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29 RESOLUTION NO. 2024-R_____
A RESOLUTION OF THE CITY COUNCIL OF THE CITY OF CULVER CITY TO (1) CERTIFY THE FINAL ENVIRONMENTAL IMPACT REPORT SCH NO. 2022030144; (2) ADOPT A MITIGATION MONITORING PROGRAM; AND (3) ADOPT A STATEMENT OF
OVERRIDING CONSIDERATIONS BASED ON AN ASSESSMENT OF PROJECT BENEFITS AGAINST THE PROJECT’S SIGNIFICANT AND UNAVOIDABLE IMPACTS,
IN COMPLIANCE WITH THE CALIFORNIA ENVIRONMENTAL QUALITY ACT, FOR THE GENERAL PLAN 2045 AND ZONING CODE UPDATE
(Environmental Impact Report, P2022-0053-EIR)
WHEREAS, on January 28, 2019, the City Council initiated a comprehensive update to the General Plan, and on March 27, 2023 initiated an update to the Zoning Code and Zoning Code Map to implement the proposed Land Use Element of the General Plan 2045 and previously adopted 2021- 2029 Housing Element; and
WHEREAS, the Project is the adoption and implementation of a comprehensive update to the Culver City General Plan and amendments to the City’s Zoning Code to implement the General Plan 2045. The General Plan 2045 would provide a framework and vision to guide growth and development within the Planning Area through 2045. The General Plan 2045, along with the Zoning Code Update, would serve as the basis for planning-related decisions made by City staff, the Planning Commission, and the City Council.
By law, a general plan must be an integrated, internally cons istent statement of City policies.
The General Plan 2045 includes the seven required elements under Government Code Section 65302 as well as optional elements. The General Plan 2045 will include the following elements: Land Use and Community Design; Housing; Mobility; Conservation; Noise; Safety; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction; Infrastructure; Community Health and Environmental Justice; Economic Development; Arts, Culture, and Creative Economy; and Governance and Leadership. (The 2021-2029 Housing Element was adopted in August 2022.)
WHEREAS, to implement the proposed Project, approval of the following applications is required:
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29 1. General Plan Amendment P2022-0053-GP: to comprehensively update the City’s General Plan, covering the area within the City boundary and its Sphere of Influence; and
2. Z oni ng Code Amendment P2024-0186-ZCA: to update the Zoning Code to implement the proposed Land Use Element of the General Plan 2045 and previously adopted 2021-2029 Housing Element; and
3. Zoni ng Code Map Amendment P2024-0 186-ZCMA: to update the Zoning Code map to implement the proposed Land Use Map of the General Plan 2045; and WHEREAS, the California Environmental Quality Act of 1970, as amended (California Public Resources Code 21000, et.seq.; and California Code of Regulations, Title 14, Ch. 3 15000, et.seq.; collectively, “CEQA”), gives to the lead agency the responsibility for considering the effects of a project, both individual and collective, of all physical development activities involved when action is taken by a lead agency to approve a Project; and
WHEREAS, the City prepared an Initial Environmental Study (Initial Study) for the Project, which determined that the Project may have a significant effect on the environment and that an Environmental Impact Report must be prepared. The Initial Study determined that the following areas must be addressed in the Project EIR: Aesthetics, Air Quality (all but odors), Biological Resources, Cultural Resources (historical and archaeological resources), Energy, Geology and Soils, Greenhouse Gas Emissions, Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use and Planning, Mineral Resources, Noise, Population and Housing, Public Services, Recreation, Transportation, Tribal Cultural Resources, and Utilities and Service Systems; and WHEREAS, the City prepared a Notice of Preparation (“NOP”) of the Draft EIR, which was circulated to the affected agencies and the public, pursuant to CEQA for 30 days beginning on March 3, 2022, and numerous comments from agencies and the public were received in response. The City held a public scoping meeting on March 24, 2022, to obtain information from the public as to issues that should be addressed in the Draft EIR; and
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29 WHEREAS, the City prepared an additional Notice of Preparation of the Draft EIR after adding the Zoning Code Update to the project scope, which was circulated to the affected agencies and the public, pursuant to CEQA for 30 days beginning on February 15, 2024, and numerous comments from agencies and the public were received in response. The City held a second public scoping meeting on March 7, 2024, to obtain information from the public as to issues that should be addressed in the Draft EIR; and
WHEREAS, the City in accordance with provisions of CEQA Guidelines Sections 15085(a) and 15087(a), the City, serving as the Lead Agency: (1) prepared and transmitted a Notice of Completion (NOC) to the State Clearinghouse; (2) published a Notice of Availability (NOA) of a Draft EIR which indicated that the Draft EIR was available for public review at the City’s Current Planning Division; (3) provided copies of the NOA and Draft EIR to the Culver City Julian Dixon Library; (4) posted the NOA and the Draft EIR on the General Plan project website and the City’s Planning Division website:
https://www.pictureculvercity.com/environmental-review
https://www.culvercity.org/Services/Building-Development/K-CEQA-Information-Documents; (5) sent an NOA to the last known name and address of all organizations and individuals who previously requested such notice in writing or attended public meetings about the Project; and (6) filed the NOA with the County Clerk. The public review period commenced on March 28, 2024, and ended on May 13, 2024, for a total of 46 days.
WHEREAS, the City received numerous written and oral comments to the Draft EIR, prepared responses to those comments and determined no revisions to the Draft EIR are necessary . The proposed written responses to comments from public agencies received during the 46-day review period were provided to such agencies and the Final EIR was made available on July 17, 2024; and WHEREAS, the Final Environmental Impact Report (EIR), dated July 2024, includes the Draft EIR, dated March 2024, responses to written comments on the Draft EIR, responses to public testimony regarding the Draft EIR, issues raised during the public comment period, and the Mitigation Monitoring Program (MMP). The Final EIR was prepared and circulated in compliance with CEQA; and
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29 WHEREAS, on August 14, 2024, the Planning Commission held a duly noticed public meeting to receive public comment on the Final EIR and consider the proposed Final EIR. During the course of the public hearing, the Planning Commission considered staff and consultant presentations, written comments received from public agencies and the public, staff reports, Applicant presentations, information presented to the Planning Commission to assist its understanding of the Project, the Final EIR, CEQA Findings of Fact and Statement of Overriding C onsiderations and public comments and testimony on the Project. In addition, the Planning Commission considered the Final EIR prepared for the Project, including information provided in staff reports, information presented from experts and in public testimony, including letters submitted to the Planning Commission following the close of the public hearing before the Planning Commission, and other matters in the public record; and WHEREAS, following conclusion of the public discussion and thorough deliberation of the subject matter, the Planning Commission by a vote of 5 to 0 adopted Resolution 2024 -P009 recommending to the City Council (1) certification of the Final Impact Report SCH No. 2022030144; (2) adoption of CEQA findings and a mitigation monitoring program ; and (3) adoption of a statement of overriding considerations based on an assessment of Project benefits against the Project’s significant and unavoidable impacts, in compliance with the California Environmental Quality Act, for General Plan Amendment P2022-0053-GP, Zoning Code Amendment, and Zoning Code Map Amendment P2024 - 0186-ZCA; -ZCMA, for the Project; and
NOW, THEREFORE, THE CITY COUNCIL OF THE CITY OF CULVER CITY, CALIFORNIA, DOES HEREBY RESOLVE AS FOLLOWS:
SECTION 1. GENERAL FINDINGS. Pursuant to the foregoing recitations, following findings sre hereby made:
1. Based on the findings contained in the Initial Study prepared by the City, it was determined that the proposed Project may have a significant effect on the environment and an EIR is required.
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29 2. The Draft and Final EIRs, including the technical appendices and responses to comments, were prepared, circulated, and completed in compliance with CEQA.
3. Revisions to the Draft EIR and responses to comments, and other documents related to the Draft EIR have been made a part of or incorporated into the Final EIR.
4. The revisions made to the Draft EIR and incorporated into the Final EIR do not require recirculation of the Draft EIR based on the following:
a. No significant new information has been added that would deprive the public of a meaningful opportunity to comment on a substantial adverse environmental effect of the project, a feasible way to mitigate or avoid such an impact that the Applicant has declined to implement, or a feasible project alternative; b. The comment period did not result in new information that would have required corrections, changes, and/or clarification to points and information included in the Draft EIR;
c. There are not significant new environmental impacts resulting from the Project from a new mitigation measure proposed to be implemented;
d. There is no substantial increase in the severity of an environmental impact that has not been mitigated to a level of insignificance;
e.
The City has not declined to adopt any feasible project alternatives or mitigation measures, considerably different from others previously analyzed, that clearly lessen the environmental impacts of the Project; and
f. The Draft EIR is not fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment precluded.
5. The Final EIR accurately describes the Project and identifies the discretionary approvals necessary for the project as listed in the recitations above.
6. The Final EIR adequately analyzes all of the potentially significant environmental impacts of approv al of the Project, mitigation measures, environmental impacts and cumulative
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29 impacts which have been mitigated to a less than significant level, alternatives to the Project on the Project site, short-term and long-term impacts, growth inducing impacts, and significant and unavoidable impacts.
SECTION 2. CERTIFICATION FINDINGS. Based upon the above recitals and the entire record, including, without limitation, the Draft and Final EIR for the General Plan 2045 and Zoning Code Update Project, attached as Exhibit C of this Resolution, oral and written testimony and other evidence received, at the public hearings held on the Project and the Final EIR, the City Council further finds:
1. That the EIR for the Project is adequate, complete, and has been prepared in accordance with the California Environmental Quality Act (CEQA).
2. That the City Council has independently reviewed and considered the EIR in reaching its conclusions.
3. The City Council has reviewed and considered in the EIR as well as the whole of the administrative record and the evidence and testimony presented in this matter, prior to making its recommendation on the Project.
4. The City Council finds that the Final EIR reflects the decision-maker’s independent judgment and analysis.
5. The City Council makes the findings attached as Exhibit A to this resolution.
6. The Council finds that a mitigation monitoring program (MMP) has been prepared and is adopted to enforce the mitigation measures required by the Final EIR and Project approvals (Exhibit B).
7. The City Council adopts of a statement of overriding considerations based on an assessment of Project benefits against the Project’s significant and unavoidable impacts (Exhibit A). \\\
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29 APPROVED and ADOPTED this 26th day of August 2024.
