect to design hazards would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Future development under Alternative 3 would also not result in inadequate emergency access for the same reason as the Project. Therefore, the impact with respect to emergency access would remain less than significant, similar to the Project, and the severity of this impact would be similar.

Tribal Cultural Resources
No tribal cultural resources have been identified within or adjacent to the Planning Area.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-88 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
policies would ensure that the Project’s impact with respect to tribal cultural resources would be less than significant.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

Development allowed under Alternative 3 could also require or result in the relocation or construction of new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities, and should upgrades to new facilities be required, the construction of those facilities could result in adverse environmental effects, which are considered throughout the technical sections of this Draft PEIR. In addition, future facilities

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-89 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
would be required to comply with the City’s requirements for construction projects, including but not limited to, grading permits and encroachment permits. As a result, this impact would be less than significant. For these reasons, the impact with respect to new or expanded water, stormwater drainage, electric power, natural gas, and telecommunications facilities under Alternative 3 would remain less than significant, similar to the Project.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

While Alternative 3 would result 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project, Alternative 3 could result in growth above GSWC’s and LADWP’s water supply projections in their respective 2020 UWMPs. As with the Project, the General Plan Update under Alternative 3 includes policies and actions that would reduce water demand of future development. Furthermore, compliance with current CALGreen requirements would ensure that future development allowed under Alternative 3 would establish water conservation features. Although future development under Alternative 3 would be required to comply with CCMC Chapter 5.03, the City’s Water Conservation Plan, and policies in the General Plan Update aimed at reducing demand over time, sufficient water supply for Alternative 3 is not documented to be available at this time. No additional mitigation measures beyond these actions would be feasible. Thus, the water supply impact for Alternative 3 is considered significant and unavoidable, similar to the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-90 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Wastewater Service Capacity
The wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to future growth anticipated under the General Plan Update. In addition, policies in the proposed General Plan Update aim to conserve water by curbing demand for domestic and commercial purposes and promoting water conservation strategies, thus reducing demand for water, and in turn, the generation of wastewater. For these reasons, this impact would be less than significant.

As is the case for the Project, Alternative 3 would not result in a determination by the wastewater treatment provider which serves or may serve the project that it has inadequate capacity to serve the project’s projected demand in addition to the provider’s existing commitments, as the wastewater treatment plant serving the Planning Area has sufficient remaining capacity to treat the full increase in sewage attributable to future growth anticipated under Alternative 3. In addition, policies in the proposed General Plan Update that would also be included under Alternative 3 aim to conserve water by curbing demand for domestic and commercial purposes and promoting water conservation strategies, thus reducing demand for water, and in turn, the generation of wastewater. As a result, the impact with respect to wastewater service capacity under Alternative 3 would remain less than significant, similar to the Project.

As is the case for the Project, Alternative 3 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, as the landfills that currently serve the city have adequate capacity to dispose of the full increase in solid waste attributable to future growth anticipated under Alternative 3. In addition, compliance with existing solid waste regulations and policies in the proposed General Plan Update that would also be included under Alternative 3 would further address potential impacts. As a result, the impact with respect to solid waste under Alternative 3 would remain less than significant, similar to the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-91 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Development allowed under Alternative 3 would also comply with federal, state, and local management and reduction statutes and regulations related to solid waste. As a result, the impact with respect to solid waste regulations would remain less than significant, similar to the Project.

The overall land use pattern under Alternative 3 would be similar to that for the Project.

Exacerbate Wildfire Risks
While the majority of the Planning Area is not within a VHFHSZ, CAL FIRE classifies the eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods as a VHFHSZ. Currently, portions of the Culver Crest and Blair Hills neighborhoods that are within the VHFHSZ contain residential development. Development associated with the Project 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. In addition, smoke from wildfires occurring in Los Angeles County and across the state has resulted in poor air quality within Culver City. 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. Compliance with the applicable requirements of the CBC, the CFC, the CCMC, the policies of the General Plan Update, and site- specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-92 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
As development allowed under Alternative 3 would also occur within the Planning Area Alternative 3 could also exacerbate wildfire risks as identified for the Project. As with the Project, required compliance with the applicable requirements of the CBC, the CFC, the CCMC, and site-specific recommendations identified prior to project approvals would ensure impacts related to exacerbating wildfire risks would be less than significant. Therefore, the impacts related to exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project.

As is the case for the Project, development of new or expanded infrastructure under Alternative 3 would also be subject to 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. Therefore, the impacts related to exacerbating wildfire risks would be reduced to a less-than-significant level, similar to the Project.

As is the case for the Project, development allowed under Alternative 3 would also be subject to the applicable regulations and requirements of the CCMC and applicable regulations regarding

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-93 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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 development allowed under Alternative 3 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 related to exposure of people or structures to significant wildfire risks would be reduced to a less-than-significant level, similar to the Project.

Relationship of the Alternative to the Project Objectives As discussed above in Section 5.5.3, Alternative 3 – the Modified Mixed Use High Designation Alternative, the overall land use pattern under Alternative 3 would be similar to that for the Project. As is the case for the Project, Alternative 3 would accommodate growth through infill development and redevelopment with growth occurring along corridors. As is the case for the Project, Alternative 3 would incorporate mixed-use development on opportunity sites and in the industrial areas. However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. In addition, with the reduction of residences there would be a reduction in the amount of incidental commercial floor area, thereby resulting in the reduction of approximately 210 jobs compared with the Project. Alternative 3 would achieve all of the objectives for the Project. However, Alternative 3 would not meet future needs based on the projected population and job growth to the same degree as the Project.

5.6 Environmentally Superior Alternative
CEQA Guidelines Section 15126.6(e)(2) indicates that an analysis of alternatives to a proposed project shall identify an environmentally superior alternative among the alternatives evaluated in an EIR and that if the “no project” alternative is the environmentally superior alternative, the EIR shall identify another environmentally superior alternative among the remaining alternatives. Selection of an environmentally superior alternative is based on comparison of the alternatives to determine which among the alternatives would reduce or eliminate the impacts associated with the Project to the greatest degree. A comparative summary of the environmental impacts of the Project and of the alternatives is provided in Table 5-2, Comparison of the Impacts of the Project and Alternatives.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-94 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
TABLE 5-2

COMPARISON OF THE IMPACTS OF THE PROJECT AND ALTERNATIVES Impact Project
Alternative 1:

No Project
Alternative
Alternative 2:

Concentrated
Growth Alternative
Alternative 3:

Modified Mixed Use
High Designation
Aesthetics
AES-1: Substantial adverse effect on a scenic vista Less than Significant Less than Significant (Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
AES-2: Conflict with applicable zoning and other regulations governing scenic quality
Less than Significant Less than Significant
(Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
AES-3: Substantial light or glare Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
Air Quality
AIR-1: Conflict with air quality management plan Significant and Unavoidable
Less than Significant
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
AIR-2: Cumulatively considerable increase of criteria pollutant in nonattainment area during construction and operation
Significant and
Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
AIR-3: Exposure of sensitive receptors to substantial pollutant concentrations during construction and operation
Significant and
Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Biological Resources
BIO-1: Candidate, sensitive, or special status species Less than Significant with Mitigation
Less than Significant
(Similar)
Less than Significant
with Mitigation
(Similar)
Less than Significant
with Mitigation
(Similar)
BIO-2: Riparian habitat or sensitive natural habitat No Impact No Impact No Impact No Impact BIO-3: State or federally protected wetlands Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
BIO-4: Wildlife corridors or wildlife nursery sites Less than Significant with Mitigation
Less than Significant
(Similar)
Less than Significant
with Mitigation
(Similar)
Less than Significant
with Mitigation
(Similar)
BIO-5- Tree preservation policy or ordinance Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-95 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Project
Alternative 1:

No Project
Alternative
Alternative 2:

Concentrated
Growth Alternative
Alternative 3:

Modified Mixed Use
High Designation
Cultural Resources
CUL-1: Historical resources Significant and
Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Similar)
Significant and
Unavoidable
(Similar)
CUL-2: Archaeological resources Less than Significant
with Mitigation
Less than Significant
(Similar)
Less than Significant
with Mitigation
(Similar)
Less than Significant
with Mitigation
(Similar)
Energy
ENG-1a: Cause wasteful, inefficient, or unnecessary consumption of energy during construction
Less than Significant Less than Significant
(Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
ENG-1b: Cause wasteful, inefficient, or unnecessary consumption of energy during operation
Less than Significant Less than Significant
(Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
ENG-2: Conflict with or obstruct a state or local plan for renewable energy or energy efficiency
Less than Significant Less than Significant
(Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
Geology and Soils
GEO-1: Geologic hazards Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
GEO-2: Soil erosion or loss of topsoil Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
GEO-3: Unstable soils Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
GEO-4: Expansive soils Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
GEO-5: Paleontological resources Less than Significant
with Mitigation
Less than Significant
(Similar)
Less than Significant
with Mitigation
(Similar)
Less than Significant
with Mitigation
(Similar)
Greenhouse Gas Emissions
GHG-1: Generate emissions Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
GHG-2: Conflict with applicable plans Less than Significant Less than Significant (Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
Hazards and Hazardous Materials
HAZ-1: Routine transport, use, or disposal of hazardous materials Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-96 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Project
Alternative 1:

No Project
Alternative
Alternative 2:

Concentrated
Growth Alternative
Alternative 3:

Modified Mixed Use
High Designation
HAZ-2: Accidental release of hazardous materials into the environment Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HAZ-3: Emit hazards within on-quarter miles of an existing or proposed school
Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HAZ-4: Hazardous materials sites Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HAZ-5: Adopted emergency response plan Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HAZ-5: Wildland fire hazards Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Hydrology and Water Quality
HYD-1: Violate water quality standards or waste discharge requirements Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HYD-2: Groundwater supplies and groundwater recharge Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HYD-3: Substantially alter existing drainage pattern Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HYD-4: Release of pollutant from inundation by flood, tsunami, or seiche Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
HYD-5: Conflict with a water quality control plan or sustainable groundwater management plan
Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Land Use and Planning
LU-1: Physically divide a community Less than Significant Less than Significant (Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
LU-2: Consistency with applicable land use plans Less than Significant Less than Significant (Greater)
Less than Significant
(Similar)
Less than Significant
(Similar)
Minerals
MIN-1 and MIN-2: Known mineral resource, locally important mineral resource recovery site
Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Noise
NOI-1: Temporary or permanent increase in ambient noise levels during construction and operation
Significant and
Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-97 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Project
Alternative 1:

No Project
Alternative
Alternative 2:

Concentrated
Growth Alternative
Alternative 3:

Modified Mixed Use
High Designation
NOI-2a: Excessive groundborne vibration or groundborne noise during construction
Significant and
Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
NOI-2b: Excessive groundborne vibration or groundborne noise during operation
Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Population and Housing
POP-1: Induce unplanned population growth Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
POP-2: Require construction of new housing Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
Public Services
PS-1i: Fire protection Less than Significant Less than Significant (Less)
Less than Significant
(Less)
Less than Significant
(Less)
PS-1ii: Police protection Less than Significant Less than Significant (Less)
Less than Significant
(Less)
Less than Significant
(Less)
PS-1iii: Schools Less than Significant Less than Significant (Less)
Less than Significant
(Less)
Less than Significant
(Less)
PS-1iv: Other public facilities Less than Significant Less than Significant (Less)
Less than Significant
(Less)
Less than Significant
(Less)
Recreation
REC-1: Deterioration of existing recreational facilities Less than Significant Significant and Unavoidable
(Greater)
Less than Significant
(Less)
Less than Significant
(Less)
REC-2: Construction or expansion of recreational facilities Less than Significant Less than Significant (Less)
Less than Significant
(Less)
Less than Significant
(Less)
Transportation
TR-1: Conflict with plan, ordinance, or policy addressing circulation system, including transit, roadway, bicycle, and pedestrian facilities Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
TR-2: Conflict or be inconsistent with CEQA Guidelines Section 15064.3 Significant and Unavoidable
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
Significant and
Unavoidable
(Less)
TR-3: Increase hazards due to a geometric design feature or incompatible uses
Less than Significant Less than Significant
(Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-98 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Impact Project
Alternative 1:

No Project
Alternative
Alternative 2:

Concentrated
Growth Alternative
Alternative 3:

Modified Mixed Use
High Designation
TR-4: Inadequate emergency access Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Tribal Cultural Resources
TCR-1: Change in the significance of a tribal cultural resource Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
Utilities and Service Systems
UTL-1: New or expanded utility infrastructure Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
UTL-2: Water supplies Significant and
Unavoidable
Less than Significant
(Less)
Significant and
Unavoidable
(Similar)
Significant and
Unavoidable
(Similar)
UTL-3: Wastewater treatment Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
UTL-4: Solid waste Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
UTL-5: Solid waste regulations Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
Wildfire
WF-1: Emergency response or evacuation plans Less than Significant Less than Significant (Similar)
Less than Significant
(Similar)
Less than Significant
(Similar)
WF-2: Exacerbate wildfire risks Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
WF-3: Infrastructure which could exacerbate fire risk Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
WF-4: Expose people or structures to significant risks Less than Significant Less than Significant (Less)
Less than Significant
(Similar)
Less than Significant
(Similar)
SOURCE: ESA, 2024.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-99 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Alternative 1, the No Project Alternative, would be the continuation of growth in the city guided by the City’s adopted 1996 General Plan and the current Zoning Code. Alternative 1 would, in comparison to the Project, result in reduced environmental impacts related to air quality, biological resources, historic resources, GHG (emissions), noise, public services, recreation (construction or expansion of recreational facilities), transportation, utilities and service systems, and wildfire, but would result in greater impacts with respect to aesthetics, energy, GHG (conflict with applicable plans), land use and planning, and recreation (deterioration of existing recreational facilities). Alternative 1 would not meet most of the Project objectives and would not meet the underlying purpose of the Project.

Alternative 2, the Concentrated Growth Alternative, would be similar to the Project but would result in greater amounts of mixed-use development throughout the city on corridors compared to the Project. Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. Therefore, under Alternative 2, the goals, policies, and implementation actions contained within the proposed General Plan elements would be applicable. Alternative 2 also includes all of the mobility improvements as proposed for the Project throughout the planning horizon of 2045. As with the Project, a Zoning Code Update for Alternative 2 would provide the development standards to implement the General Plan Update. Alternative 2 would result in 2,870 fewer residents compared to the Project, 1,110 fewer housing units, and 1,100 fewer jobs than the Project. Alternative 2 would, in comparison to the Project, result in reduced environmental impacts related to air quality, noise, public services, recreation, transportation, and utilities and service systems, primarily as a result of its reduction of growth in comparison to the Project.

Alternative 2 would achieve all of the objectives for the Project. However, Alternative 2 would not meet future needs based on the projected population and job growth to the same degree as the Project.

Alternative 3, the Modified Mixed Use High Designation Alternative, would be similar to the Project but would result in a reduction of residential units and commercial uses in the areas designated as Mixed Use High compared with the Project. Under this alternative, all of the proposed elements of the General Plan Update, except the proposed Land Use Element, would remain the same as under the Project. The overall land use pattern under Alternative 3 would be similar to that for the Project. As with the Project, Alternative 3 would accommodate growth through infill development and redevelopment with growth occurring along corridors.

Alternative 3 would incorporate mixed-use development on opportunity sites and in the industrial areas. However, Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum FAR would decrease from 4.0 to 3.5. Alternative 3 would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project. Alternative 3 would, in comparison to the Project, result in reduced environmental impacts related to air quality, noise, public services, recreation, transportation, and utilities and service systems, primarily as a result of its reduction of growth in comparison to the Project. Alternative 3 would achieve all of the objectives for the Project. However, Alternative 3 would not meet future needs based on the projected population and job growth to the same degree as the Project.

5. Alternatives
General Plan 2045 and Zoning Code Update Project 5-100 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Alternative 2, the Concentrated Growth Alternative, is considered the environmentally superior alternative, as it would reduce the magnitude of overall impacts compared to the Project to a greater extent than Alternative 3, as it would result in less development and associated physical impacts. However, as noted above, Alternative 2 would not meet future needs based on the projected population and job growth to the same degree as the Project.

General Plan 2045 and Zoning Code Update Project 6-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CHAPTER 6
Other CEQA Considerations
This chapter addresses environmental topics required by the California Environmental Quality Act (CEQA) that are not covered within the other chapters of this Draft Program Environmental Impact Report (Draft PEIR), including: significant unavoidable impacts; irreversible environmental changes; growth inducing impacts; potential secondary effects related to Project mitigation measures; and environmental effects found not to be significant. In addition, reasons for implementation of the Project, notwithstanding potentially significant unavoidable impacts identified, are addressed in this chapter.

6.1 Significant and Unavoidable Impacts
CEQA Guidelines Section 15126.2(a) requires that an EIR describe significant environmental impacts that cannot be avoided, including those effects that can be mitigated but not reduced to a less-than-significant level. As indicated in Chapter 4, Environmental Impact Analysis, of this Draft PEIR, the Project would result in the following significant unavoidable impacts.

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

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

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

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

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

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

The Project would result in a potentially significant impact, as vibration generated during the construction of future development projects could exceed the significance thresholds. While implementation of mitigation would reduce the severity of vibration during construction, the impact during this phase would remain significant and unavoidable.

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

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

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

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

6.2 Reason s the Project is Being Proposed
Notwithstanding its Significant Unavoidable
Impacts
In addition to identification of the Project’s significant unavoidable impacts, Section 15126.2(c) of the State CEQA Guidelines requires a description of the reasons why a Project is being proposed, notwithstanding significant unavoidable impacts associated with the Project. The reasons why the Project has been proposed are grounded in the underlying purpose of the Project. As discussed in Chapter 2, Project Description, of this Program EIR, the underlying purpose of the Project is to comprehensively update the General Plan to establish a long-range vision that reflects the unique needs of the City and provides clear direction to improve the quality of life for residents, businesses, and visitors. Thus, the General Plan Update establishes the long- range vision for the City and provides the goals and policies, which are steps to achieve the vision. The intent of the General Plan Update is to guide the physical growth of the city over the next two decades through the stated goals and policies, which are implemented by the Zoning Code Update.

As discussed above, the Project would result in significant and unavoidable impacts with respect to air quality, cultural resources, noise, transportation, and water supply. However, notwithstanding these significant and unavoidable environmental impacts, the Project is proposed so that the city has a comprehensive General Plan consisting of 13 elements that each focus on particular issues and provide strategies for sustainable future growth. The General Plan Update would guide the evolution of the land use pattern to accommodate growth through thoughtful infill development and redevelopment. For example, the Project provides the roadmap for the city to increase the housing supply and mix of housing types in an equitable manner. In addition, the Project would foster harmony between people and the environment through continued sustainability efforts in compliance with state requirements. The Project would achieve the following benefits:
• Establish a long-range vision that reflects the aspirations of the community and outlines steps to achieve this vision through its policies;
• Guide decision-making related to development, housing, transportation, environmental quality, public services, parks, open space, and environmental justice; • Help the City achieve compliance with applicable state and regional policies, including housing production and environmental regulations;
• Allow City departments, other public agencies, and private developers to design projects that will enhance the character of the community, preserve environmental resources, and minimize hazards; and
• Provide the basis for establishing and setting priorities for detailed plans and implementing programs, such as the zoning ordinance and future specific plans.

6. Other CEQA Considerations
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6.3 Growth- Inducing Impacts
CEQA Guidelines Section 15126.2( e) requires a discussion of a proposed project’s potential to foster economic or population growth, or the construction of additional housing, either directly or indirectly, in the surrounding environment. This includes consideration of projects that would remove obstacles to population growth. Growth does not necessarily create significant physical changes to the environment. However, depending upon the type, magnitude, and location of growth, it can result in significant adverse environmental effects. Under CEQA, growth is not to be considered necessarily detrimental, beneficial, or of significant consequence. Induced growth is considered a significant impact only if it can be demonstrated that the potential growth, in some other way, significantly affects the environment. In general, a project may foster physical, economic, or population growth in a geographic area if it meets any one of the criteria identified below:
• The project results in the urbanization of land in a remote location (leapfrog development); • The project removes an impediment to growth (e.g., the establishment of an essential public service, or the provision of new access to an area);
• The project establishes a precedent-setting action that could lead to physical adverse changes in the environment (e.g., a change in zoning or general plan amendment approval); • Economic expansion or growth occurs in an area in response to the project (e.g., changes in revenue base, employment expansion, etc.).

If a project meets any one of these criteria, it may be considered growth inducing. Generally, growth-inducing projects are either located in isolated, undeveloped, or underdeveloped areas, necessitating the extension of major infrastructure, such as sewer and water facilities or roadways, or encourage premature or unplanned growth.

6.3.1 Population and Housing Growth
As discussed in Section 4.13, Population and Housing, of this Program EIR, Culver City’s 2020 population was estimated to be 40,800 people. As part of the General Plan Update process, the City projects its 2045 population to be 62,400, which translates to a an approximately 53 percent increase in growth over the next 25 years. Section 4.13 further states that 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. It should be noted that the General Plan Update is accommodating continued growth anticipated in the Planning Area and is not inducing growth.

As the potential growth in the city under the Project consists of infill development and new mixed-use opportunities in activity centers and along commercial corridors, the General Plan Update would not result in urbanization of land in remote locations. Development allowed under the Project would focus on redevelopment and revitalization of areas already served by infrastructure and would not require extensions of utilities, roads, or other infrastructure. As no new major roads or highways have been proposed to provide new access to the city, the

6. Other CEQA Considerations
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General Plan Update would not remove an impediment to growth. Instead, proposed development allowed under the Project would accommodate growth that will occur in the Southern California region, as anticipated by SCAG projections for the city in the next 25 years.

Therefore, the General Plan Update would not be growth inducing or set new precedent for growth but would involve development in anticipation of expected growth in the city.

6.3.2 R emoval of Obstacles to Population Growth
The Project encourages the reuse and intensification of previously developed areas of the city rather than the extension of urban development into undeveloped areas of the city.

Development under the Project would occur for areas of the city that are developed and are served by an extensive network of roadways, electricity, water, sewer, storm drain and other infrastructure sized to accommodate or allow for existing and planned growth. Only minor connections would be needed to accommodate new development allowed under the Project.

Since no new major roads or highways would be implemented to provide new access to the city, the General Plan Update would not facilitate development in any undeveloped areas where development could not already occur under existing City plans or ordinances. Instead, the Project focuses on infill development and mixed-use opportunities to provide higher density housing near transit, jobs, neighborhood amenities, and health care facilities. Therefore, the General Plan Update would not result in the removal of obstacles to growth that would result in growth-inducing development.

6.3.3 Employment Growth
Implementation of the Project would generate short-term employment opportunities during construction activities associated with future development. The General Plan Update would not be considered growth inducing as future development allowed under the Project would draw from the existing supply of construction workers in the Southern California workforce.

Implementation of the Project would contribute to permanent employment opportunities at commercial and industrial developments created along corridors and other large opportunity sites within the city. Potential full-time and part-time positions are anticipated to be filled by the local labor force. The jobs associated with the future proposed development could attract new residents to the city; however, Culver City has an existing employment base from which to pull employees. Furthermore, the economic expansion that would occur associated with future development is accounted for in the General Plan Update and is anticipated by the City.