________________________________________________
YASMINE-IMANI MCMORRIN, Mayor
City of Culver City, California
ATTESTED BY: APPROVED AS TO FORM:
__________________________________ _____________________________________ JEREMY BOCCHINO, City Clerk HEATHER BAKER, City Attorney
1 CEQA Findings of Fact and Statement
of Overriding Considerations
Findings Required by CEQA
Pursuant to Public Resources Code Section 21081 and CEQA Guidelines Section 15091 (Title 14 Cal. Code Regs. § 15091), no public agency shall approve or carry out a project where an EIR has been certified which identifies one or more significant effects on the environment that would occur if the project is approved or carried out, unless the public agency makes one or more findings for each of those significant effects, accompanied by a brief explanation of the rationale of each finding. The possible findings, which must be supported by substantial evidence in the record, are:
(1) Changes or alterations have been required in, or incorporated into, the project whic h
m
itigate or avoid the significant effects on the environment. (2) Changes or alterations are within the responsibility and jurisdiction of another public agency and have been, or can and should be, adopted by that other agency. (3) Specific economic, legal, social, technological, or other considerations make infeasible the mitigation measures or project alternatives identified in the EIR.
These findings do not attempt to describe the full analysis contained in the Draft Program EIR (PEIR) and Final PEIR, collectively referred to as the PEIR. Instead, a full explanation of these environmental findings and conclusions can be found in the PEIR, and these findings hereby incorporate by reference the discussion and analyses in the PEIR supporting the PEIR’s determination regarding the Project’s impacts and mitigation measures designed to address those impacts.
CEQA requires that the lead agency adopt mitigation measures or alternatives, where feasible, to substantially lessen or avoid significant environmental impacts that would otherwise occur.
Project modification or alternatives are not required, however, where such changes are infeasible or where the responsibility for modifying the project lies with some other agency (CEQA Guidelines, §15091(a), (b)). With respect to a project for which significant impacts are not avoided or substantially lessened either through the adoption of feasible mitigation measures or feasible environmentally superior alternative, a public agency, after adopting proper findings, may nevertheless approve the project if the agency first adopts a statement of overriding considerations setting forth the specific reasons why the agency found that the project’s “benefits” rendered “acceptable” its “unavoidable adverse environmental effects.” (CEQA Guidelines, §§15093, 15043(b); see also Pub. Resources Code, §21081(b)).
EXHIBIT A
Findings of Fact Required by CEQA
2 Final PEIR and City Proceedings
Pursuant to CEQA Guidelines Section 15088, the City reviewed all comments received during the Draft PEIR review period and provided a written response to each comment in the Final PEIR. The Final PEIR dated July 2024, consists of the following documents:
• Draft PEIR and Technical Appendices dated March 2024
• Final PEIR dated July 2024, which includes:
– A list of persons, organizations, and public agencies that commented on the Draft PEIR, as well as the verbatim comments received on the Draft PEIR; – Written responses to comments;
– Corrections and additions to the Draft PEIR; and
– Mitigation Monitoring Program (MMP).
The Final PEIR document was posted for viewing and download with the previously posted Draft PEIR prior to the City’s consideration of the Final PEIR and Project recommendations at https://www.pictureculvercity.com/environmental-review
. In addition, a hard copy can be viewed
at City Hall by appointment during normal business hours. In addition, pursuant to CEQA Guidelines Section 15088(b), responses were sent to all public agencies that made comments on the Draft PEIR at least 10 days prior to certification of the Final PEIR. All individuals that commented on the Draft PEIR and provided a physical or email address were notified of completion of the Final PEIR.
Record of Proceedings and Custodian of Documents
For purposes of CEQA and these Findings, the Administrative Record of Proceedings for the Project includes, but is not limited to, the following documents:
• The Draft General Plan 2045 and Zoning Code Update and all related documents; • NOPs, NOA for the Draft EIR, and all other public notices issued by the City in conjunction with the Project;
• All written comments submitted by agencies and members of the public during the Draft EIR public review comment period;
• All responses to written comments submitted by agencies and members of the public during the Draft EIR public review comment period;
• All documents, studies, EIRs, or other materials incorporated by reference in the Draft EIR, and Final EIR, including the MMP;
• Matters of common knowledge to the City, including, but not limited to, federal, State, and local laws and regulations;
• All staff reports and related documents prepared by the City and written testimony or documents submitted by any person relevant to any findings or statement of overriding considerations adopted by the City pursuant to CEQA;
Findings of Fact Required by CEQA
3 • Any documents expressly cited in these Findings of Fact; and • Any and all other materials required for the record of proceedings by PRC Section 21167.6(e).
The documents and other materials that constitute the record of proceedings on which the Project Findings are based are located at the City in the Advance Planning Division Community Development Department, Planning Division located at: Culver City Hall, 9770 Culver Boulevard, 2
nd Floor, Culver City, CA 90232. The custodian for these documents is the City’s Advance Planning Director. This information is provided in compliance with PRC Section 21081.6(a)(2) and CEQA Guidelines Section 15091(e).
Project Objectives
CEQA Guidelines Section 15124(b) states that a project description shall contain “a statement of the objectives sought by the proposed project.” In addition, CEQA Guidelines Section 15124(b) further states that “the statement of objectives should include the underlying purpose of the project.” 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 to provide the amendments necessary to the Zoning Code to implement the General Plan 2045.
Core values include equity and inclusion; sustainability; innovation and creativity; and compassion and community. At the outset of the General Plan 2045 process, the following Guiding Principles were developed, which are specific and objective benchmarks that guided the development of the General Plan 2045:
• 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;
Findings of Fact Required by CEQA
4 • Cultivate social connections between residents, workers, businesses, and visitors through urban design that sustains and revitalizes the public realm, creates great places to gather, adapts to a changing climate, and promotes public safety; • Be a creative and proactive leader in solving regional, state, and national challenges around issues like housing, mobility, public safety, equity, climate change, and environmental pollution and disruption;
• Elevate community health and health equity through new, improved, and well-maintained public amenities that are accessible to all—like parks, sport courts and fields, gathering places, healthy and affordable food, natural resources, and community services—that allow people of all ages and abilities to thrive physically, socially, and mentally; • Sustain arts and culture in Culver City, including visual, performing, literary, and culinary arts. Support the continued preservation of historic and cultural resources in Culver City; • 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.
Project Description
Culver City (City) is located in the western area of Los Angeles County in Southern California and comprises about 5 square miles. The City is bounded by the City of Los Angeles to the north, west, and south, and by unincorporated areas of Los Angeles County along its eastern boundary.
The Project includes a comprehensive update to the General Plan, Picture Culver City: General Plan 2045 (General Plan 2045) and amendments to the City’s Zoning Code that are necessary to implement the General Plan 2045. These collectively are referred to as the Project. The General Plan Planning Area includes the city of Culver City and its unincorporated Sphere of Influence (SOI). The Planning Area The SOI is located to the east of the City Boundary in the Baldwin Hills area of Los Angeles County (see Draft PEIR Figure 2-2).
By law, a general plan must be an integrated, internally consistent statement of City policies.
Government Code Section 65302 requires that a general plan include the following seven elements: Land Use, Circulation, Housing, Conservation, Open Space, Noise, and Safety.
Findings of Fact Required by CEQA
5 Senate Bill (SB) 1000 and Government Code Section 65302 require that since disadvantaged communities have been identified within the City, the Plan must also address Environmental Justice either as a standalone element or integrating related goals, policies, and objectives throughout other elements. The General Plan 2045 includes a Community Health and Environmental Justice element. Additional elements may be included as well, at the discretion of the City. The General Plan 2045 includes the following elements: Land Use and Community Design; Mobility; Conservation; Noise; Safety; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction, Infrastructure, Community Health and Environmental Justice; Economic Development; Arts, Culture, and Creative Economy; and Governance and Leadership. The City adopted the 2021-2029 Housing Element in August 2022. The Project would serve to implement the adopted Housing Element through the amendments to the Land Use Map and the Zoning Code Update.
The General Plan 2045 would provide a framework and vision to guide growth and development within the Planning Area. Together with the Zoning Code Update, the 2045 General Plan would serve as the basis for planning-related decisions made by City staff, the Planning Commission, and the City Council. Growth projections associated with the Project include an increase of 11,310 households with an associated increase of 21,600 persons and an increase of 16,260 jobs (see Draft PEIR Table 2-3).
Land uses within the Planning Area can be broken down into four main categories of development: activity centers, commercial corridors, residential neighborhoods, and parks/open space. New development within the city would primarily occur on parcels that already contain some existing homes or businesses. The City’s primary approach to accommodating growth is to provide strategies for thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors.
The Project seeks to intensify and mix land uses on key segments of the commercial corridors, and to improve pedestrian experiences along the City’s commercial corridors through parking management strategies, active street frontage guidelines, and public realm improvements. To support the community’s housing vision, the land use vision allows for new residential and mixed-use development within the City’s industrial areas.
California Government Code Section 65860(a) requires that a jurisdiction’s zoning ordinance be consistent with its General Plan or any updates to its General Plan. In light of the proposed changes in the General Plan 2045, updates to the Zoning Code are necessary for consistency with the land use designations in the General Plan 2045. The proposed Zoning Code Update would implement the new vision in the General Plan 2045, changing from single-use commercial and industrial districts to mixed-use zones.
Findings Regarding the Potential Environmental Effects of the Project
The following sections set forth the City Council’s Findings regarding significant environmental impacts and identifies the mitigation measures proposed to address the significant impacts. The
Findings of Fact Required by CEQA
6 mitigation measures are provided in their entirety in the Mitigation Monitoring Program (MMP) that is provided as an attachment to these Findings and Statement of Overriding Considerations.
The PEIR addresses at a program level the direct, indirect, and cumulative environmental effects of construction and operation activities associated with development that will occur under the Project. These findings provide the written analysis and conclusions of the City Council regarding the environmental impacts of the Project, the mitigation measures included as part of the PEIR and adopted by the City Council as part of the Project, and the alternatives that have been rejected as infeasible. These findings refer to the analyses contained in the PEIR to avoid duplication and redundancy.
Findings of No Impact
The environmental effects listed below were identified as not potentially significant in the Draft PEIR as well as the Initial Study contained in Draft PEIR Appendix A. Refer to Draft PEIR Section 6.6, Effects Found Not to Be Significant and Section 4.3, Impact BIO-2. The City Council finds that the PEIR and the record of proceedings in this matter do not identify or contain substantial evidence identifying significant environmental effects of the Project with respect to the areas listed below.
1. Aesthetics (substantially damage scenic resources, including, but not limited to, trees, rock outcroppings, and historic buildings within a state scenic highway)
2. Agricultural and Forest Resources
3. Air Quality (other emissions, such as those leading to odors)
4. Biological Resources (riparian habitat or sensitive natural habitat; conflict with an adopted Habitat Conservation Plan, Natural Community Conservation Plan, or other such approved plan)
5. Cultural Resources (human remains)
6. Geology and Soils (soils incapable of adequately supporting the use of septic tanks or alternative wastewater disposal systems)
7. Hazards and Hazardous Materials (within an airport land use plan or within two miles of public airport or public use airport)
8. Noise (within the vicinity of a private air strip or airport land use plan or if no adopted plan within two miles of public airport or public use airport) Findings of Less than Significant Prior to Mitigation
This section sets forth the environmental impacts determined to have less-than-significant impact in the Draft PEIR prior to mitigation. The section provides reference to the relevant impact statement in the Draft PEIR and includes a summary of the relevant cumulative analysis for the specific impact statements. The City Council finds that although the following environmental effects were identified in the Initial significant, the PEIR and the record of
Findings of Fact Required by CEQA
7 proceedings do not identify or contain substantial evidence identifying significant environmental effects of the Project with respect to the areas listed below.