Therefore, impacts related to employment growth are not considered growth inducing.

6.3.4 Precedent -Setting Policies
The purpose of the Project is to preserve and enhance the character of Culver City and to establish long-range development policies that will guide future decision-making. Therefore, by its nature, the General Plan Update is designed to reduce the potential for uncontrolled growth and associated environmental impacts.

6. Other CEQA Considerations
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As described throughout this section, the anticipated growth under the Project would primarily consist of infill development and new mixed-use opportunities in activity centers and along commercial corridors within the city and would not result in the urbanization of land in remote locations. New development in the city would serve to accommodate imminent future growth in the Southern California region, as captured by SCAG projections for the city in the next 25 years.

A general plan and zoning code are regulatory documents that plan for future growth and guide development. As such, the General Plan Update and Zoning Code Update would accommodate future growth and would reduce the potential for uncontrolled growth. Future, unanticipated actions, such as General plan amendments or changes to the zoning of individual properties, are in direct contrast to the General Plan Update process. Therefore, by accommodating growth that is already projected by SCAG, the Project would not be growth inducing or precedent setting.

6.4 Significant Irreversible Environmental Changes
According to Sections 15126(c) and 15126.2(d) of the State CEQA Guidelines, an EIR is required to address any significant irreversible environmental changes that would occur should the proposed project be implemented. As stated in CEQA Guidelines Section 15126.2(d) indicates:

Uses of nonrenewable resources during the initial and continued phases of the project may be irreversible since a large commitment of such resources makes removal or nonuse thereafter likely. Primary impacts and, particularly, secondary impacts (such as highway improvement which provides access to a previously inaccessible area) generally commit future generations to similar uses. Also, irreversible damage can result from environmental accidents associated with the project. Irretrievable commitments of resources should be evaluated to assure that such current consumption is justified.

The Project would allow for future development that would necessarily consume limited, slowly renewable and non-renewable resources. This consumption would occur during the construction phase of individual projects allowed under the Project and would continue throughout their operational lifetime. Development of individual projects allowed under the Project would require a commitment of resources that would include: (1) building materials, (2) fuel and operational materials/resources, and (3) the transportation of goods and people to and from the project sites. Construction of individual projects would require the consumption of resources that are non-replenishable or may renew so slowly as to be considered non- renewable. These resources would include the following construction supplies: certain types of lumber and other forest products; aggregate materials used in concrete and asphalt such as sand, gravel, and stone; metals such as steel, copper, and lead; petrochemical construction materials such as plastics; and water. Furthermore, nonrenewable fossil fuels such as gasoline and oil would also be consumed in the use of construction vehicles and equipment, as well as the transportation of goods and people to and from the project sites.

Ongoing operation of individual projects allowed under the Project would entail a further commitment of energy resources in the form of petroleum products, natural gas, electricity, and water. Long-term impacts would also result from an increase in vehicular traffic, and the associated air pollutant and noise emissions. This commitment of resources would be a long-

6. Other CEQA Considerations
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term obligation in view of the fact that, practically speaking, it would not be possible to return developed land to its original condition.

6.5 Potential Secondary Effects Related to Project
Mitigation Measures
CEQA Guidelines Section 15126.4(a)(1)(D) requires that if a mitigation measure proposed to address the significant effects of the Project would cause one or more significant effects in addition to those caused by the Project, the effects of the mitigation measure shall be discussed but, in less detail, than the significant effects of the Project. Accordingly, the mitigation measures proposed to address significant Project impacts were evaluated to determine if significant secondary impacts associated with their implementation would occur. The following provides a discussion of the subject areas in which mitigation measures are required, as well as any potential secondary significant effects that could occur as a result of their implementation.

For the reasons stated below, implementation of the Project mitigation measures would not result in significant secondary impacts.

6.5.1 Air Quality
Mitigation Measures AQ-1 and AQ-2 require that construction contractors use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off-Road New Diesel Engine Emission Standards and South Coast Air Quality Management District (SCAQMD) Low-VOC and/or Super-Compliant VOC architectural coatings and industrial maintenance coatings if future projects exceed SCAQMD significance thresholds during construction for emissions of NOX, CO, PM10, PM2.5 and/or Volatile Organic Compounds (VOCs).

For future projects that exceed SCAQMD significance thresholds during operation, Mitigation Measures AQ-3 through AQ-5 require that these projects to provide and/or install Energy Star– certified appliances or appliances of equivalent energy efficiency, electrical vehicle charging stations, and preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles.

These mitigation measures for air quality would implement emissions control strategies during construction and operation that would reduce impacts, and no further impacts would occur with their implementation. Therefore, these mitigation measures would not result in significant secondary impacts on the environment.

6.5.2 Biological Resources
Mitigation BIO-1 would require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area to determine any direct, indirect, and cumulative biological impacts from construction and operations, as well as specific mitigation or avoidance measures necessary to offset significant impacts associated with future projects.

6. Other CEQA Considerations
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For projects that are constructed during the nesting season, Mitigation BIO-2 would require that a nesting bird and raptor survey be conducted within a 500-foot radius of a construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any vegetation removal, and if nesting raptors and migratory songbirds are identified, the following minimum no disturbance buffers be implemented: 100 feet around active passerine (perching birds and songbirds) nests, 300 feet around active raptor nests.

These mitigation measures for biological resources would implement protection strategies during construction that would reduce impacts, and no further impacts would occur with their implementation. As a result, these mitigation measures would not result in significant secondary impacts on the environment.

6.5.3 Cultural Resources
Mitigation Measure CUL-1 requires that an historic resources assessment be conducted prior to development of any project within areas that contain properties more than 45 years old, and if any projects have the potential to result in direct and/or indirect effects on those resources, that recommendations in the assessment be followed to protect the significance of these resources.

Mitigation Measure CUL-2 requires that an archaeological resources assessment be conducted prior to development of any project that involves ground disturbance, and if resources are identified during the assessment, then their boundaries shall be determined, and they shall be evaluated for eligibility in the California Register and local register. If a resource is determined to be eligible and the project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts to that resource.

The activities involved with assessing and protecting historic and archaeological resources would not require additional ground disturbance or cause changes in the physical environment.

Therefore, these mitigation measures would not result in significant secondary impacts on the environment.

6.5.4 Geology and Soils – Paleontological Resources
Mitigation Measure GEO-1 requires that a paleontological resources assessment be conducted prior to development of any project that involves ground disturbance, and if resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for significance pursuant to CEQA, Society of Vertebrate Paleontology, and/or a local register. If a resource is determined to be significant and the project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the project to that resource. The mitigation measure would ensure that paleontological resources would be treated consistent with CEQA Guidelines and regulatory provisions for the protection of these resources. Similar to the mitigation of historical and archaeological resources described above, the activities involved with assessing and protecting paleontological resources would not require additional ground disturbance or cause changes in the physical environment that would result in secondary impacts on the environment.

6. Other CEQA Considerations
General Plan 2045 and Zoning Code Update Project 6-9 SCH No. 2022030144 City of Culver City March 2024
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6.5.5 Noise
Implementation of Mitigation Measure NOI-1 would require applicants for new development projects that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) to prepare and submit a noise study that would include noise-reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards while implementation of Mitigation Measure NOI-4.12-2 would require applicants for new development projects located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) to prepare and submit a vibration impact evaluation that would include project-specific measures, if necessary, to ensure project compliance with vibration standards. Measures to reduce noise and vibration would likely involve control strategies for construction equipment that the Applicant would use or install, thus no further impacts would occur with this implementation. Therefore, these mitigation measures for construction noise would not result in secondary impacts on the environment.

6.6 Effects Found Not to Be Significant
CEQA Guidelines Section 15128 states that an EIR shall contain a brief statement indicating reasons that various possible significant effects of a Project were determined not to be significant and were not discussed in detail in the Draft EIR. This section discusses those issue areas that were determined not to require further analysis in this Draft PEIR. For further discussion of these issues and more detailed evaluation of potential impacts found not to be significant refer to the Initial Study provided in Appendix A of this Draft PEIR. 1 6.6.1 Aesthetics
a) Would the project substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway? The Planning Area does not have any City- or State-designated scenic highways. As such, development allowed under the General Plan Update would not damage scenic resources located within the viewshed of a state scenic highway. No Project-specific and cumulative impacts would occur.

1 The Initial Study that was prepared focused on the General Plan Update. With the inclusion of the Zoning Code Update as part of the Project to maintain compliance with the recently adopted housing element and to comply with state law, the City issued a Recirculated NOP. Since the Zoning Code Update is the mechanism to implement the General Plan Update, the Zoning Code Update is consistent with the density and intensity of development that would occur under the General Plan Update. The Zoning Code Update is evaluated in each section of the Draft PEIR; the inclusion of the Zoning Code Update as part of the Project does not alter the conclusions in the Initial Study.

6. Other CEQA Considerations
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6.6.2 Agricultural and Forest Resources
a) Would the project convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance (Farmland), as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program of the California Resources Agency, to non-agricultural use? The majority of the Planning Area is highly urbanized. The Planning Area does not contain agricultural uses or related operations and no areas are designated Prime Farmland, Unique Farmland, or Farmland of Statewide Importance as shown on the maps prepared pursuant to the Farmland Mapping and Monitoring Program. Furthermore, the Project does not identify any areas within the Planning Area as designated for agriculture use. Therefore, the Project would not convert Prime Farmland, Unique Farmland, or Farmland of Statewide Importance to non- agricultural uses and no impacts would occur.
b) Would the project conflict with existing zoning for agricultural use, or a Williamson Act contract?
No portion of the Planning Area is zoned for agriculture and no parcels within the Planning Area are enrolled under a Williamson Act contract. As such, the Project would not conflict with existing zoning for agricultural use or a Williamson Act contract and no impacts would occur. c) Would the project conflict with existing zoning for, or cause rezoning of, forestland (as defined in Public Resources Code Section 12220(g)), timberland (as defined by Public Resources Code Section 4526), or timberland zoned Timberland Production (as defined by Government Code Section 51104(g))?
As discussed above, the majority of the Planning Area is highly urbanized. No forest land or timberland zoning is present within the Planning Area. As such, the Project would not conflict with existing zoning for forest land or timberland and no impacts would occur. d) Would the project result in the loss of forestland or conversion of forestland to non-forest uses?
No forest land exists within the Planning Area. As such, the Project would not result in the loss of forest land or conversion of forest land to non-forest use and no impacts would occur. e) Would the project involve other changes in the existing environment which, due to their location or nature, could result in conversion of Farmland to non-agricultural use or conversion of forestland to non-forest use?
No agricultural uses or forestlands exist within the Planning Area. As such, the General Plan Update would not involve converting farmland to other uses, either directly or indirectly and no impacts would occur.

6. Other CEQA Considerations
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6.6.3 Air Quality
a) Would the project result in other emissions (such as those leading to odors) adversely affecting a substantial number of people?
Potential sources that may emit odors during construction activities include the use of architectural coatings and solvents. SCAQMD Rule 1113 (Architectural Coatings) limits the amount of volatile organic compounds from architectural coatings and solvents. According to the SCAQMD CEQA Air Quality Handbook, construction equipment is not a typical source of odors. Complying with the CARB Air Toxics Control Measure (ATCM) would minimize odors from the combustion of diesel fuel. The ATCM was adopted in 2004 and limits diesel-fueled commercial vehicle idling to five minutes at any given location. Development allowed under the GPU would also comply with SCAQMD Rule 402 (Nuisance), which prohibits the emissions of nuisance air contaminants or odorous compounds. Construction activities and materials adhering with mandatory SCAQMD Rules and State measures would not result in other emissions that create objectionable odors. Accordingly, development occurring under the GPU is not expected to generate emissions leading to nuisance odors that would adversely affect nearby sensitive receptors.

According to the SCAQMD CEQA Air Quality Handbook, land uses associated with odor complaints typically include agricultural uses, wastewater treatment plants, food processing plants, chemical plants, composting, refineries, landfills, dairies, and fiberglass molding. While it is unknown whether development allowed under the GPU would involve the types of uses associated with odor complaints, the developments allowed under the GPU would include proper housekeeping practices for trash receptacles and other components or activities, thereby avoiding adverse odor impacts. Similar to construction, the developments allowed under the GPU would also adhere to SCAQMD Rule 402 (Nuisance), which prohibits the emissions of nuisance air contaminants or odorous compounds. Project-specific and cumulative impacts would be less than significant.

6.6.4 Biological Resources
a) Would the project conflict with the provisions of an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or state habitat conservation plan?
There are no adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other approved local, regional, or State habitat conservation plans in place for the Planning Area. No Project-specific and cumulative impacts would occur.

6.6.5 Cultural Resources
a) Would the project disturb any human remains, including those interred outside of formal cemeteries?
Development allowed under the Project may involve excavation into native soils, with the potential to encounter previously unknown human remains. Various regulatory provisions

6. Other CEQA Considerations
General Plan 2045 and Zoning Code Update Project 6-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
address how to handle human remains that could be inadvertently uncovered during excavation activities. These include State Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and State CEQA Guidelines Section 15064.5(e). Under these codes, if unrecorded human remains are discovered during construction within the Planning Area, excavation would be halted and the County Coroner would be notified. If the human remains are determined to be Native American, the California Native American Heritage Commission (NAHC) would be notified within 24 hours and the guidelines of the NAHC would be adhered to in the treatment and disposition of the remains. Compliance with these regulatory protocols would ensure that impacts on human remains would be less than significant. Project-specific and cumulative impacts would be less than significant.

6.6.6 Geology and Soils
a) Would the project have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water?
The Planning Area is served by municipal wastewater infrastructure. Development allowed under the Project would connect to existing mainlines and service lines, which are largely located in surrounding roadways. As such, future development would not use septic tanks or alternative wastewater disposal systems. No impacts would occur.

6.6.7 Hazards and Hazardous Materials
a) Would the project be located within an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the Project result in a safety hazard or excessive noise for people residing or working in the Project area? The Planning Area does not include an airport land use plan or a public airport. The nearest airports to the Planning Area are the Santa Monica Municipal Airport and the Los Angeles International Airport (LAX), located about three miles west and five miles southwest of the Planning Area, respectively. Therefore, the Planning Area is not located within an airport land use plan area and would not result in airport-related safety hazards or excessive noise for people residing or working in the Planning Area. No impacts would occur.

6.6.8 Noise
a) Would the project be located within the vicinity of a private air strip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, and expose people residing or working in the Project area to excessive noise levels?
The Planning Area does not include an airport land use plan or a public airport. The nearest airports to the Planning Area are the Santa Monica Municipal Airport and the Los Angeles International Airport (LAX), located about three miles west and five miles southwest of the Planning Area, respectively. Therefore, development facilitated by the Project would not expose people to excessive noise levels from such uses. No impacts would occur.

General Plan 2045 and Zoning Code Update Project 7-1 SCH No. 2022030144 City of Culver City March 2024
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CHAPTER 7
References
As part of the General Plan Update process, the City prepared 13 Existing Conditions Reports, which can be found on the City’s website at https://www.pictureculvercity.com/existing- conditions-reports. The Reports addressed different topics, including an Environmental Background Report; a Parks, Public Facilities, and Public Services; and Infrastructure. The Existing Conditions Reports provided baseline information and identified issues and opportunities, which were used to inform the preparation of the Draft General Plan Update.

Information contained in the Existing Conditions Reports was used in the preparation of the Program EIR.

In addition, the following provides the references that were used for each of the chapters and sections in the Program EIR.

Project Description
Culver City, Draft Mobility Element, Raimi + Associates, 2023. ———, existing land use data, 2019.

Raimi + Associates, Preferred Plan Growth Projections, November 2022.

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

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

Air Quality
California Air Resources Board, 2004. Final Regulation Order, Amendments to the California Diesel Fuel Regulations, Amend Section 2281, Title 13, California Code of Regulations. https://www.arb.ca.gov/regact/ulsd2003/fro2.pdf. Accessed January 2024. ———, 2005. Air Quality and Land Use Handbook: A Community Health Perspective. ———, 2016. Ambient Air Quality Standards (5/4/16), http://www.arb.ca.gov/research/aaqs/ aaqs2.pdf. Accessed January 2024.
———, 2023a. Ozone & Health, Health Effects of Ozone, https://ww2.arb.ca.gov/resources/ ozone-and-health. Accessed January 2024.

7. References
General Plan 2045 and Zoning Code Update Project 7-2 SCH No. 2022030144 City of Culver City March 2024
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———, 2023b. CARB Identified Toxic Air Contaminants. https://ww2.arb.ca.gov/resources/ documents/carb-identified-toxic-air-contaminants. Accessed January 2024. ———, 2023c. Nitrogen Dioxide & Health. https://ww2.arb.ca.gov/resources/nitrogen -dioxide- and-health. Accessed January 2024.
———, 2023d. Carbon Monoxide & Health. https://ww2.arb.ca.gov/resources/carbon - monoxide-and-health. Accessed January 2024.
———, 2023e. Sulfur Dioxide & Health. https://ww2.arb.ca.gov/resources/sulfur -dioxide-and- health. Accessed January 2024.
———, 2023f. Inhalable Particulate Matter and Health (PM2.5 and PM10). https://www.arb.ca.gov/research/aaqs/common-pollutants/pm/pm.htm. Accessed January 2024.
———, 2023g. Lead & Health. https://ww2.arb.ca.gov/resources/lead -and-health. Accessed January 2024.
———, 2023h. Omnibus Regulation. https://ww2.arb.ca.gov/our -work/programs/innovative- clean-transit/omnibus-regulation#:~:text=The%20Heavy%2DDuty%20Engine% 20and,from%20conventional%20heavy%2Dduty%20engines. Accessed January 2024.

California Air Resources Board 2023i, Area Designations Maps/State and National. https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area- designations. Accessed December 2023.

Culver City, 1995. Culver City General Plan, Circulation Element. ———. Municipal Code Chapter 15.02.1100, Green Building Program and Requirements.

Fehr & Peers, 2024 (VMT date).

Southern California Association of Governments (SCAG), 2020. Connect SoCal 2020, Demographics and Growth Forecast, September 2020.

South Coast Air Quality Management District (SCAQMD), 1993. CEQA Air Quality Handbook, April 1993.
———, 2003. White Paper on Potential Control Strategies to Address Cumulative Impacts from Air Pollution, Appendix D.
———, 2006, Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds.
———, 2008. Final Localized Significance Threshold Methodology, July 2008. ———, 2009, Appendix C - Mass Rate LST Look-up Table.
———, 2017. Final 2016 AQMP, March 2017, p. 2-38.
———, 2018. Guidance on Frequently Questioned Topics in Roadway Analysis for the California Environmental Quality Act, https://www.aqmd.gov/docs/default- source/ceqa/handbook/roadway-ceqa-guidance_v10.pdf. Accessed December 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-3 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2019, 2020, 2021, 2022. Historical Data by Year, https://www.aqmd.gov/home/air- quality/historical-air-quality-data/historical-data-by-year. Accessed January 2024. ———, 2021a. Final Report Multiple Air Toxics Exposure Study in the South Coast Air Basin MATES V.
———, 2021b. Rule 2305. Warehouse Indirect Source Rule.
———, 2022. 2022 Air Quality Management Plan , Appendix I-154, Adopted December 2 ———, 2023, Air Quality Significance Thresholds, revision March 2023. ———, n.d., Multiple Air Toxics Exposure Study, MATES V Data Visualization Tool, Cancer Risk. https://experience.arcgis.com/experience/79d3b6304912414bb21ebdde80100b23/ page/Main-Page/?views=Click-tabs-for-other-data%2CCancer-Risk., Accessed December 2023.

United States Environmental Protection Agency, 2023a. Health Effects of Ozone Pollution, https://www.epa.gov/ground-level-ozone-pollution/health-effects-ozone-pollution.

Accessed January 2024.
———, 2023b, The Green Book Nonattainment Areas for Criteria Pollutants, last updated on December 1, 2023. https://www.epa.gov/green-book. Accessed December 2023 ———, 2023b. Technical Overview of Volatile Organic Compounds. https://www.epa.gov/indoor-air-quality-iaq/technical-overview-volatile-organic- compounds. Accessed January 2024.
———, 2023c. Nitrogen Dioxide (NO2) Pollution. https://www.epa.gov/no2 -pollution/basic- information-about-no2. Accessed January 2024.
———, 2023d. Carbon Monoxide (CO) Pollution in Outdoor Air. https://www.epa.gov/co - pollution/basic-information-about-carbon-monoxide-co-outdoor-air-pollution. Accessed January 2024.
———, 2023e. Sulfur Dioxide (SO2) Pollution. https://www.epa.gov/so2 -pollution/sulfur- dioxide-basics#effects. Accessed January 2024.
———, 2023f. Particulate Matter (PM) Pollution, https://www.epa.gov/pm - pollution/particulate-matter-pm-basics. Accessed January 2024. ———, 2023g. Lead Air Pollution. https://www.epa.gov/lead -air-pollution/basic-information- about-lead-air-pollution. Accessed January 2024.
———, 2023. NAAQS Table, last updated on March 15, 2023. https://www.epa.gov/criteria -air- pollutants/naaqs-table. Accessed December 2023.

Biological Resources
California Department of Fish and Wildlife (CDFW), 2024. California Natural Diversity Database (CNDDB). http://www.dfg.ca.gov/biogeodata/cnddb/mapsanddata.asp. Accessed February 2024.

7. References
General Plan 2045 and Zoning Code Update Project 7-4 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023. California Sensitive Natural Community List, Vegetation Classification and Mapping Program. https://nrm.dfg.ca.gov/FileHandler.ashx?DocumentID=153609&inline.

Accessed November 2023.

California Native Plant Society, 2024. Inventory of Rare and Endangered Plants (online edition, v8-01a). California Native Plant Society. Sacramento, CA. http://www.rareplants.cnps.org/.

Accessed February 2024.

Longcore, T. (ed), 2016. Urban Biodiversity Assessment: Baldwin Hills Biota Update. Los Angeles:

University of Southern California for Baldwin Hills Conservancy (Proposition 84) and Baldwin Hills Regional Conservation Authority (Proposition A).

Los Angeles County, 2008. Baldwin Hills Community Standards District, Public Draft Environmental Impact Report. State Clearinghouse No. 2007061133. June 2008. ———, 2015. General Plan 2035, Figure 9-3. Significant Ecological Areas and Coastal Resource Areas Policy Map. https://planning.lacounty.gov/generalplan/generalplan. Accessed November 2023.
———, Long Range Planning Department, 2023. Baldwin Hills Community Standards District Amendment Website. Available at: Baldwin Hills CSD - LA County Planning. Accessed December 2023
South Coast Wildlands, 2008. South Coast Missing Linkages: A Wildland Network for the South Coast Ecoregion. Produced in cooperation with partners in the South Coast Missing Linkages Initiative. Available online [http://www.scwildlands.org.] U.S. Fish and Wildlife Service (USFWS), 2023a. Critical Habitat Portal. http://ecos.fws.gov/ crithab/. Accessed November 2023.
———, 2023b. National Wetlands Inventory. https://fwsprimary.wim.usgs.gov/wetlands/apps/ wetlands-mapper/. Accessed November 1, 2023.
———, 2024. Information Planning and Conservation System. https://ipac.ecosphere.fws.gov/ location/index. Accessed February 2024.