Aesthetics
Draft PEIR Section 4.1 evaluates the potential aesthetics impacts that could result from implementation of the Project.
Scenic Vistas (Impact AES-1)
Facts/Effects: While the Planning Area does not have any designated scenic vistas, the Blair Hills/Baldwin Hills area, including the Baldwin Hills Scenic Overlook, offers expansive, long- range views. In addition, there are view corridors from Playa Street traveling northeast towards Overland Avenue; Elenda Street traveling northwest towards Culver Boulevard; and Jefferson Boulevard traveling south along Ballona Creek. The Planning Area is mainly characterized by urban environments, and as a result, scenic vistas are mostly limited to open space, vacant natural areas, and parks.
Due to the highly urbanized nature of the Planning Area, the majority of the future development under the General Plan 2045 will primarily occur on parcels that already contain existing development. General Plan 2045 policies 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. While the Zoning Code Update will result in increases in height in some areas of the City, future development projects that occur under the Project will be subject to development and planning review and will be required to comply with other applicable regulations regarding aesthetic qualities that are established to protect visual resources, such as building heights, building setbacks, lighting, landscaping, and signage. Thus, compliance with the applicable policies and development standards designed to minimize effects to scenic vistas will ensure that impacts will be less than significant.
Conflict with Applicable Regulations Governing Scenic Quality (Impact AES-2) Facts/Effects: While the General Plan 2045 would increase densities and intensities of land uses, the majority of the proposed changes would occur within Culver City with limited land use changes occurring within the SOI. General Plan 2045 policies 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 provides development standards, including setbacks, floor area ratio, building heights and lot coverage that establish the form and mass of future buildings that will occur under the Project. While some increase in building height would occur in certain areas of the city, the maximum building heights throughout the city would be 56 feet, consistent with the initiative approved by City Council in 1990. Future development would be reviewed by the City for compliance with applicable requirements prior to project approval and issuance of a building permit. Therefore, impacts will be less than significant.
Findings of Fact Required by CEQA
8 Light and Glare (Impact AES-3)
Facts/Effects: Future development under the Project will create new sources of light and glare.
New development will primarily occur on parcels that already contain some development since the primary approach to accommodating growth is through infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The General Plan 2045 includes policies requiring the use of low intensity and shielded lighting to reduce the amount of light reaching sensitive habitat, ensure neighborhood compatibility and reduce light and glare impacts in and around the Planning Area. In addition, future development will be required to comply with applicable lighting regulations and standards, that include directing light to be oriented downward and to avoid any light spillover to adjacent properties; requiring that permanently installed lighting shall not blink, flash, or be of unusually high intensity or brightness; landscaping and pedestrian walkway lights shall be low profile; and that limiting the height of freestanding light poles and luminaires.
Therefore, the Project will result in less than significant light and glare impacts.
Cumulative Aesthetics Impacts
Facts/Effects: No state scenic highway is located within the southern region of Los Angeles County, including Culver City, and thus reasonably foreseeable growth within the central southern region of Los Angeles County, including Culver City, will not substantially damage scenic resources within the corridor of a state scenic highway. The area is generally urban in character. Development to accommodate future residents and jobs may impact scenic vistas if it were to encroach on open hillsides. Various proposed policies including those that address open space preservation and sensitive transitions between new and existing development would ensure that scenic quality is maintained in the City. Development in surrounding jurisdictions will be required to comply with General Plan policies and development standards addressing scenic resources. With regard to light and glare, the Project will not contribute to a cumulative significant impact since applicable policies and standards regarding lighting will reduce impacts to less than significant. Therefore, the Project will result in less-than-significant cumulative aesthetics impacts.
Biological Resources
Draft PEIR Section 4.3 evaluates the potential impacts to biological resources that could result from implementation of the Project.
Adversely Affect State or Federally Protected Wetlands (Impact BIO-3) Facts/Effects: Based on the habitats present within the Planning Area and review of the National Wetlands Inventory, there are no wetlands present within the Planning Area. Therefore, the General Plan 2045 and Zoning Code Update will have no effect on these resources.
However, Ballona Creek traverses the City and the planned Ballona Creek Revitalization Project will enhance the restoration and use of Ballona Creek. Restoration/enhancement activities and/or the proposed upgrades to recreational facilities along Ballona Creek could result in the removal or disturbance of the concrete-lined channel or the channel banks. These activities may require Clean Water Act permits from the U.S. Army Corps of Engineers and the Regional
Findings of Fact Required by CEQA
9 Water Quality Control Board (RWQCB) and/or a streambed alteration agreement from the California Department of Fish and Wildlife (CDFW), which would be obtained from the City prior to any work, and permit conditions would be implemented. Therefore, impacts regarding state or federally protected wetlands will be less than significant.
Conflict with Tree Preservation Policy or Ordinance (Impact BIO-5) Facts/Effects: Future development that will occur under the Project will 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, the General Plan 2045 contains policies that promotes a strong urban forest and the maintenance of landscaping. Therefore, impacts will be less than significant.
Cumulative Biological Resource Impacts
Facts/Effects: The Project will result in less than significant impacts with regard to adverse effects to state or federally protected wetlands and will not conflict with tree preservation policies or ordinances. Cumulative development will comply with applicable requirements regarding these biological resources. Therefore, the Project will result in less than significant cumulative impacts related to biological resources.
Energy
Wasteful, Inefficient, or Unnecessary Consumption of Energy Resources (Impact ENG-1)
Facts/Effects: During construction energy will be used only for necessary on-site activities and to transport construction materials and demolition debris to, from, and within the city. Idling restrictions and the use of cleaner, energy-efficient equipment and fuels will 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 will not result in the wasteful, inefficient, and unnecessary consumption of energy, and this impact will be less than significant.
The net increase in energy that will occur from new development under the Project will be served by existing infrastructure capacity for electricity, natural gas, and transportation energy.
Therefore, new developments will not result in the wasteful, inefficient, and unnecessary consumption of energy, and this impact will be less than significant.
Conflict with State or Local Renewable Energy Plan (Impact ENG-2) Facts/Effects: The construction of new development that could occur under the Project will utilize construction contractors who must demonstrate compliance with applicable regulations, such as the U.S. Environmental Protection Agency (USEPA) and National Highway Traffic Safety Administration fuel-efficiency standards for medium- and heavy-duty trucks, and California Air Resource Board (CARB) regulations regarding heavy-duty truck idling limits and replacing older, less efficient equipment with newer, more efficient models. Operation of new development under the Project will be consistent with the relevant goals and policies from the General Plan 2045 that are designed to encourage development that results in the efficient use
Findings of Fact Required by CEQA
10 of energy resources. Additionally, new development will comply with Title 24 requirements and CALGreen to reduce energy consumption. Therefore, future development under the Project will result in a less than significant impact related to conflicting or obstructing a state or local plan for renewable energy or energy efficiency during construction and/or operation.
Cumulative Energy Impacts
Facts/Effects: All cumulative development projects and development under the Project will be required to comply with CALGreen and Title 24 energy efficiency requirements and other regulations, which will reduce energy consumption by promoting energy efficiency and the use of renewable energy, and incorporate mitigation measures, if applicable. As such, the Project will not result in the wasteful, inefficient, and unnecessary consumption of energy nor will it result in a cumulatively considerable contribution to energy use and impacts will be less than significant.
The Project, as well as other cumulative development projects will be required to demonstrate consistency with federal and state fuel efficiency goals and incorporate, if applicable, any mitigation measures as required under CEQA. The Project will be consistent with the guidance provided in the Southern California Association of Government (SCAG) 2020-2045 Regional Transportation Plan and Sustainable Communities Strategy (RTP/SCS) to reduce transportation fuel and vehicle miles travelled (VMT). As the Project will incorporate land use characteristics consistent with state goals for reducing VMT, the Project will not have a cumulatively considerable impact related to transportation energy, and impacts will be less than significant.
Geology and Soils
Draft PEIR Section 4.6 evaluates the potential impacts to geology and soils that could result from implementation of the Project.
Geologic Hazards: Earthquake Fault; Seismic Ground Shaking; Seismic-Related Ground Failure; Landslide (Impact GEO-1)
Facts/Effects: The Project will accommodate growth and development within areas potentially subject to surface rupture within an Alquist-Priolo fault zone, strong seismic shaking, seismic- related ground failure and landslides. However, future development that occurs under the Project will be consistent with applicable goals and policies as well as applicable laws, regulations, and standards related to seismic hazards. In addition, site-specific geotechnical investigations will address localized geologic hazards. Therefore, impacts will be less than significant.
Soil Erosion or Loss of Topsoil (Impact GEO-2)
Facts/Effects: Construction activities that disturb one or more acres of land surface are subject to the National Pollutant Discharge Elimination System (NPDES) General Permit for Stormwater Discharges Associated with Construction and Land Disturbance Activities (Order No. 2022- 0057-DWQ) adopted by the State Water Resources Control Board (SWRCB). Permit compliance includes implementation of a storm water pollution prevention plan. In addition, the General Plan 2045 includes goals and policies that require the use of best management
Findings of Fact Required by CEQA
11 practices (BMPs) to control soil erosion during and after ground-disturbing activities and geotechnical reports for projects requiring grading permits. Therefore, impacts related to soil erosion and topsoil loss will be less than significant.
Unstable Soils (Impact GEO-3)
Facts/Effects: Certain geologic units present in the Planning Area have the potential for landslides, slope instability, liquefaction, and liquefaction-induced lateral spreading.
Development allowed under the Project could be located on geologic units or soils that are unstable, or that could become unstable, and result in geologic hazards if not addressed appropriately. The potential hazards of unstable soil or geologic units will be addressed largely through the integration of geotechnical information in the planning and design process for future development to determine the local soil suitability for specific projects in accordance with standard industry practices and state-provided requirements. In addition, future projects will comply with applicable requirements related to unstable geologic units or soils. As such, implementation of the Project will result in a less than significant impact related to unstable geologic units or soils.
Expansive Soils (Impact GEO-4)
Facts/Effects: Expansive soils within the Planning Area are generally located around Baldwin Hills due to the high clay content. Future development under the Project will be required to comply with all appliable design, engineering, and construction standards and requirements of the California Building Code (CBC) within the Culver City Municipal Code (CMC), including the Grading Ordinance. Therefore, future development under the Project will not result in geologic hazards associated with expansive soils. As such, implementation of the Project will result in a less than significant impact related to unstable expansive soils.
Cumulative Geology and Soils Impacts
Facts/Effects: Each development site has unique geologic considerations that would be subject to site development and construction standards. Potential cumulative impacts relating to geology and soils would be minimized through preparation of geotechnical reports, compliance with code requirements, and implementation of appropriate construction methods. Therefore, future development including growth anticipated under the General Plan 2045, will not result in a significant cumulative impact with respect to geology and soils.
Hazards and Hazardous Materials
Draft PEIR Section 4.8 evaluates the potential impacts relative to hazards and hazardous materials that could result from implementation of the Project.
Routine Use, Transportation, and Disposal of Hazardous Materials (Impact HAZ-1) Facts/Effects: Future development that will occur under the Project could involve demolition of older buildings that contain asbestos containing materials and lead based paint. In addition, operation of future development could increase the amount of hazardous materials being transported, used, and stored in the city. However, the construction and operation of future development will comply with applicable regulations set forth by Culver City, USEPA,
Findings of Fact Required by CEQA
12 Occupational Safety and Health Administration (OSHA), Department of Toxic Substances Control (DTSC), Caltrans, SCQAMD, and other agencies. The City will review development applications for subsequent development under the Project for compliance with the applicable regulations, policies of the General Plan 2045, the City’s Municipal code, and the mitigation measures referenced in other sections of the PEIR. Therefore, the Project will result in a less than significant impact related to the routine use, transport, or disposal of hazardous materials.
Accident and Upset Conditions (Impact HAZ-2)
Facts/Effects: Future development under the Project will be required to comply with applicable regulations and General Plan 2045 policies during construction activities, which will ensure that future development will not create a significant hazard to the public or environment through reasonably foreseeable upset and accident conditions involving release of hazardous materials into the environment. In addition, all new development will be required to comply with applicable regulations for hazardous materials adopted by USEPA, OSHA, DTSC, Caltrans, CHP, SCAQMD, and other agencies. Therefore, the Project will result in a less than significant impact related to accident and upset conditions.
Emit Hazardous Materials within 0.25 Mile of a School (Impact HAZ-3) Facts/Effects: The Project will be required to comply with existing federal, State, and local regulations related to hazardous materials, which will ensure that future development allowed under the Project will not emit hazardous emissions or handle hazardous or acutely hazardous materials, substances, or waste within one-quarter mile of an existing or proposed school.
Future development (including redevelopment of existing developed sites) allowed under the General Plan 2045 will be required to store, manage, and dispose of the materials in accordance with applicable requirements. Therefore, the Project will result in a less than significant impact related to emitting hazardous materials within one-quarter mile of a school.
Hazardous Materials Sites (Impact HAZ-4)
Facts/Effects: There are known contaminated properties, some of which have been remediated and some that are undergoing remediation, and other properties could be added if contamination is discovered. Thus, future development allowed under the Project could occur on a contaminated site. As discussed above in Impact HAZ-1, HAZ-2, and HAZ-3, any development on a contaminated site will be required to comply with applicable regulations that will ensure that the development does not create a significant hazard to the public or the environment. Therefore, the Project will result in a less than significant impact related to hazardous materials sites.
Impairment or Interference with Emergency Response Plan (Impact HAZ-5) Facts/Effects: Continued growth and development associated with implementation of the Project has the potential to strain the emergency response and recovery capabilities of federal, State, and local governments. However, the Los Angeles County Operational Area Emergency Response Plan provides the framework for responding to major emergencies or disasters. In addition, the City’s Multi-Jurisdictional Hazard Mitigation Plan (MJHMP) provides a strategy for reducing the City's vulnerability to the impacts of natural hazard events such as earthquakes,
Findings of Fact Required by CEQA
13 flood, and wildfire. The General Plan 2045 contains policies that aim to continually strengthen emergency response. The Project would not interfere with implementation of the MJHMP or of agencies that respond in the event of a disaster or major emergency in Culver City. Therefore, the Project will result in a less than significant impact related to impairment or interference with an emergency response plan.
Wildland Fire Hazards (Impact HAZ-6)
Facts/Effects: 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 Very High Fire Hazard Severity Zone (VHFHSZ). Future development that will occur under the Project will be required to adhere to building and fire codes and review by Culver City Fire Department (CCFD) to reduce fire hazards. Compliance with applicable requirements and review by CCFD will ensure that people or structures are not exposed, either directly or indirectly, to a significant risk of loss, injury, or death involving wildland fires. Therefore, the Project will result in a less than significant impact related to wildland fire hazards.
Cumulative Hazards and Hazardous Materials Analysis
Facts/Effects: As with the Project, cumulative projects in the surrounding area will be subject to the requirements and regulations addressing hazardous materials, emergency response, and wildland fires. The Project will not contribute to a significant cumulative impact relative to these issue areas.
Hydrology and Water Quality
Draft PEIR Section 4.9 evaluates the potential impacts to hydrology and water quality that could result from implementation of the Project.
Violate Water Quality Standards or Waste Discharge Requirements (Impact HYD-1) Facts/Effects: The Planning Area is generally a developed, urban environment with limited vacant parcels, where the sources and types of stormwater pollutants are typical of an urban setting. Under the Project an increase in impervious surfaces could occur, which could increase the amount of urban pollution in storm water runoff. In addition, other pollutant sources from past uses and disposal practices as well as chemicals and fertilizers applied to landscaping could result. Construction and operation of future development that will occur under the Project will comply with all applicable laws, regulations, and standards related to water quality and waste discharge, including the General NPDES Permit for Discharges of Groundwater from Construction and Project Dewatering Permit No. CAG994004, the Permit Order No. R4-2018- 0125 issued by LARWQCB, and the Los Angeles MS4 Permit No. Order No. R4-2021-0105/ NPDES Permit No. CAS004004, as may be updated over time. In addition, future projects will comply with policies in the General Plan 2045 and requirements related to water quality of the CCMC. Therefore, the Project will result in less than significant impacts related to violating water quality standards or waste discharge requirements.
Findings of Fact Required by CEQA
14 Groundwater Supplies and Groundwater Recharge (Impact HYD-2) Facts/Effects: The groundwater supplies used by the Los Angeles Department of Water and Power (LADWP) and the Golden State Water Company (GSWC), water providers for the City, are regulated. Since there are limits on the amount of groundwater each provider can pump for potable use, the potential for overdraft is limited. With regard to recharge, while an increase in impervious surfaces will likely occur, the General Plan 2045 will maintain and expand parks and open space resources. In addition, future development under the Project will not preclude established groundwater recharge processes for the three underlying groundwater basins within the Planning Area. Lastly, an engineering geology report required by the California Building Code (CBC) regulates development that requires grading to submit an engineering geology report, which would include information about existing groundwater supplies and potential impacts to groundwater supplies. Therefore, the Project will result in less than significant impacts related to groundwater supplies and groundwater recharge.
Drainage Patterns (Impact HYD-3)
Facts/Effects: Ballona Creek is a major drainage that flows through the Planning Area.
Implementation of the General Plan 2045 will not directly alter the course of Ballona Creek, or any other streams or rivers. Future development will be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s sewer system, such as the Los Angeles County MS4 Permit (Order No. R4-2021-0105, NPDES Permit No. CAS004004), Los Angeles County LID Ordinance, the CCMC (Sections 5.05.010 and 5.05.040), and the City’s SUSMP and SWQMP. Adherence to the regional and City’s permits, regulations, and ordinances will limit surface runoff from development under the General Plan 2045, reducing siltation and erosion. The Project will not substantially alter the existing drainage pattern of the Planning Area in a manner that would result in substantial erosion or siltation on- or off-site; substantially increase the rate or amount of surface runoff in a manner which would result in flooding on- or offsite; create or contribute runoff water which would exceed the capacity of existing or planned stormwater drainage systems or provide substantial additional sources of polluted runoff; or impede or redirect flood flows. Future development under the Project would be required to comply with the requirements related to stormwater runoff of CCMC and the City’s SUSMP. Therefore, impacts related to drainage patterns will be less than significant.
Release of Pollutant from Inundation by Flood, Tsunami, or Seiche (Impact HYD-4) Facts/Effects: The Planning Area, which is located approximately 1.5 miles inland from nearby coastal areas, 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. Future development facilitated under the Project will be required to comply with all applicable laws, regulations, and permits related to drainage and flooding hazards, which will reduce the risk of onsite flooding and release of pollutants. Therefore, impacts associated with release of pollutants from inundation by flood, tsunami, or seiche will be less than significant.
Findings of Fact Required by CEQA
15 Conflict with Water Quality Control Plan or Sustainable Groundwater Management Plan (Impact HYD-5)
Facts/Effects: Implementation of the Project will not degrade water quality due to compliance with all applicable federal, state, regional and local water quality laws, regulations, and permits.
The General Plan 2045 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. Implementation of the General Plan 2045 will not interfere with or conflict with the Groundwater Sustainability Plan since the City is a member of Santa Monica Basin Groundwater Sustainability Agency and the Project includes various implementation actions that support the Groundwater Sustainability Plan, including incentivizing and mandating stormwater infiltration where feasible and participating in regional coordination regarding aquifer recharge and sustainable ground water supply. Thus, the Project will not conflict with the Santa Monica Subbasin Groundwater Sustainability Plan and impacts will be less than significant.
Cumulative Hydrology and Water Quality Impacts
Facts/Effects: Future development in Ballona Creek and Marina Del Rey Watersheds, including development anticipated under the Project, will be subject to the requirements of the NPDES program and other federal, State, and regional regulations such as pollution control ordinances. Adherence to these regulations will minimize degradation of water quality associated with the construction and operation of individual projects. As such, the cumulative impact with respect to water quality will be considered less than significant.
The Santa Monica Subbasin, West Coast Basin, and Central Basin are regulated, and thus have limits on the amount of groundwater that is pumped for potable use. Therefore, the cumulative impact with respect to depletion of groundwater supplies and groundwater recharge will be less than significant.
As the Planning Area and much of the County is heavily urbanized, future development will not involve the direct alteration of existing streams, rivers, or other drainage patterns. All future development will be subject to floodplain management and stormwater and urban runoff pollution control ordinances for each jurisdiction that will prevent flood damage resulting from hydromodification. Therefore, the cumulative impact with respect to storm drainage will be considered less than significant.
Cumulative growth and development throughout the area has resulted in the introduction of new structures and impervious surfaces that increased stormwater runoff, leading to increased flood hazards associated with the water levels in Ballona Creek. Future development in the area, including growth anticipated under the Project, will be subject to floodplain management and stormwater and urban runoff pollution control ordinances for each jurisdiction that will prevent flooding. Therefore, the cumulative impact with respect to flooding will be considered less than significant.
Findings of Fact Required by CEQA
16 Land Use and Planning
Draft PEIR Section 4.10 evaluates the potential impacts relative to land use and planning that could result from implementation of the Project.