Cultural Resources
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.

Byrd, Brian F., and L. Mark Raab, 2007. Prehistory of the Southern Bight: Models for a New Millennium, in California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp 215-227.

Cerra, Julie Lugo, 1992. Culver City: The Heart of Screenland. Windsor Publications. ———, 2013. Culver City Chronicles, Charleston, History Press, pp 35.

Culver City, 2020. History of Culver City- Rancho Rincon de los Bueyes (Higueras) website.

Accessed September 1, 2020 at: https://www.culvercity.org/how-do-i/learn/about-culver- city/history-of-culver-city/early-settlers-of-culver-city/rancho-rincon-de-los-bueyes-higueras

7. References
General Plan 2045 and Zoning Code Update Project 7-5 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023. Culver City Municipal Code, Chapter 15.05 Historic Preservation Program.

Dinkelspiel, Frances, 2008. Towers of Gold, St. Martin’s Press, New York.

Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast. Plenum Press, New York.

Gumprecht, Blake, 2001. Los Angeles River: Its Life, and Possible Rebirth. The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.

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

Paleoenvironmental Reconstruction of the Ballona Lagoon. In People in a Changing Land:

The Archaeology and History of the Ballona in Los Angeles, California. Volume I:

Paleoenvironment and Culture History, edited by J. Homburg, J. Douglass, and S. Reddy, pp. 85-110. Statistical Research, Inc., Tucson, Arizona.

Jackson, Robert H., Agriculture, 1999. Drought & Chumash Congregation in the California Missions (1782-1834), Articles, California Mission Studies Association Newsletter, 1999.

Johnson, J. R., and D. D. Earle, 1990. Tataviam Geography and Ethnohistory. Journal of California and Great Basin Anthropology, Vol. 12, No. 2, pp. 191-214.

Koerper, H.C., R.D. Mason, and M.L. Peterson, 2002. Complexity, Demography, and Change in Late Holocene Orange County. In Catalysts to Complexity: Late Holocene Societies of the California Coast, edited by J.M.

Kroeber, A. L, 1925. Handbook of the Indians of California. Dover Publications, Inc., New York, reprinted 1976.

Los Angeles Almanac. January 2, 2019. Original Settlers of Los Angeles. Available at:
http://www.laalmanac.com/history/hi03c.php.

McCawley, William, 1996. The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press, Morongo Indian Reservation.

McWilliams, Carey, 1946. Southern California: An Island on the Land. Gibbs Smith, Layton, Utah.

Milliken, Randall, Laurence H. Shoup, and Beverly R. Ortiz, 2009. Ohlone/Costanoan Indians of the San Francisco Peninsula and their Neighbors, Yesterday and Today, prepared by Archaeological and Historical Consultants, Oakland, California, prepared for National Park Service Golden Gate National Recreation Area, San Francisco, California, June 2009.

Mullaly, Larry and Bruce Petty, 2002. The Southern Pacific Railroad in Los Angeles, 1873 - 1996.

Golden West Books, San Marino, California.

Orsi, Richard J, 2005. Sunset Limited – the Southern Pacific Railroad and the Development of the American West, 1850 - 1930. University of California Press, Berkeley and Los Angeles, California.

Pitt, Leonard, 1994. The Decline of the Californios: A Social History of the Spanish-speaking Californians, 1846-1890. University of California Press, Berkeley.

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

7. References
General Plan 2045 and Zoning Code Update Project 7-6 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Raab, L. Mark, Judith F. Porcasi, Katherine Bradford, and Andrew Yatsko, 1995. Debating Cultural Evolution: Regional Implications of Fishing Intensification at Eel Point, San Clemente Island.

Pacific Coast Archaeological Society Quarterly 31(3):3–27.

Reedy, Seetha N, 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pg. 48-66.

Starr, Kevin, 2007. California: A History. Modern Library, New York.

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.

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.

United States Department of the Interior, 1997a. National Register Bulletin #15: How to Apply the National Register Criteria for Evaluation.
———, 1997b. National Register Bulletin #21: Defining Boundaries for National Register Properties Form.

United States Department of the Interior, National Park Service, 2017. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings. ———, 2021. National Historic Landmarks Frequently Asked Question.

Wallace, W. J., 1955. A Suggested Chronology for Southern California Coastal Archaeology.

Southwestern Journal of Anthropology 11(3):214-230.

Warren, C. N., 1968. Cultural Traditions and Ecological Adaptation on the Southern California Coast. Archaic Prehistory in the Western United States, edited by Cynthia Irwin-Williams.

Eastern New Mexico University Contributions in Anthropology 1(3):1-14.

Energy
BP, 2021. Statistical Review of World Energy 2021, 70th edition, https://www.bp.com/content/ dam/bp/business-sites/en/global/corporate/pdfs/energy-economics/statistical-review/bp- stats-review-2021-full-report.pdf. Accessed January 2024.

California Air Resources Board (CARB), 2023a. California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californias- greenhouse-gas-vehicle-emission-standards-under-assembly-bill-1493-2002-pavley.

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

California Building Standards Commission, 2022. Guide to the 2022 California Green Building Standards Code Nonresidential. July.

7. References
General Plan 2045 and Zoning Code Update Project 7-7 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
California Energy Commission (CEC), 2022. 2022 Building Energy Efficiency Standards for Residential and Nonresidential Buildings. August 2022.
———, 2023a. 2022 Total System Electric Generation. https://www.energy.ca.gov/data - reports/energy-almanac/california-electricity-data/2022-total-system-electric-generation.

Accessed January 2024.
———, 2023b. 2021 Power Content Labels. Updated January 31, 2023. ———, 2023c. Supply and Demand of Natural Gas in California. https://www.energy.ca.gov/data-reports/energy-almanac/californias-natural-gas- market/supply-and-demand-natural-gas-california. Accessed January 2024. ———, 2023d. Final 2022 Integrated Energy Policy Report Update, p. 123. https://www.energy.ca.gov/data-reports/reports/integrated-energy-policy-report/2022- integrated-energy-policy-report-update. Accessed January 2024. ———, 2023e. Draft 2023 Integrated Energy Policy Report, p.A -1. https://efiling.energy.ca.gov/GetDocument.aspx?tn=253086. Accessed January 2024. ———, 2023f. 2021– 2023 Investment Plan Update for the Clean Transportation Program.

December 17, 2021.
———, 2024. 2022 California Annual Retail Fuel Outlet Report Results (CEC -A15) Energy Assessments Division. https://www.energy.ca.gov/sites/default/files/2023-08/2010- 2022%20CEC-A15%20Results%20and%20Analysis%20ADA.xlsx. Accessed January 2024.

California Gas and Electric Utilities, 2023. 2023 California Gas Report. https://www.socalgas.com/sites/default/files/Joint_Biennial_California_Gas_Report_2023_ Supplement.pdf. Accessed January 2024.

California Public Utilities Commission, 2022. 2022 California Gas Report. https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_Califor nia_Gas_Report_2022.pdf. Accessed January 2024.

Culver City Municipal Code. Title 15, Section 15.02.105, California Building Code Adopted by Reference with Local Amendments. https://codelibrary.amlegal.com/codes/culvercity/ latest/culvercity_ca/0-0-0-76668. Accessed March 2023.
———. Title 17, Section 17.320.035, Parking Design and Layout Guidelines. https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0- 52279#JD_17.320.020. Accessed March 2023.

Culver City, 1995. Circulation Element, p. C-8.
———, 2020. Bicycle & Pedestrian Action Plan.

Fehr & Peers, 2024 (VMT Data).

Los Angeles Department of Water and Power (LADWP), 2022. 2022 Power Strategic Long-Term Resource Plan, p. ES-5.

7. References
General Plan 2045 and Zoning Code Update Project 7-8 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023. Briefing Book 2022-2023, p. 61. https://ladwp -jtti.s3.us-west-

2.amazonaws.com/wp-content/uploads/sites/3/2023/05/18120930/2022- 23_Briefing_Book_Online.pdf. Accessed January 2024.

National Highway Traffic Safety Administration, 2023. Corporate Average Fuel Economy. https://www.nhtsa.gov/laws-regulations/corporate-average-fuel-economy#75896.

Accessed January 2024.

Southern California Association of Governments, 2023. Greenhouse Gases. https://scag.ca.gov/greenhouse-gases. Accessed January 2024.

Southern California Edison (SCE), 2023a. About Us- Who We Are. https://www.sce.com/about- us/who-we-are. Accessed January 2024.
———, 2023b. 2022 Annual Report, p. 2.
———, 2023c. 2022 Sustainability Report, p. 15.
———, 2023d. 2021 Annual Report, p. 2.

Southern California Gas, 2023. Company Profile. https://www.socalgas.com/about-us/company- profile. Accessed January 2024.

U. S. Environmental Protection Agency (USEPA), 2011. Fact Sheet: EPA and NHTSA Adopt First- Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, 2011. https://www.nhtsa.gov/sites/nhtsa.gov/files/detailed-fact- sheet.pdf. Accessed January 2024.
———, 2012. EPA and NHTSA Set Standards to Reduce Greenhouse Gases and Improve Fuel Economy for Model Years 2017–2025 Cars and Light Trucks. ———, 2016. Federal Register / Vol. 81, No. 206 / Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles— Phase 2, 2016. ———, 2020. Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30, 2020. https://www.federalregister.gov/documents/2020/04/30/2020-06967/the-safer- affordable-fuel-efficient-safe-vehicles-rule-for-model-years-2021-2026-passenger-cars-and.

Accessed January 2024.
———, 2021. Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.
———, 2022. California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Notice of Decision, 87 Fed. Reg. 14,332 (March 14, 2022).

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

7. References
General Plan 2045 and Zoning Code Update Project 7-9 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
City of Culver City and Culver City Unified School District, 2017. Multi-Jurisdictional Hazard Mitigation Plan. Available at: https://www.culvercity.org/files/assets/public/documents/ planning-amp-development/multijurisdictionalhazardm.pdf. Accessed March 2023.

Culver City, 2017. IOF Specific Plan Project Draft Environmental Impact Report. https://www.culvercity.org/files/assets/public/documents/city-manager/inglewood-oil- field/environmental-review-process/toc091117.pdf. Accessed March 2023. ———, 2020. Environmental Background Report Existing Conditions Report. https://www.pictureculvercity.com/resources. Accessed March 2023. ———, 2021. Seismic Retrofit Ordinance.
https://www.culvercity.org/files/assets/public/documents/community- development/ordinance-2021-013.pdf. Accessed March 2023.

Department of General Services, 2022. Building Standards Commission, California Building Standards Code. Available at: https://www.dgs.ca.gov/BSC/Codes#@ViewBag.JumpTo/.

Accessed March 2023.

Environmental Science Associates (ESA), 2018. Archaeological and Paleontological Monitoring Report for the Ivy Station Project, City of Culver City and City of Los Angeles, County of Los Angeles California. Prepared for: Culver City Triangle Investor, Inc., c/o Lowe Enterprises Real Estate Group.
———, 2020. Progress Report - Archaeological and Paleontological Construction Monitoring Services for the Culver Studios Innovation Plan Project; Culver City, Los Angeles County, California. Prepared for The Culver Studios Owner, LLC. ———, 2021. Archaeological and Paleontological Monitoring Report for the 8777 Washington Project; Culver City, County of Los Angeles, California. Prepared for: CLPF-8777 Washington, L.P.

Mcleod, Samuel, 2019. Paleontological Resources for the Proposed Culver City General Plan Update Project, in Culver City, Los Angeles County, Project Area. Letter on file at ESA.