Physically Divide an Established Community (Impact LU-1) Facts/Effects: Implementation of the Project will 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 will not change under the General Plan 2045 and the changes focus density in areas that will not result in a division of a community. The Project will not physically divide an established community. Therefore, the Project will result in a less than significant impact.
Consistency with Applicable Land Use Plans (Impact LU-2) Facts/Effects: The Project will not conflict with California Government Code Section 65302, SCAG’s 2020 RTP/SCS, the Complete Streets Act (AB 1358), the 6th cycle RHNA, Culver City and Culver City Unified School District Multi-Jurisdictional Hazard Mitigation Plan, the Culver City Bicycle & Pedestrian Action Plan, or the Culver City Urban Forest Master Plan. The Project will not conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the Project will result in a less than significant impact.
Cumulative Land Use Impacts
Facts/Effects: Future development in the area, including growth anticipated under the proposed General Plan 2045, will not physically divide an established community or conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect, as future development in each jurisdiction will be required to be consistent with each jurisdiction’s General Plan and zoning code. In addition, future development in the western area of Los Angeles County will be required to be consistent with regional plans such as SCAG’s Connect SoCal Plan and the RHNA. Therefore, future development in the western area of Los Angeles County, including growth anticipated under the General Plan 2045, will have a less-than-significant cumulative impact with respect to land use and planning.
Mineral Resources
Draft PEIR Section 4.11 evaluates the potential impacts relative to mineral resources that could result from implementation of the Project.
Loss of Known Mineral Resources (Impact MIN-1) and Loss of Mineral Resources Recovery Site (Impact MIN-2)
Facts/Effects: Since the Planning Area is not within an identified Mineral Resource Zone (MRZ) for significant mineral resources, future growth resulting from implementation of the Project will not impact regionally important aggregate material resources. No impact to aggregate mineral resources would occur. With regard to the IOF, while there is ongoing oil and gas production within the City’s portion of the IOF, the City adopted the Oil Termination Ordinance, which
Findings of Fact Required by CEQA
17 requires the closure of the City’s portion of the IOF. The General Plan 2045 will not change the existing open space land use designation for the IOF that lies within the Planning Area. This designation, which allows open space, recreational, and/or park development, will ensure the presence and access to the existing oil and gas deposits will remain. Therefore, the Project will not result in the loss of the regionally or locally important oil and gas resources and impacts to mineral resources will be less than significant.
Cumulative Mineral Resources Analysis
Facts/Effects: The Project will have no impact related to non-fuel mineral resources. With regard to the IOF, the Project will preserve access to the existing oil and gas resources and will not contribute to a cumulatively considerable impact related to the loss of availability of mineral resources.
Population and Housing
Draft PEIR Section 4.13 evaluates the potential impacts relative to population and housing that could result from implementation of the Project.
Induce Unplanned Population Growth (Impact POP-1)
Facts/Effects: The projected growth that would occur as a result of the Project both in housing and employment is considered planned growth. The Project will accommodate the 6th cycle Regional Housing Needs Assessment (RHNA) allocation of 3,341 new units as well as future cycles through 2045. The Project 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. New residential opportunities will be a result of targeted residential and mixed-use development in activity centers and along commercial corridors to provide housing near jobs, neighborhood amenities, and health care facilities. This type of infill development focuses on redevelopment and revitalization of areas already served by infrastructure and will not require extensions of roads or other infrastructure. While an increase in employment opportunities within the Planning Area is expected during the 2045 planning horizon, the Project will ensure that housing needs, including future housing needs for the projected increase in employment, will be met. Therefore, the Project will not induce substantial unplanned population growth, either directly or indirectly and impacts will be less than significant.
Require Construction of New Housing (Impact POP-2)
Facts/Effects: The Project will provide infill development opportunities in vacant and underutilized areas in the city, while seeking to preserve existing neighborhoods. The Project will increase the overall number of dwelling units in the city as well as include policies that seek to ensure equity and protect diversity in the city’s communities. Therefore, the Project will not displace substantial numbers of existing people or housing, necessitating the construction of replacement housing elsewhere and impacts will be less than significant.
Findings of Fact Required by CEQA
18 Cumulative Population and Housing Analysis
Facts/Effects: Future development in westside region of Los Angeles County, including growth anticipated under the Project, will not induce substantial unplanned population growth in the area as future development will have to be consistent with the general plans and zoning codes of local jurisdictions in the area, and therefore will not be unplanned. In addition, future development in the westside region will be required to follow existing state law governing relocation of residents. Therefore, the Project will not contribute to cumulative impacts related to population and housing, and cumulative impacts will be less than significant.
Public Services
Draft PEIR Section 4.14 evaluates the potential impacts relative to public services that could result from implementation of the Project.
Fire Protection (Impact PS-1.i)
Facts/Effects: Growth anticipated as a result of the Project will increase the demand for fire protection services. However, the increase in population is anticipated to occur incrementally over the next 25 years. While Culver City Fire Department (CCFD) is not currently meeting their emergency response time goals, CCFD has plans to augment their existing staff by seven staff members.
The 2019 Standards of Cover and Community Risk Assessment and the CCFD Strategic Plan outline recommendations to increase CCFD performance regarding deployment, response time, data collection, and mutual aid. While no additional fire stations are currently proposed, the Standards of Cover and Community Risk Assessment will be updated by CCFD during implementation of the General Plan 2045 to identify what new and/or expanded fire stations may be needed through the 2045 planning horizon. If a new station were to be needed in the future, the necessary environmental review would be conducted at that time.
Public safety in Culver City, including fire protection and emergency services provided by CCFD, is funded from the City’s general fund. Revenue sources that contribute to the general fund, including property and sales taxes, are anticipated to grow in rough proportion to the projected growth that will occur as a result of the Project. In addition, future development that occurs as a result of the Project will be reviewed by the City and CCFD and will be required to comply with applicable requirements in effect at the time building permits are issued. With compliance with applicable regulations and consistency with General Plan policies, the Project will not require the provision of new or physically altered fire protection facilities, or the need for new or physically altered fire protection facilities, the construction of which could cause significant environmental impacts. Therefore, impacts will be less than significant.
Police Protection (Impact PS-1.ii)
Facts/Effects: Growth anticipated as a result of the Project will likely increase the number of police responses in the city, which could increase the need for equipment and personnel. In addition, the redistribution and increase of population and traffic density into areas proposed for growth could necessitate the reassignment of certain resources pertaining to police services.
Findings of Fact Required by CEQA
19 While the projected growth could result in a need for additional personnel, the growth would occur incrementally over the next 25 years. If a new police station were to be needed in the future, the necessary environmental review would be conducted at that time. The revenues and fees generated by future development are anticipated to offset the costs of additional personnel and materials. In addition, future development that occurs as a result of the Project will be reviewed by the City and CCFD and will be required to comply with applicable requirements in effect at the time building permits are issued. With compliance with applicable regulations and consistency with General Plan policies, the Project will not require the provision of new or physically altered police protection facilities, or the need for new or physically altered police protection facilities, the construction of which could cause significant environmental impacts.
Therefore, impacts will be less than significant.
Schools (Impact PS-1.iii)
Facts/Effects: Growth anticipated as a result of the Project will generate 3,556 elementary school students, 1,016 middle school students and 2,032 high school students in Culver City public school enrollment. Projected enrollment in 2045 with project-generated students will exceed the elementary, middle, and high school capacities. The General Plan 2045 contains policies related to schools, including continued coordination with the City Unified School District (CCUSD) to inform the CCUSD on impacts of major developments and population growth trends that may impact school enrollment. CCUSD will collect development impact fees for future development prior to issuance of building permits, which will 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 under Senate Bill 50.
Therefore, impacts related to school facilities will be less than significant.
Other Public Facilities (Impact PS-1.iv)
Facts/Effects: As demand for other public facilities increases as a result of anticipated growth as a result of the Project, there may be a need to increase staffing and facilities (i.e., libraries) to maintain acceptable service ratios and other performance objectives. However, no expansions are proposed at this time. If the expansion of an existing facility or a new facility were to be needed in the future, the necessary environmental review would be conducted at that time. The City will review plans for consistency with the Project. Therefore, the Project will not require the provision of other public facilities, the construction of which could cause significant environmental impacts, in order to maintain sufficient capacity and impact will be less than significant.
Cumulative Public Services Analysis
Facts/Effects: The Project and other development in areas served by CCFD, including those with mutual aid agreements, will increase the population of the service area, thereby increasing fire protection demand. Revenue sources that contribute to the Cities’ and the County’s general funds, including property and sales taxes, will be expected to grow in rough proportion to the increase in growth in areas served by CCFD. Furthermore, CCFD has established mutual aid agreements with the City of Los Angeles and Los Angeles County to increase response levels of service to residents of the city as well as surrounding areas. Therefore, the cumulative impact
Findings of Fact Required by CEQA
20 will be less than significant, and the Project will not contribute to a cumulatively significant impact.
As the CCPD does not provide police protection services outside of the City boundary, development and growth associated with other nearby jurisdictions will not result in cumulative impact on CCPD resources and their service commitments. The costs of additional police personnel and materials are anticipated to be offset through the increased revenues and fees, including property and sales taxes, generated by future development. As a result, the Project will not contribute to a cumulatively significant impact regarding police protection services.
CCUSD will continue to collect development impact fees throughout implementation of the Project that will fund needed facility upgrades and expansions to ensure that there is sufficient capacity to accommodate future public-school students. The payment of statutory fees fully mitigates the impacts of development on school facilities for purposes of CEQA under Senate Bill 50. Therefore, the cumulative school impact will be less than significant, and the Project will not contribute to a cumulatively significant impact regarding schools.
Population growth anticipated under the Project may result in the need for new public facilities such as libraries. However, if new facilities are proposed, compliance with applicable requirements, including environmental review, would be necessary. In addition, if a facility were to be needed in another jurisdiction, the same would apply. Therefore, the contribution of the Project to potential cumulative impact relative to other public facilities will be less than significant.
Recreation
Draft PEIR Section 4.15 evaluates the potential impacts relative to recreation that could result from implementation of the Project.
Deterioration of Existing Recreational Facilities (Impact REC-1) Facts/Effects: The current park service ratio for the City is 8.9 acres of parkland per 1,000 residents, inclusive of regional parks and joint use facilities. However, the current service ratio for City-parkland is 2.2 acres per 1,000 residents, which does not meet the standard of 3 acres per 1,000 residents. The City has identified locations for planned or proposed trails and recreational facilities throughout Culver City, including joint-use facilities proposed throughout the City.
While no new parks are currently proposed within the Planning Area, approximately 90 percent of Culver City residences are within one half-mile walking distance of an existing park, trail, or open space, including facilities just outside City limits. The service ratio provides an understanding of population relative to park acreage, and therefore a measure of the availability of park space to serve residents, but this ratio alone does not determine the quality of park service available to residents. In addition to improving the amount of park space and access to parks, enhancement of park amenities that improve park usability allow for a greater variety of uses and programming. Accessibility and the quality of the pedestrian environment leading to/from a green space is also an important factor. Policies in the General Plan 2045 will reduce
Findings of Fact Required by CEQA
21 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 will not increase the use of existing neighborhood and regional parks or other recreational facilities such that substantial physical deterioration of the facility will occur or be accelerated. Impacts will be less than significant.
Require Construction or Expansion of Recreational Facilities (Impact REC-2) Facts/Effects: The Project encourages the development of future recreational facilities in order to meet demand associated with anticipated population growth under the Project. General Plan 2045 policies are designed to minimize environmental impacts associated with the construction of new parks or expanded recreational facilities. Environmental impacts associated with construction of new and/or expanded parks and recreational facilities will be subject to applicable requirements and additional environmental review under CEQA, as needed. The Project will not require the construction or expansion of recreational facilities which might have an adverse physical effect on the environment. Therefore, the Project will result in a less than significant impact.
Cumulative Recreation Analysis
Facts/Effects: Future development and population growth anticipated by the Project will generate additional demand for parks and recreational facilities. All new and expanded facilities will be subject to applicable General Plan land use designations and policies as well as applicable regulations related to construction and operational impacts. The Project includes policies and standards to minimize potentially cumulatively considerable environmental impacts of new development, including sustainable park and recreational facility design, development, and planning standards. Therefore, the Project will not contribute to a cumulatively significant impact related to the construction or expansion of recreational facilities, the construction of which might have adverse physical effects on the environment. Cumulative impacts regarding recreation will be less than significant.
Transportation
Draft PEIR Section 4.16 evaluates the potential impacts relative to transportation that could result from implementation of the Project.
Conflict with Adopted Circulation Program, Plan, Ordinance, or Policy (Impact TR-1) Facts/Effects: The Project will not preclude the implementation of the Culver City Short Range Mobility Plan, and provides complimentary goals, policies, and implementation actions that address transit improvements. In addition, the Mobility Element supports and complements the measures, objectives, and policies in the City’s Bicycle and Pedestrian Action Plan. Further, the Mobility Element places an emphasis on Complete Streets and a layered transportation network consistent with the City’s Complete Streets Policy. The Mobility Element establishes the goal of providing a transportation network that is safe and accessible for all travel modes consistent with the City’s Local Road Safety Plan. The Project will enable the City to improve bicycling programs and infrastructure throughout the City, providing connections to the existing and proposed bicycle network. The goals and policies in the Mobility Element will be consistent with
Findings of Fact Required by CEQA
22 the applicable plans and therefore, the Project will not conflict with any applicable program, plan, or ordinance on the circulation system, including transit, roadway, bicycle, and pedestrian facilities. Impacts will be less than significant.
Introduce Incompatible Uses (Impact TR-3)
Facts/Effects: The land use diagram and policies contained in the General Plan 2045 emphasize transition areas and buffers between land uses of varying intensity, which will serve to reduce potential conflicts between users of the transportation system connected with each land use, including commercial and industrial truck traffic, commute traffic, pedestrians, and cyclists. Access locations for development allowed under the Project will be designed to the City’s standards and will provide adequate sight distance, sidewalks, crosswalks, and pedestrian movement controls to meet the City’s requirements to protect pedestrian safety. The various goals and policies contained within the Mobility Element are designed to address transportation safety, improve circulation, implement transportation projects, and advance current City plans, policies, programs, and ordinances. The transportation projects included in the Mobility Element are envisioned to improve mobility, safety, and access, and thus will be designed to applicable federal, state, and City Engineering Design Standards or other applicable roadway standards. As a result, the Project will not substantially increase hazards due to a geometric design feature or incompatible use, and impacts will be less than significant.
Result in Inadequate Emergency Access (Impact TR-4)
Facts/Effects: Project-level review required by the City includes site access review for emergency vehicles and traffic control plans that account for emergency vehicles. The City’s development review process will ensure that future development under the Project will be consistent with applicable policies and will not hinder emergency access for individual sites.
Therefore, the Project will not result in inadequate emergency access, and impacts will be less than significant.
Cumulative Transportation Analysis
Facts/Effects: Cumulative impacts are determined through consistency with the SCAG RTP/SCS, in that a Plan must demonstrate compliance with air quality conformity requirements and GHG reduction targets. The Project would have a cumulative impact if average daily VMT per capita and VMT per employee at buildout would exceed the corresponding VMT metrics, and if total VMT would exceed the total VMT for the existing conditions. At buildout the Project will represent a 4.26 percent decrease in residential VMT per capita compared to the existing conditions, a 4.59 percent decrease in work VMT per employee compared to the existing conditions, and a 6.39 percent decrease in total daily VMT per service population. Therefore, the resulting cumulative VMT impact will be less than significant.
With regard to conflicting with applicable plans, policies, and ordinances, the Project will not conflict with the various local, regional, and state regulatory frameworks. Therefore, the Project will not contribute to a cumulative significant impact relative to conflicting with applicable plans, policies, and ordinances. Impacts regarding this cumulative impact will be less than significant.
Findings of Fact Required by CEQA
23 While traffic generated by future development in the region could substantially increase hazards due to a geometric design feature or incompatible use, the General Plan 2045 includes policies which emphasize transition areas and buffers between land uses of varying intensity, which would serve to reduce potential conflicts between users of the transportation system connected with each land use. The Project includes an emphasis on multi-modal street networks which would improve compatibility between different transportation modes and address potential safety concerns. Future development under the Project would be compliant with applicable City design guidelines. Therefore, the Project will not contribute to a cumulative impact relative to hazards due to geometric design features or incompatible uses.
Tribal Cultural Resources
Draft PEIR Section 4.17 evaluates the potential impacts relative to tribal cultural resources that could result from implementation of the Project.
Tribal Cultural Resource Significance (TCR-1)
Facts/Effects: The Planning Area was a highly suitable area for the inhabitance of indigenous people. In addition, the current or prior existence of development throughout the city does not preclude the presence of tribal cultural resources located underneath this development since existing improvements within the city (e.g., roads, buildings, structures, etc.) were constructed prior to the existence of cultural resources protection laws. The NAHC identified one resource in their database and recommended that the City contact the Gabrielino Tongva Indians of California Tribal Council for more information on this particular resource. The City submitted notification and request to consult letters pursuant to AB 52 and SB 18 to seven Native American individuals and organizations on March 2, 2022 and February 15, 2024. The City received one response from the Kizh Nation indicating that they are in agreement with the Project and requesting consultation if there would be ground disturbance occurring with future projects.
Future projects will 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, as necessary. In addition, the City will 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 in support of the City’s goals for protection of cultural resources. Adherence to the regulations and consistency with General Plan policies and implementation actions will ensure that the impacts with respect to tribal cultural resources will be less than significant.
Cumulative Tribal Analysis
Facts/Effects: Future development in the Planning Area and surrounding region, will be required to comply with SB 18 and AB 52 consultation, which will ensure that tribal cultural resources are properly identified and that mitigation measures are identified to reduce impacts on these resources. Potential cumulative impacts relating to tribal cultural resources will be minimized on a site-by-site basis to the extent that appropriate consultation is conducted.
Findings of Fact Required by CEQA
24 Therefore, the Project’s contribution to this potentially significant cumulative impact will not be cumulatively considerable. Cumulative impacts to tribal cultural resources will be less than significant.
Utilities and Service Systems
Draft PEIR Section 4.18 evaluates the potential impacts relative utilities and service systems that could result from implementation of the Project.
New or Expanded Water, Wastewater Treatment, Stormwater Drainage, Electric Power, Natural Gas, or Telecommunications Facilities (Impact UTL-1) Facts/Effects: Future development that will occur under the Project will result in an increased demand for water, wastewater treatment, storm drainage, electric power, natural gas, and telecommunication services.
With regard to water, while growth under the Project was not specifically accounted for in the 2020 Urban Water Management Plan (UWMP) for each local water provider, Golden State Water Company (GSWC) and Los Angeles Department of Water and Power (LADWP) will account for the projected growth during the next UWMP update cycle in 2025. Water is also further discussed in 12.b, Impact UTL-2, below. Future projects will be required to demonstrate availability of water, as required and applicable, in the form of will-serve letters and for larger projects preparation of a Water Supply Assessment (WSA).
With regard to wastewater, new development allowed under the Project will be subject to the latest adopted edition of the California Plumbing Code and CALGreen Code, which will reduce the amount of effluent entering the wastewater system. In addition, as discussed under 12.c, Impact UTL-3, there is sufficient capacity at the Hyperion Water Reclamation Plan (HWRP) and Joint Water Pollution Control Plant (JWPCP) to accommodate wastewater collection and treatment generated by the growth that will occur under the Project.
With regard to stormwater drainage, future development will be required to comply with all applicable construction and operational laws, regulations, and permits related to hydromodification and discharging into the City’s system. City requirements and policies will ensure that runoff will not inundate existing storm drainage facilities such that new or expanded facilities will be required.
With regard to electric power and natural gas, all new development will be subject to energy efficiency standards contained in the latest adopted edition of the CALGreen Code, thus reducing the need for new infrastructure. Future development could result in a demand for and/or the provision of new telecommunication facilities. As with other public services, applicable requirements relative to electric power, natural gas, and telecommunications, including environmental analysis if needed and the implementation of mitigation measures, will ensure that impacts are less than significant.
Findings of Fact Required by CEQA
25 In summary, the Project will result in less-than-significant impacts related to new or expanded water, wastewater treatment, stormwater drainage, electric power, natural gas, or telecommunications facilities.
Water Supplies (Impact UTL-2)
Facts/Effects: The Project’s projected increase development will result in an increased demand for potable water. Culver City is served by two water service providers: GSWC and LADWP.
GSWC and LADWP will account for this growth during the next UWMP update cycle in 2025 and thus, will account for future development in the Planning Area prior to the General Plan Update’s horizon year of 2045. Individual development proposals that meet the definition of a project under CEQA will be required to address water supply as part of the CEQA process, and for qualifying projects, a WSA will be required pursuant to SB 610 for inclusion in the project’s CEQA analysis. In the event of a water shortage, GSWC and LADWP will rely on their Water Shortage Contingency Plans (WSCPs), which are to be engaged in the case of a water shortage event, such as a drought or supply interruption. In addition, future development will be required to comply with Chapter 5.03 of the City’s Municipal Code, the City’s Water Conservation Plan, and General Plan 2045 policies aimed at reducing demand over time.
Therefore, implementation of the Project will result in less than significant impacts to water supply.