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

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

Greenhouse Gas Emissions
14 California Code of Regulations Section 15064.4(b).

Anderegg, William R. L., J.W. Prall, J. Harold, S.H. Schneider, 2010. Expert Credibility in Climate Change, Proceedings of the National Academy of Sciences of the United States of America. 107:12107–12109.

7. References
General Plan 2045 and Zoning Code Update Project 7-10 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Association of Environmental Professionals, Alternative Approaches to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007; U.S.

Environmental Protection Agency, Acute Exposure Guideline Levels (AEGLs) for Nitrogen Trifluoride; January 2009.

CalAdapt, 2024. Local Climate Change Snapshot Culver City, California. https://cal- adapt.org/tools/local-climate-change-snapshot/. Accessed January 2024.

California Air Pollution Control Officers Association (CAPCOA), 2008. CEQA & Climate Change:

Evaluating and Addressing Greenhouse Gas Emissions from Projects Subject to the California Environmental Quality Act.

California Air Resources Board (CARB), 2009. Climate Change Scoping Plan a framework for change, December.
———, 2014. First Update to the Climate Change Scoping Plan Building on the Framework, May. ———, 2017. California’s 2017 Climate Change Scoping Plan, November. ———, 2018. SB 375 Proposed Update to the SB 375 Greenhouse Gas Emission Reduction Targets. https://ww2.arb.ca.gov/sites/default/files/2020-06/SB375_Updated_Final_ Target_Staff_Report_2018.pdf. Accessed March 2023.
———, 2020a. Greenhouse Gas Emissions of Contemporary Wildfire, Prescribed Fire, and Forest Management Activities. December. https://ww2.arb.ca.gov/sites/default/ files/classic/ cc/inventory/pubs/ca_ghg_wildfire_forestmanagement.pdf?utm_medium= email&utm_source=govdelivery. Accessed January 2024.
———, 2020b. Southern California Association of Governments’ (SCAG) 2020 Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination, October 2020. https://ww2.arb.ca.gov/sites/default/files/2021-
02/SCAG%202020%20SCS%20CARB%20Acceptance%20of%20GHG%20Quantification%20De termination%20Executive%20Order.pdf. Accessed January 2024. ———, 2022a. 2022 Scoping Plan for Achieving Carbon Neutrality, December. ———, 2022b. 2022 Scoping Plan for Achieving Carbon Neutrality – Appendix D: Local Actions, November.
———, 2022c. CARB approves amendments to Off -Road Regulation to further reduce emissions, November 17. https://ww2.arb.ca.gov/news/carb-approves-amendments-road-regulation- further-reduce-emissions. Accessed January 2024.
———, 2023a. Advanced Clean Trucks Program. https://ww2.arb.ca.gov/our - work/programs/advanced-clean-trucks/about. Accessed March 2023. ———, 2023b. California's Greenhouse Gas Vehicle Emission Standards under Assembly Bill 1493 of 2002 (Pavley). https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission- standards-under-assembly-bill-1493-2002-pavley. Accessed March 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-11 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023c. Current Zero -Emissions Vehicle Regulation. https://ww2.arb.ca.gov/our- work/programs/advanced-clean-cars-program/zev-program/current-zero-emission-vehicle- regulation. Accessed March 2023.
———, 2023d. Sustainable Communities and Climate Protection Program. https://ww2.arb.ca.gov/our-work/programs/sustainable-communities-climate-protection- program/about. Accessed March 2023.
———, 2023e. California GHG Emission Inventory Data – 2000–2021 GHG Inventory (2023 Edition). https://ww2.arb.ca.gov/ghg-inventory-data. Accessed January 2024. ———, 2024a . Advanced Clean Cars II. https://ww2.arb.ca.gov/our-work/programs/advanced- clean-cars-program/advanced-clean-cars-ii. Accessed January 2024. ———, 2024b. Current California GHG Emission Inventory Data – 2000–2021 GHG Inventory (2023 Edition). https://ww2.arb.ca.gov/ghg-inventory-data. Accessed January 2024.

California Building Standards Commission, 2010. California Green Building Standards Code.

California Climate Change Assessment, 2018. California’s Fourth Climate Change Assessment Statewide Summary Report, November. https://www.energy.ca.gov/sites/default/files/ 2019-11/Statewide_Reports-SUM-CCCA4-2018-013_Statewide_Summary_Report_ ADA.pdf. Accessed January 2024.

California Department of Finance, 2023. Gross State Product in California. https://dof.ca.gov/wp-content/uploads/sites/352/2023/06/CA-GDP.xlsx. Accessed January 2024. Amounts are based on current dollars as of the date of the report (June 2023). ———, 2024. E -5 Population and Housing Estimates for Cities, Counties, and the State, 2020– 2023. https://dof.ca.gov/wp-content/uploads/sites/352/Forecasting/Demographics/ Documents/E-5_2023_InternetVersion.xlsx. Accessed January 2024.

California Department of Water Resources, 2006. Climate Change Report, Progress on Incorporating Climate Change into Planning and Management of California’s Water Resources, page 2-75.

California Energy Commission, 2022. Building Energy Efficiency Standards.

California Environmental Protection Agency (CalEPA), 2006. Climate Action Team, Climate Action Team Report to Governor Schwarzenegger and the Legislature. https://efiling.energy.ca.gov/GetDocument.aspx?tn=204014&DocumentContentId=2726.

Accessed January 2024.
———, 2023a. 2022 State Agency Greenhouse Gas Reduction Report Card. https://calepa.ca.gov/wp-content/uploads/sites/6/2023/05/CAT-Report-Card-2022.a.pdf.

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

7. References
General Plan 2045 and Zoning Code Update Project 7-12 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023c. Understanding the Urban Heat Island Index, Appendix C, Figure C41. https://calepa.ca.gov/wp-content/uploads/sites/6/2016/10/UrbanHeat-Report- AppendixC.pdf. Accessed January 2024.

California Legislative Information, 2022. AB-1279 The California Climate Crisis Act (2012-2022), September 16. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml? bill_id=202120220AB1279. Accessed January 24.

Culver City Municipal Code. Chapter 15.02.1100, Green Building Program and Requirements. ———. Section 15.02.105, Solar Photovoltaic Systems.

Culver City, 2020. Bicycle and Pedestrian Master Plan. Adopted by City Council, June. https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021- 10-cc-bikepedplan-app2020-v10-final.pdf. Accessed January 2024. ———, 2021. 2019 Community Greenhouse Gas Inventory Report, April. https://9021zeroemissions.rinconconsultants.com/wp-content/uploads/2021/11/2.- CulverCity_2019_Community_GHG_Inventory_Clean.pdf. Accessed January 2024.

Governor’s Office of Planning and Research, 2008. Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, June 19. https://opr.ca.gov/ceqa/docs/20210720-june08-ceqa.pdf. Accessed January 2024.

Intergovernmental Panel on Climate Change (IPCC), 1995. Second Assessment Report, Working Group I: The Science of Climate Change.
———, Fourth Assessment Report, 2007. Working Group I Report: The Physical Science Basis, Table 2.14.
———, 2013. Fifth Assessment Report, Summary for Policy Makers, page 17.

Letter from Cynthia Bryant, Director of the Governor’s Office of Planning and Research (OPR) to Mike Chrisman, California Secretary for Natural Resources, dated April 13, 2009.

National Highway Traffic Safety Administration (NHTSA), 2023. Corporate Average Fuel Economy. https://www.nhtsa.gov/laws-regulations/corporate-average-fuel- economy#75896. Accessed January 2024.

Office of Environmental Health Hazard Assessment (OEHHA), 2018. Indicators of Climate Change in California. May. https://oehha.ca.gov/media/downloads/climate- change/report/2018caindicatorsreportmay2018.pdf. Accessed January 2024.

Office of the Governor of California, 2005. Executive Order S-3-05, June 2. https://www.library.ca.gov/wp-content/uploads/GovernmentPublications/executive-order- proclamation/5129-5130.pdf. Accessed January 2024.
———, 2007. Executive Order S -01-07, January 18. https://climateactionnetwork.ca/wp- content/uploads/2011/06/eos0107.pdf. Accessed January 2024.

7. References
General Plan 2045 and Zoning Code Update Project 7-13 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2015. Executive Order B -30-15, April 29. https://www.library.ca.gov/wp- content/uploads/GovernmentPublications/executive-order-proclamation/39-B-30-15.pdf.

Accessed January 2024.
———, 2018. Executive Order, September 10. https://www.ca.gov/archive/gov39/wp - content/uploads/2018/09/9.10.18-Executive-Order.pdf. Accessed January 2024.

P. Friedlingstein et al., 2020. Global Carbon Budget 2020. https://essd.copernicus.org/articles/12/3269/2020/. Accessed January 2024.

Pacific Institute for Studies in Development, Environment and Security, 2003. Climate Change and California Water Resources: A Survey and Summary of the Literature. July. https://pacinst.org/wp-content/uploads/2003/07/climate_change_and_california_water_ resources.pdf. Accessed January 2024.

Pew Center on Global Climate Change, 2006. Climate Change 101: Understanding and Responding to Global Climate Change, October 12. https://www.pewtrusts.org/- /media/legacy/uploadedfiles/wwwpewtrustsorg/reports/global_warming/climate101full12 1406065519pdf.pdf. Accessed January 2024.

South Coast Air Quality Management District (SCAQMD), 2008a. Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, Attachment E. October 2008. ———, 2008b. Board Meeting, December 5, 2008, Agenda No. 31. http://www3.aqmd.gov/hb/2008/December/0812ag.html. Accessed March 2023. ———, 2008c. Greenhouse Gases, CEQA Significance Thresholds, Board Letter – Interim CEQA GHG Significance Threshold for Stationary Sources, Rules and Plans. December 5, 2008. ———, 2023. Greenhouse Gases CEQA Significance Thresholds. http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/ghg- significance-thresholds. Accessed March 2023.

Southern California Association of Governments (SCAG), 2020a. 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy. Connect SoCal, October. ———, 2020b. 2020– 2045 Regional Transportation Plan/Sustainable Communities Strategy.

Demographics and Growth Forecast Technical Report. September 2020. ———, 2023. SCAG EV Charging Station Study - Electric Vehicle (EV) Infrastructure Plan – Culver City, February 28. https://www.culvercity.org/files/assets/public/v/1/documents/ public-works/sustainability/2023-02-cc-scag-ev-studyplan-package-final.pdf. Accessed January 2024.

U.S. Environmental Protection Agency (USEPA), 2020. Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30. https://www.govinfo.gov/content/pkg/FR-2020-04- 30/pdf/2020-06967.pdf. Accessed January 2024.
———, 2021. Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards.

7. References
General Plan 2045 and Zoning Code Update Project 7-14 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023a. Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gas, last updated on November 1, 2023. https://www.epa.gov/climate-indicators/climate-change- indicators-atmospheric-concentrations-greenhouse-gases. Accessed January 2024. ———, 2023b. Climate Change Indicators: Greenhouse Gases, last updated on December 13, 2023. https://www.epa.gov/climate-indicators/greenhouse-gases. Accessed January 2024. ———, 2023c. Global Greenhouse Gas Emissions Data, last updated on February 15, 2023. www.epa.gov/ghgemissions/global-greenhouse-gas-emissions-data. Accessed January 2024.

USEPA and NHTSA, 2016. Adopt Standards to Reduce GHG and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles for Model Year 2018 and Beyond, August. https://www.govinfo.gov/content/pkg/FR-2016-10-25/pdf/2016-21203.pdf. Accessed January 2024.

U.S. Global Change Research Program, 2018. Climate Science Special Report: Fourth National Climate Assessment, Volume 1, Executive Summary. https://science2017.globalchange.gov /chapter/executive-summary/. Accessed January 2024.

United States Census Bureau, 1995. National and State Population Estimates: 1990–1994, 1995.

Hazards and Hazardous Materials
California Department of Forestry and Fire Protection, 2011. Very High Fire Hazard Severity Zones in Local Responsibility Areas (Culver City). September 2011.

California Department of Toxics Substances Control, 2023. EnviroStor Online Database. https://www.envirostor.dtsc.ca.gov/public/. Accessed May 2023.

Culver City, 2017. Inglewood Oil Field Specific Plan Project Draft Environmental Impact Report. https://www.culvercity.org/files/assets/public/documents/city-manager/inglewood-oil- field/environmental-review-process/toc091117.pdf. Accessed April 2023.

Culver City and Culver City Unified School District, 2017. Multi-Jurisdictional Hazard Mitigation Plan. https://www.culvercity.org/files/assets/public/documents/planning-amp- development/multijurisdictionalhazardm.pdf. Accessed July 2023. ———, 2023. Evacuation Route Capacity and Viability Study. Prepared by Michael Baker International. October 2023.

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

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

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

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.

7. References
General Plan 2045 and Zoning Code Update Project 7-15 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Sentinel Peak Resources California, LLC, 2017. History of Inglewood Oil Field. https://inglewoodoilfield.com/history-future/history-inglewood-oilfield/. Accessed May 2023.
———, 2022. The Inglewood Oil Field: 2022 Annual Newsletter and Community Announcement. https://inglewoodoilfield.com/wp-content/uploads/2022/09/2022-IOF-Annual- Newsletter.pdf. Accessed May 2023.

State Water Resources Control Board, 2023. GeoTracker Online Database. https://geotracker.waterboards.ca.gov/. Accessed May 2023.

United States Department of Transportation, 2021. Federal Hazmat Law, September 2021.

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

Hydrology and Water Quality
Ballona Creek Watershed Management Group, 2016. Enhanced Watershed Management Program for the Ballona Creek Watershed. Available at: https://www.waterboards.ca.gov/ losangeles/water_issues/programs/stormwater/municipal/watershed_management/ballon a_creek/BallonaCreek_RevisedEWMP_corrected2016Feb1.pdf. Accessed March 2023.

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

Accessed March 2023.

California Department of Water Resources, 2004a. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Santa Monica Subbasin. https://water.ca.gov/- /media/DWR-Website/Web-Pages/Programs/Groundwater-Management/Bulletin- 118/Files/2003-Basin-Descriptions/4_011_01_SantaMonicaSubbasin.pdf. Accessed March 2023.
———, 2004b. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, West Coast Subbasin. Available at: https://water.ca.gov/-/media/DWR-Website/Web- Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003-Basin- Descriptions/4_011_03_WestCoastSubbasin.pdf. Accessed March 2023. ———, 2004c. California Groundwater Bulletin 118: Coastal Plain of Los Angeles Groundwater Basin, Central Subbasin. Available at: https://water.ca.gov/-/media/DWR-Website/Web- Pages/Programs/Groundwater-Management/Bulletin-118/Files/2003-Basin- Descriptions/4_011_04_CentralSubbasin.pdf. Accessed March 2023. ———, 2015. California’s Groundwater Update 2013: A Compilation of Enhanced Content for California Water Plan Update 2013. Available at: https://water.ca.gov/-/media/DWR- Website/Web-Pages/Programs/Groundwater-Management/Data-and- Tools/Files/Statewide-Reports/California-Groundwater-Update-2013/California-- Groundwater-Update-2013---Chapter-6---South-Coast.pdf. Accessed March 2023. ———, 2023a. Groundwater Sustainability Plan 4-011.01 SANTA MONICA. Available at:
https://sgma.water.ca.gov/portal/gsp/preview/129. Accessed March 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-16 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023b. Adjudicated Area Annual Reports. Available at:
https://sgma.water.ca.gov/adjudbasins/report/publicview. Accessed March 2023. ———, 2023c. SGMA Portal. SGMA Groundwater Management (SGMA) Portal - Department of Water Resources (ca.gov) Accessed April 2023.

California Regional Water Quality Control Board, 2023. Water Quality Control Plan: Los Angeles Region Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties. https://www.waterboards.ca.gov/losangeles/water_issues/programs/basin_plan/. Accessed March 2023.
———, 2019. Construction Stormwater Program. Available at:
https://www.waterboards.ca.gov/water_issues/programs/stormwater/construction.html.

Accessed March 2023.

California Water Boards – Los Angeles (R4), 2021. California Regional Water Quality Control Board Los Angeles Region Regional Phase I MS4 NPDES Permit (Order No. R4-2021-0105).

Available at: https://www.waterboards.ca.gov/losangeles/water_issues/ programs/stormwater/municipal/public_docs/2022/1_Order(ACC-RPSignature).pdf.

Accessed March 2023.

County of Los Angeles, 2014. Los Angeles County General Plan Update Draft Environmental Impact Report. Available at: https://planning.lacounty.gov/assets/upl/project/ gp_2035_deir.pdf. Accessed March 2023.
———, 2023. Marina Del Rey Watershed webpage. Available at:
https://dpw.lacounty.gov/wmd/watershed/mdr/index.cfm. Accessed March 2023.

Culver City, 2017. IOF Specific Plan Project Draft Environmental Impact Report. Available at:
https://www.culvercity.org/files/assets/public/documents/city-manager/inglewood-oil- field/environmental-review-process/toc091117.pdf. Accessed March 2023. ———. 2020. Land Use and Community Design Existing Conditions Report. October 2020.

Culver City Public Works Department, 2021. Culver City Stormwater Quality Master Plan.

Available at: https://www.culvercity.org/City-Projects/Stormwater-Quality-Master-Plan- SWQMP#:~:text=The%20Stormwater%20Quality%20Master%20Plan%20presents%20over% 20400%20potential%20project,all%20of%20the%20potential%20projects. Accessed March 2023.
———, 2023. Stormwater and Urban Runoff. https://www.culvercity.org/City- Hall/Departments/Public-Works/Culver-City-Environmental-Initiatives/Stormwater-and- Urban-Runoff. Accessed March 2023.

Golden State Water Company (GSWC), 2016. 2015 Urban Water Management Plan: Culver City.

Available at: http://www.gswater.com/download/CulverCity_2015_UWMP-FinalDraft.pdf.

Accessed March 2023.
———, 2021. 2020 Urban Water Management Plan: Culver City Service Area. Available at:
https://www.gswater.com/urban-water-management-plan. Accessed March 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-17 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Los Angeles County Flood Control District (LACFCD), 2018. Marina Del Rey Enhanced Watershed Management Program Plan. Available at: https://www.waterboards.ca.gov/ rwqcb4/water_issues/programs/stormwater/municipal/watershed_management/marina_d elrey/20180226MdREWMPrevised.pdf. Accessed March 2023.

Los Angeles Regional Water Quality Control Board, 2013. Order No. R4-2013-0095, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties.
———, 2018. Order No. R4 -2018-0125, General NPDES Permit No. CAG994004, Waste Discharge Requirements for Discharges of Groundwater from Construction and Project Dewatering to Surface Waters in Coastal Watersheds of Los Angeles and Ventura Counties. ———, 2019. Basin Plan for the Coastal Watersheds of Los Angeles and Ventura Counties ———, 2021. Order No. R4 -2021-0105, NPDES Permit No. CAS004004, Regional Phase I MS4 NPDES Permit, Waste Discharge Requirements and National Pollutant Discharge Elimination System (NPDES) Permit For Municipal Separate Storm Sewer System (MS4) Discharges within the Coastal Watersheds of Los Angeles and Ventura Counties.

State Water Resources Control Board (SWRCB), 2018. California 2018 Integrated Report.

Water Replenishment District of Southern California, 2021. Regional Groundwater Monitoring Report Water Year 2019–2020. March.

Land Use and Planning
Culver City, 2015. Culver City Urban Forest Master Plan. https://www.culvercity.org/files/ sharedassets/public/city-hall/culver_city_urban_forest_master_plan.pdf. Accessed October 2023.
———, 2020a. Land Use and Community Design Existing Conditions Report. https://static1.squarespace.com/static/5d950bfaae137b5f0cbd75f5/t/5f936f995f4c6062f85 b1d27/1603498031880/LUECR_Web.pdf. Accessed October 2023. ———, 2020b. Bicycle and Pedestrian Action Plan. June 2020. https://www.culvercity.org/files/assets/public/documents/public-works/mobility/2021-10- cc-bikepedplan-app2020-v10-final.pdf. Accessed October 2023.

Mineral Resources
California Department of Conservation, Office of Mine Reclamation (OMR), 2016. Mines Online Database – Culver City. Available at: https://maps.conservation.ca.gov/mol/index.html.

Accessed May 2023.

California Geologic Energy Management Division (CalGEM), 2020. California State Oil and Gas Supervisor 2020 Annual Report. Available at: CALIFORNIA STATE OIL AND GAS SUPERVISOR ANNUAL REPORT 2020. Accessed December 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-18 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
California Geological Survey (CGS), 2021. Updated Mineral Resource Zones for Portland Cement Concrete Aggregate in the San Fernando Valley and Saugus-Newhall Production- Consumption Regions. Available at: https://www.conservation.ca.gov/cgs/Documents/ Publications/Special-Reports/SR_254-MLC-SanFernandoValleySaugusNewhallPCR-2021- Plate01-MRZs-a11y.pdf. Accessed May 2023.

Culver City, 1973. Culver City General Plan – Conservation Element. Available at:
conservationelement.pdf (culvercity.org). Accessed May 2023. ———, 2017a . Inglewood Oil Field Specific Plan. Available at:
https://www.culvercity.org/files/assets/public/v/1/documents/city-manager/inglewood-oil- field/environmental-review-process/b1specificplan.pdf. Accessed December 2023. ———, 2017b. Inglewood Oil Field Specific Plan Project Draft Environmental Impact Report.

Available at: https://www.culvercity.org/files/assets/public/v/1/documents/city- manager/inglewood-oil-field/environmental-review-process/toc091117.pdf. Accessed December 2023.

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

United States Bureau of Mines, Principles of a Resource/Reserve Classification for Minerals.

Available at: https://pubs.usgs.gov/circ/1980/0831/report.pdf. Accessed May 2023 Noise
California Department of Transportation (Caltrans), Technical Noise Supplement to the Traffic Noise Analysis Protocol, 2013.
———, Transportation and Construction Vibration Guidance Manual, April 2020.

California Legislative Information, Assembly Bill No. 1307. September 7, 2023. Available at:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB1307.

Accessed October 2023.

Federal Highway Administration (FHWA), Roadway Construction Noise Model User’s Guide, 2006.

Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Manual, 2018.

Fehr & Peers, 2024 (VMT and traffic volume data).

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

United States Department of Labor, 1970. Occupational Safety and Health (OSH) Act of 1970, https://www.osha.gov/laws-regs/oshact/completeoshact. Accessed March 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-19 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Population and Housing
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. ———, 2012. E-8 Historical Population and Housing Estimates for Cities, Counties, and the State, 2000-2010. Sacramento, California, November 2012.

Culver City, 2020a. Culver City General Plan Update: Housing Element Existing Conditions Report. Table 1: Population Trends in Culver City and LA County. https://www.pictureculvercity.com/resources. Accessed February 2023. ———, 2020b. Culver City Land Use and Community Design Existing Conditions Report. https://www.pictureculvercity.com/resources. Accessed February 2023. ———, 2022a. Housing Element. https://www.pictureculvercity.com/housing-element.