Wastwater Treatment (Impact UTL-3)
Facts/Effects: No new major sewer upgrades are anticipated or proposed as part of the Project. All new development in the City will be subject to sewer capacity considerations as part of the City review process. Improvements and upgrades to sewer lines are prioritized based on need. Development fees are collected from each project and used to fund the highest priority improvements. The proposed land use changes associated with the Project and the projected increase in wastewater flows associated with the anticipated growth will not exceed the treatment capacity at the HWRP or the JWPCP. Therefore, impacts related to wastewater will be less than significant.
Solid Waste Generation (Impact UTL-4)
Facts/Effects: The generation of solid waste (both construction and operation waste) will increase with future development that will occur under the Project. Construction waste will be required to be diverted from landfills in accordance with Municipal Code Section 15.02.1140. As required, a minimum of 75 percent of the nonhazardous construction and demolition debris from new development or redevelopment will be recycled and/or salvaged for reuse. There is adequate capacity in the inert landfills to accommodate the projected volume of waste that could occur. Based on the projected growth that will occur, operationally, the 10 Class III landfills in the county have adequate capacity to accept the projected volume of waste. In addition, all future development projects proposed in the City will be required to comply with applicable federal, state, and local statutes and regulations related to solid waste that are intended to reduce the disposal of waste in landfills. Therefore, the Project will not generate solid waste in excess of state or local standards, or in excess of the capacity of local infrastructure, or
Findings of Fact Required by CEQA
26 otherwise impair the attainment of solid waste reduction goals. Impacts will be less than significant.
Solid Waste Regulations (Impact UTL-5)
Facts/Effects: As indicated above, development and growth in the Planning Area will increase the generation of solid waste. In accordance with City requirements, future development allowed under the Project will be served with solid waste and recycling services provided by the City or its authorized agents (Municipal Code Section 5.01.01). Future development allowed under the Project will be required to comply with statewide and local requirements, including AB 341, AB 939, SB 1016, and SB 1383, which require waste reduction, recycling, and diversion. In addition, projects will be required to be consistent with policies in the General Plan 2045 and applicable requirements in the Zoning Code Update related to solid waste. Therefore, future development allowed under the Project will comply with federal, state, and local management and reduction statutes and regulations related to solid waste, and the impact will be less than significant.
Cumulative Utilities and Service Systems Analysis
Facts/Effects: Construction and installation of new water transmission and distribution infrastructure will be the responsibility of Metropolitan, LADWP and GSWC. Metropolitan continues to improve regional water supplies though its IRP planning process and its 26 member agencies continue to improve local water supplies. The GSWC and LADWP have the ability to implement a WSCP in the case of supply shortages and demonstrated its effectiveness during the historic 2013–2017 drought. In addition, with these efforts and the increasing efficiency and drought planning requirements from the State, sufficient water supply is estimated to be available within the region to meet all future demands within the service area. Thus, sufficient water supplies will be available to serve the Project and reasonably foreseeable future development during normal, single dry and multiple dry years. Cumulative water supply impacts will be less than significant.
With regard to wastewater conveyance and treatment, all cumulative projects will be required to comply with applicable requirements and policies related to wastewater collection and treatment. The Project’s contribution to cumulative impacts will be less than significant.
As with growth that will occur under the Project, future development in the region will be required to comply with applicable federal, state, and local laws and policies, including AB 341, AB 939, SB 1016, and SB 1383, which require waste reduction, recycling, and diversion. As with the City, all jurisdictions within the region will be required to comply with existing as well as new federal, state, and local statutes and regulations aimed at reducing solid waste. Therefore, cumulative impacts related to solid wase capacity and compliance with regulatory requirements will be less than significant.
Cumulative development contributes to an incremental increase in impervious surfaces that could increase stormwater runoff and impact existing storm drain facilities requiring relocated or new facilities. All cumulative projects will be required to comply with applicable requirements
Findings of Fact Required by CEQA
27 and policies that minimize stormwater runoff. Therefore, cumulative impacts to storm drainage will be less than significant.
Wildfire
Draft PEIR Section 4.19 evaluates the potential impacts relative to wildfires that could result from implementation of the Project.
Emergency Response or Evacuation Plans (Impact WF-1)
Facts/Effects: The continued growth and development associated with implementation of the Project could have the potential to interfere with an adopted emergency response or evacuation plan if the emergency response services and/or evacuation routes were to become overburdened by the increase in residents or intensity of new development associated with implementation of the Project. Evacuation routes in the city have been designed to accommodate future development through the Project’s horizon year (2045). In the event of an evacuation, major freeways including I-10 and I-405 will be used as the main evacuation routes outside of the city. The City’s MJHMP also provides a strategy for reducing the City's and CCUSD’s vulnerability to the impacts of natural hazard events such as earthquakes, flood, and wildfire. In addition to the City’s emergency response systems, the Los Angeles County Operational Area Emergency Response Plan provides the framework for responding to major emergencies or disasters. New development associated with implementation of the Project will be reviewed and approved by CCFD for compliance with applicable Fire Code requirements that pertain to emergency access during the development review process. Therefore, compliance with local and regional emergency response, evacuation plans, building regulations and requirements established in the CMCC, as well as consistency with applicable General Plan policies will ensure that the Project will not impede an adopted emergency or evacuation plan.
Thus, impacts will be less than significant.
Exacerbate Wildfire Risk (Impact WF-2)
Facts/Effects: Future development associated with implementation of the Project will 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.
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. Compliance with CFC, CBC, and consistency with General Plan 2045 policies, as well as review of all new structures and private and public improvements by CCFD, will ensure that fire risks are not exacerbated. Therefore, the Project will result in a less than significant impact related to exacerbating wildfire risk.
Installation or Maintenance of Associated Infrastructure Which Exacerbate Fire Risk (Impact WF-3)
Facts/Effects: 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, will generally occur in urban and developed areas that contain existing
Findings of Fact Required by CEQA
28 defensible space, roadways, fuel breaks, water sources, power lines, and other utilities. The City will review future development applications for compliance with the relevant policies in the General Plan 2045. Furthermore, CCFD or LACFD will review the development plans for any City utilities or fire prevention and protection equipment, such as the installation and maintenance of fire access roadways, access walkways to and around buildings, and hydrant quantity and placement, to ensure compliance with the CFC and CBC. Therefore, the Project will result in a less than significant impact related to the installation or maintenance of associated infrastructure that could exacerbate fire risk or result in temporary or ongoing impacts to the environment.
Expose People or Structures to Significant Risks (Impact WF-4) Facts/Effects: The eastern portion of the Planning Area, including the Culver Crest and Blair Hills neighborhoods and areas within the IOF, is designated as a VHFHSZ and is adjacent to land designated as a VHFHSZ outside of the Planning Area. The Blair Hills (located near the Baldwin Hills) and Culver Crest neighborhoods contain sloping hillsides that are susceptible to landslides and flooding after fire has removed protective vegetative cover. Future development allowed under the Project will be required to comply with all applicable requirements related to soil instability and water quality, including the regulations of the CCMC and policies in the General Plan 2045 regarding development on unstable geologic soils and controlling stormwater runoff during and after construction. The General Plan 2045 contains specific policies related to the prevention of flooding, landslides, and drainage changes, including policies that require ensuring prudent development and redevelopment within areas with high landslide potential during environmental and development review processes. Combined with the continued implementation of the City’s MJHMP, as well as review of development plans by CCFD, these policies provide additional proactive measures to refine and enhance the resiliency of the area, as well as strengthening the City’s review of new applications for development to ensure that the Project will not expose people or structures to significant risks, including downslope or downstream flooding or landslides, as a result of runoff, post-fire slope instability, or drainage changes. As such, impacts will be less than significant.
Cumulative Wildfire Analysis
Facts/Effects: Cumulative projects in surrounding jurisdictions will be required to comply with the CBC, CFC, and local municipal codes which will reduce impacts associated with wildfires.
Pursuant to the Fire Code of the jurisdictions, all development will be required to comply with requirements relating to emergency planning and preparedness, emergency access, water supply, defensible space and vegetation management, and specific requirements for specialized uses involving flammable and hazardous materials. The implementation of these standard requirements will reduce impacts associated with accidental ignitions emanating from project sites and will not exacerbate wildfire risks. Therefore, the Project will not contribute to a cumulatively significant impact and the cumulative impact would be less than significant.
Findings of Less than Significant With Mitigation
This section sets forth the environmental impacts determined to have less than significant impact in the Draft PEIR with implementation of mitigation measures. Applicable mitigation
Findings of Fact Required by CEQA
29 measures are identified below and the mitigation measures are provided in their entirety in the Mitigation Monitoring Program (MMP) that is provided as an attachment to these Findings and Statement of Overriding Considerations. Based on that analysis and other evidence in the administrative record relating to the project, the City Council finds and determines that mitigation measures described in the Final EIR reduce the potentially significant impacts identified for the following environmental impact categories to below the level of significance. Pursuant to PRC Section 21081, the City Council finds that changes or alterations have been required in, or incorporated into, the Project which mitigate or avoid each of the following significant effects on the environment.
Biological Resources
Draft PEIR Section 4.3 evaluates the potential impacts to biological resources that could result from implementation of the Project.
Adversely Affect Candidate, Sensitive, or Special Status Species (Impact BIO-1) Facts/Effects: The vast majority of the Planning Area is heavily developed and contains minimal biological resources; however, fragmented, isolated swathes of coastal scrub and chaparral vegetation remain throughout portions of the IOF and Kenneth Hahn State Recreation Area. Construction of some projects could result in direct removal of suitable wildlife habitat for special-status species (which may include nesting avian species), resulting in the potential mortality of wildlife species existing within the habitat as well as the displacement of more mobile wildlife species to other habitat areas nearby. While the majority of special-status biological resources have a low potential to occur within the Planning Area as result of the largely developed nature of the Planning Area, new development projects could significantly impact these resources, when analyzed on a project-by-project basis due to specific onsite conditions.
Although compliance with the goals and policies of the General Plan 2045 and the applicable laws and regulations would help to minimize impacts to special-status species, MM BIO-1 (Baseline Biological Assessment) and MM BIO-2 (Nesting Bird Surveys) are recommended to ensure that impacts to special-status species from implementation of the General Plan 2045 would be reduced to a less than significant level. These mitigation measures require development under the General Plan 2045 to implement procedures and processes related to protecting special-status species, such as preconstruction surveys, compensatory mitigation for loss of designated habitats, and protection and/or avoidance of special-status species.
Implementation of the mitigation measures would ensure that construction impacts to special- status species with implementation of the General Plan 2045 would be less than significant.