Accessed April 2023.
———, 2022b. Housing Element. Appendix B: Residential Sites Inventory. https://www.pictureculvercity.com/housing-element. Accessed March 2023. ———, 2023. Housing Element Update Timeline. https://www.pictureculvercity.com/housing- element/#updatetimeline. Accessed April 2023.

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

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.

Raimi + Associates, Preferred Plan Growth Projections. November 2022.

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. ———, 2020a. Connect SoCal (2020 RTP/SCS). Adopted September 3, 2020. ———, 2020b. Final RHNA Allocation Methodology. Adopted March 5, 2020. ———, 2020c. Final Connect SoCal Demographics and Growth Forecast. Adopted September 3, 2020.
———, 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.
———, 2021b. SCAG 6th Cycle Final RHNA Allocation Plan. Approved on March 22, 2021 and modified on July 7, 2021.
———, 2023. Regional Housing Needs Assessment. https://scag.ca.gov/rhna. Accessed April 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-20 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
United States Census Bureau, 2010. OnTheMap web application, Work Area Profile Analysis by Place of Work. https://onthemap.ces.census.gov/. Accessed March 2023.

Public Services
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. ———, 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.
———, 2019b. 2018-19 Enrollment by Ethnicity and Grade, Los Angeles County Report . https://dq.cde.ca.gov/dataquest/page2.asp?Level=School&Subject=Enrollment. Accessed March 2023.

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.
———, 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.

California Department of Forestry and Fire Protection, 2011. Very High Fire Hazard Severity Zones in Local Responsibility Areas (Culver City). September 2011.

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.

Commission on Fire Accreditation International, 2019. Accreditation Report, Culver City Fire Department. https://www.culvercityfd.org/files/sharedassets/fire/ culvercityfdaccreditationr.pdf. Accessed April 2023.

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.

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.

Culver City, 2019. Culver City Hall Master Plan. https://www.culvercity.org/files/assets/public/ documents/city-manager/cityhallmasterplan.pdf. Accessed March 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-21 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2020. General Plan Update Parks, Public Facilities, and Public Services Existing Conditions Report, July 2020.
———, 2023. Hazard Mitigation Plan. https://www.culvercity.org/Services/Public - Safety/Hazard-Mitigation-Plan. Accessed March 2023.

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

Culver City Fire Department personal communication, 2019. Public Services, Infrastructure and Smart Cities Stakeholder Meeting with City Staff. September 3, 2019.

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.

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.
———, 2023a. About CCPD. https://www.culvercitypd.org/Office-of -the-Chief-of-Police/About- CCPD. Accessed May 2023.
———, 2023b. 2023- Quarter 1 Report.

Culver City Unified School District, 2014. Facilities Master Plan. https://www.ccusd.org/ CapitalProjects/CCUSD_Facilities_Master_Plan.pdf. Accessed March 2023. ———, 2020. Draft Developer Fee Study.
———, 2023a. Culver City USD Future -Ready Facilities Plan. https://www.ccusdfutureready.org/. Accessed March 2023. ———, 2023b. Frequently Asked Questions. https://www.ccusdfutureready.org/faq . Accessed April 2023.
———. 2023c . Our Schools. https://www.ccusd.org/. Accessed May 2023.

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

Herbertson, 2019. Charles Herbertson, P.E., L.S., Public Works Director / City Engineer, email correspondence on October 23, 2019.

7. References
General Plan 2045 and Zoning Code Update Project 7-22 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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.

Los Angeles Fire Department, 2014. Mutual Aid Agreements/Disaster Declarations/Potential Fiscal Impacts. July 3, 2014.

West Los Angeles College, 2021. 2021 Annual Security Report – West Los Angeles College, p. 13. https://www.wlac.edu/sites/wlac.edu/files/2022-08/2021AnnualSecurityReport.pdf.

Accessed April 2023.

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

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.
———, 2020. Parks, Public Facilities, and Public Services Existing Conditions Report, p. 8. https://www.pictureculvercity.com/resources. Accessed March 2023. ———. 2023a. Culver City Pool. https://www.culvercity.org/Explore/Parks -Recreation/Culver- City-Pool. Accessed July 28, 2023.
———, 2023b. Culver City Senior Center. https://www.culvercity.org/City -Hall/Jobs/Culver-City- Senior-Center. Accessed March 2023.
———, 2023c. Parks, Recreation, and Public Facilities Element. ———, 2023d. Teen Center. https://www.culvercity.org/Explore/Parks -Recreation/Teen-Center.

Accessed March 2023.

Culver City Historical Society, 2011. Historic Site #13 - Veterans Memorial Building. https://www.culvercityhistoricalsociety.org/historic-sites/veterans-memorial-building/.

Accessed March 2023.

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.
———, 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.

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.

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

7. References
General Plan 2045 and Zoning Code Update Project 7-23 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Transportation
City of Culver City, 2022. Resolution Adopting 2022-2026 Short Range Mobility Plan, February 28, 2022.
———, 2023. Culver CityBus About Us. https://www.culvercitybus.com/Culver -CityBus/About- Us. Accessed March 2023.

Fehr & Peers, 2024. Culver City General Plan Update CEQA Transportation Analysis Memorandum.

Tribal Cultural Resources
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.

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

Los Angeles Almanac. January 2, 2019. Original Settlers of Los Angeles. Available at:
http://www.laalmanac.com/history/hi03c.php.

McCawley, William, 1996. The First Angelinos, The Gabrielino Indians of Los Angeles. Malki Museum Press, Morongo Indian Reservation.

Reedy, Seetha N., 2015. Feeding Family and Ancestors: Persistence of Traditional Native American Lifeways during the Mission Period in Coastal Southern California. Journal of Anthropological Archaeology, No. 37, pg. 48-66.

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.

Utilities and Service Systems
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/Ba llonaCreek_RevisedEWMP_corrected2016Feb1.pdf. Accessed April 2023.

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.
———, 2021b. Jurisdiction Per Capita Disposal Trends – Culver City, for reporting year 2021. https://www2.calrecycle.ca.gov/LGCentral/AnnualReporting/ReviewReports. Accessed April 2023.

7. References
General Plan 2045 and Zoning Code Update Project 7-24 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
———, 2023a. Senate Bill 1374 (2002). Accessed April 2023. ———, 2023b. Mandatory Commercial Organics Recycling. www.calrecycle.ca.gov/ recycle/commercial/organics/. Accessed March 2023.

California Department of Water Resources, 2023. SGMA Groundwater Management. https://water.ca.gov/Programs/Groundwater-Management/SGMA-Groundwater- Management. Accessed April 2023.

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

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.

California State Water Resources Control Board, 2010. 20 x 2020 Water Conservation Plan, February 2010.

County of Los Angeles Department of Public Works, 2021. CoIWMP 2020 Annual Report.

October 2021. https://dpw.lacounty.gov/epd/swims/News/swims-more-links.aspx?id=4#.

Accessed April 2023.

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. ———, 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.
———, 2022. Capital Improvement Plan FY 2022/2023 to FY 2026/2027. https://www.culvercity.org/files/assets/public/documents/finance/governmenttransparenc y/02_annualcitybudgets/3_cip/cip_2022-2023.pdf. Accessed July 2023. ———, 2023a. Sewer Infrastructure Management System (SIMS). https://gisproxy.culvercity.org/Html5Viewer/index.html?viewer=Sims.sims. Accessed April 2023.
———, 2023b. Trash & Recycling. https://www.culvercity.org/Services/Trash -Recycling.

Accessed April 2023.
———, 2023c. Water Conservation. https://www.culvercity.org/City -Hall/Departments/Public- Works/Culver-City-Environmental-Initiatives/Water-Conservation. Accessed April 2023. ———, 2023d. Technology. https://www.culvercity.org/City -Hall/Departments/IT. Accessed April 2023.

Culver City Zoning Code, 2023. Title 17, Sections 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.

7. References
General Plan 2045 and Zoning Code Update Project 7-25 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
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. ———, 2021. 2020 Urban Water Management Plan: Culver City Service Area. https://www.gswater.com/urban-water-management-plan. Accessed March 2023.

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.

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. ———, 2023b. Loadings for Each Class of Land Use.
https://www.lacsd.org/home/showpublisheddocument/3644/637644575489800000.

Accessed April 2023.

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.

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.

Metropolitan Water District of Southern California, 1999. Water Surplus and Drought Management Plan, Report No. 1150.
———, 2016. Integrated Water Resources Plan – 2015 Update, Report No. 1518. ———, 2021. 2020 Urban Water Management Plan, June 2021.

Southern California Edison, 2019. Circuit reliability Review, Culver City, 2019. https://www1.sce.com/nrc/reliability/reports/CulverCity.pdf. ———, 2023. 2023-2025 Wildfire Mitigation Plan. https://www.sce.com/safety/wild -fire- mitigation. Accessed March 2023.

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.

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

7. References
General Plan 2045 and Zoning Code Update Project 7-26 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Sustainable Groundwater Management Act [And Related Statutory Provisions from SB1168 (Pavley), AB1739 (Dickinson), and SB1319 (Pavley) as Chaptered], 2015 Amendments, effective January 1, 2019.

West Basin Municipal Water District, 2021. Urban Water Management Plan. https://wuedata.water.ca.gov/getfile?filename=/public%2Fuwmp_attachments%2F1728223 502%2FWBMWD%202020%20UWMP_Final_2021-06-30.pdf. Accessed April 2023.

Wildfire
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.

Culver City Fire Department, 2019a. Culver City Fire Department Strategic Plan 2019-2024. https://www.culvercityfd.org/About-the-Department/Documents. Accessed May 2023. ———, 2019b. Community Risk Assessment, Standards of Cover. https://www.culvercityfd.org/ files/sharedassets/fire/crasoc_website_20190618.pdf. Accessed May 2023.

Culver City and Culver City Unified School District, 2023. Evacuation Route Capacity and Viability Study.

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. ———, 2023a. Fire Hazard Reduction Programs. https://fire.lacounty.gov/fire- hazard-reduction- programs/. Accessed May 2023.
———, 2023b. Forestry Fuel Modification. Available online at: https://fire.lacounty.gov/ forestry-fuel-modification/. Accessed May 2023.

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

General Plan 2045 and Zoning Code Update Project 8-1 SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CHAPTER 8
List of Preparers
Lead Agency
City of Culver City
Planning and Development
9770 Culver Boulevard
Culver City, CA 90232
Troy Evangelho, AICP Advance Planning Manager
Lauren Wren Associate Planner
Oscar Reyes-Zapien Planning Technician II
Environmental Impact Report
Environmental Science Associates (ESA)
626 S Wilshire Boulevard, Suite 1100
Los Angeles, CA 90017
Luci Hise-Fisher, AICP Project Director
Margarita Jerabek Director, Cultural Resources
Alan Sako Director, Air Quality, Climate & Acoustics
May Lau Environmental Scientist V
Steve Smith Planner III
Marlie Long Planner III
Nick Reynoso Air Quality & Acoustics Analyst I
Carleen Sawires Air Quality Analyst
Tim Witwer Air Quality & Acoustics Analyst III
Kyle Garcia Senior Associate I, Cultural Resources
Fatima Clark Associate III, Cultural Resources
Denise Kaneshiro Senior Graphic Designer
Aaron Guzman Senior Publications Specialist
Chapter 8. List of Preparers
General Plan 2045 and Zoning Code Update Project 8-2 S CH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Transportation
Fehr and Peers
600 Wilshire Boulevard, Suite 1050
Los Angeles, California 90017
John Muggridge, AICP Principal
Jinghua Xu, Ph.D., P.E. Senior Associate

City Council Meeting AgendaAugust 26, 2024

City Council Meeting Agenda
August 26, 2024