Interfere with Wildlife Corridors or Wildlife Nursery Sites (Impact BIO-4) Facts/Effects: The Project would not substantially interfere with movement of native resident or migratory fish or wildlife species or with established wildlife corridors due to the lack of wildlife movement corridors within the Planning Area. However, nesting birds and/or nesting bird habitat have been recorded within the Planning Area, where Project could directly or indirectly impact these biological resources. There are areas that consist of trees, shrubs, and ground cover,
Findings of Fact Required by CEQA
30 including non-native/ornamental vegetation dispersed throughout developed land uses that could be used by breeding raptors and songbirds. Disturbing or destroying active nests is a violation of the Migratory Bird Treaty Act (MBTA) and nests and eggs are protected by Fish and Game Code, Section 3503. While these biological resources have a low potential to occur due to the heavily developed nature of the Planning Area, future development could impact these resources if removal of active nests or harassment of a breeding bird occur during construction, resulting in a potentially significant impact.
Compliance with the Project and the MBTA would help to minimize impacts to nesting birds and their associated habitat. However, impacts could be potentially significant. MM BIO-2 (Nesting Bird Surveys), which requires procedures and processes related to protecting nesting birds and their associated habitat, such as pre-construction surveys and protection and/or avoidance of nesting birds and their associated habitats, will reduce impacts to a less-than-significant level on a project-by-project basis.
Cumulative Biological Resources Impacts
Facts/Effects: There are limited biological resources and habitats within the Planning Area due to its largely developed nature. The General Plan 2045 includes policies that aim to protect and enhance the biological resources within the Planning Area. With implementation of these policies of MM BIO-1 and MM BIO-2, potential impacts to special-status biological resources, including protected habitats, will be reduced to a less than significant level. Therefore, the Project would result in less than significant cumulative impacts related to biological resources.
Cultural Resources
Draft PEIR Section 4.4 evaluates the potential impacts to cultural resources that could result from implementation of the Project.
Archaeological Resources (Impact CUL-2)
Facts/Effects: The archival research conducted for the Project indicates that 18 known archaeological resources have been previously identified within the city. Current or prior existence of development throughout the City does not preclude the presence of archaeological resources located underneath this development. In addition, the city would have been a highly suitable area for the inhabitance of indigenous people in light of Ballona Creek flowing through the area. Project-related demolition, construction, maintenance, and/or improvement activities have the potential to cause a potentially significant impact to archaeological resources.
Implementation of Mitigation Measure (MM) CUL-2, along with the City’s standard conditions of approval, and applicable policies in the General Plan 2045 will reduce impacts to archaeological resources to a less than significant level.
Cumulative Archaeological Resources Impacts
Facts/Effects: Future development in the Planning Area, including growth anticipated under the proposed General Plan 2045, and larger Los Angeles County region throughout the 2045 planning horizon, could result in a substantial adverse change in the significance of archaeological resources, thus resulting in a potentially significant cumulative impact. However,
Findings of Fact Required by CEQA
31 with implementation of MM CUL-2, the Project’s contribution to this potentially significant cumulative impact will not be cumulatively considerable.
Geology and Soils
Draft PEIR Section 4.6 evaluates the potential impacts to geology and soils, including paleontological resources, that could result from implementation of the Project.
Paleontological Resources (Impact GEO-5)
Facts/Effects: Based on the records search conducted for the Project four fossil localities have been recorded within the city boundaries and eight other localities located outside the city but from the same sedimentary deposits (older Quaternary alluvium deposits and the San Pedro Sand) that occur within and throughout the city. Specific project-related demolition, construction, maintenance, and/or improvement activities have the potential to result in a potentially significant impact to paleontological resources. Implementation of MM GEO-1 and applicable policies in the General Plan 2045 will reduce impacts to paleontological resources to a less than significant level.
Cumulative Paleontological Resources Impacts
Facts/Effects: Future development in the Planning Area, including growth anticipated under the proposed General Plan 2045, and larger Los Angeles County region throughout the 2045 planning horizon, could result in a substantial adverse change in the significance of paleontological resources, thus resulting in a potentially significant cumulative impact. However, with implementation of MM GEO-1, the Project’s contribution to this potentially significant cumulative impact will not be cumulatively considerable.
Impacts Found to Be Significant after Mitigation (Significant and Unavoidable)
This section sets forth the environmental impacts determined to be significant and unavoidable even with implementation of all feasible mitigation measures. The City Council finds that the following environmental effects were identified in the Draft PEIR as potentially significant and that even with the implementation of all feasible mitigation measures the PEIR and the record of proceedings in this matter identify or contain substantial evidence identifying significant and unavoidable environmental effects as listed below.
Air Quality
Draft PEIR Section 4.2 evaluates the potential air quality impacts that could result from implementation of the Project.
Conflict with or Obstruct Applicable Air Quality Plan (Impact AIR-1) Facts/Effects: The Air Basin is designated nonattainment for O3 and PM2.5 under the CAAQS and NAAQS, nonattainment for lead (Los Angeles County only) under the NAAQS, and nonattainment for PM10 under the CAAQS. Long-term growth associated with buildout under
Findings of Fact Required by CEQA
32 the Project could result in the emissions of criteria pollutants that exceed SCAQMD thresholds for criteria pollutants.
Development activities under the Project will primarily occur on parcels that already contain some existing residential or non-residential uses. The City’s primary approach to accommodating growth is to provide strategies for thoughtful infill development and redevelopment that range from modest additions of individual housing units to the redevelopment of large, aggregated properties within opportunity sites located in activity centers and along commercial corridors. The Project will not conflict with Air Quality Management Plan (AQMP) land use and transportation strategies that are intended to reduce VMT and resulting regional mobile source emissions and will result in a less than significant impact associated with the first indicator in the AQMP.
However, future development that will occur under the Project will increase vehicle trips and VMT that will result in emissions of ozone precursors and particulate matter. A project might be in conflict with the AQMP if the development is greater than that anticipated in the local general plan and SCAG’s growth projections. The AQMP is based on population, employment and VMT forecasts by SCAG. The Project projects a population of 62,400 persons in 2045, which will exceed the SCAG growth forecast of 41,600 persons in 2045; the Project projects 28,310 households in 2045, which will exceed the SCAG growth forecast of 18,000 households in 2045; and the Project projects 84,300 jobs in 2045, which will exceed the SCAG growth forecast of 64,100 jobs in 2045.
Culver City continues to coordinate with SCAQMD and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. The General Plan 2045 policies will reduce emissions, which would address potential impacts related to conflicts with an applicable air quality plan. In addition, Mitigation Measures MM AQ-1 through MM AQ-5 will 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 will remain significant and unavoidable.
Result in Cumulatively Considerable Net Increase in Criteria Pollutants (Impact AIR-2) Facts/Effects: During construction, the use of heavy-duty construction equipment and vehicle trips generated by construction workers and haul trips traveling to and from each specific project site has the potential to create regional air quality impacts. In addition, fugitive dust emissions will result from construction activities. During the finishing phase, the application of architectural coatings (i.e., paints) and other building materials will release VOCs. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of operation and, for dust, the prevailing weather conditions. Since there are no specific developments currently proposed under the Project and there is no knowledge as to timing of construction, location or the exact nature of future projects, modeling of construction emissions would be speculative. Mandatory compliance with CARB and SCAQMD rules and regulations will reduce emissions, particularly for NOX, PM10, and PM2.5, during future construction
Findings of Fact Required by CEQA
33 activities under the Project. However, even with mandatory compliance with CARB and SCAQMD rules regulations, it is possible that some future development projects could be large enough in scale and/or intensity such that many pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period emissions could exceed the SCAQMD significance thresholds. Therefore, project-related construction activities could result in significant regional air quality impacts. Even with implementation of recommended mitigation measures that will reduce emissions, construction impacts will remain significant and unavoidable.
Operation of future development under the Project will generate criteria pollutant emissions from vehicle trips traveling within the City, energy sources such as natural gas combustion, and area sources such as landscaping equipment and consumer products usage. The net change in operational emissions between existing conditions and under the Project will not exceed the SCAQMD regional significance thresholds, with the exception of VOC emissions that would exceed the threshold (Draft PEIR Table 4.2-7). The net change in emissions at 2045 buildout will be negative for NOX, CO, and SOX compared to existing conditions primarily due to the focus of the Project on infill development and revitalization to help Culver City achieve an integrated land use mix that accommodates growth while reducing VMT and associated emissions, improvements in vehicle emissions standards and, to a lesser extent, improvements in building energy efficiency standards. The increase in VOC emissions is primarily the result of growth in building floor area and residential units, which results in population growth and associated use of consumer products. The increase in PM10 and PM2.5 emissions, while below the threshold, is primarily the result of growth in building floor area and residential units, which results in population growth and associated growth in total VMT, which generates a net increase in re-entrained roadway fugitive dust emissions.
Policies in the Community Health and Environmental Justice Element and Conservation Element will potentially reduce emissions, which could potentially address impacts. As required by SB 1000, the Community Health and Environmental Justice Element includes a number of policies relevant to air quality, focusing on reducing emissions and reducing exposure to pollution at sensitive land uses.
Because regional emissions from future development under the Project may exceed the SCAQMD regulatory thresholds during construction and/or operational activities, there is the potential that these emissions will exceed the CAAQS and NAAQS thus resulting in a health impact. Without knowing the exact specifications for all projects that may be developed, there is no way to accurately calculate the potential for health impacts from the overall Project. As applicable, individual projects will be required to provide environmental assessments to determine health impacts from the construction and operation of the projects. Because there is no way to determine the potential for these projects to affect the health of sensitive receptors within the city, the Project will result in a potentially significant health impact.
The Project will result in a potentially significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment during construction and operation due to regional emissions that could exceed the SCAQMD
Findings of Fact Required by CEQA
34 significance thresholds. While implementation of Mitigation Measures MM AQ-1 through MM AQ-5 will serve to reduce the severity of the impacts, the Project will result in a significant and unavoidable impact.
Expose Sensitive Receptors to Substantial Pollutant Concentrations (Impact AIR-3) Facts/Effects: Potential new development that will occur as a result of the Project will likely occur close to existing sensitive receptors and thus, the development has the potential to expose sensitive receptors to substantial pollutant concentrations. Future projects may require project-specific dispersion modeling to evaluate potential health risk impacts associated with construction. However, there is no information regarding specific development projects, such as specific building information, construction schedules, quantities of grading, and other information that would be required in order to provide a meaningful estimate of emissions. While the General Plan policies could reduce emissions, construction equipment exhaust combined with fugitive particulate matter emissions has the potential to expose sensitive receptors to substantial concentrations of criteria air pollutant emissions or diesel particulate matter and result in a potentially significant impact. Under the Project, industrial-type land uses may be permitted within the City Planning Area. As operation of some these future developments may occur within proximity to sensitive receptors, there is the potential for localized emissions to exceed the significance thresholds and result in a result in a potentially significant impact.
With regard to CO hotspots, no exceedances of CO have been recorded at monitoring stations in the Air Basin since 2003 and the Air Basin is currently designated as a CO attainment area for both the CAAQS and NAAQS. Intersection volumes were evaluated and based on roadway segment volumes under the buildout horizon, the volume of traffic will be below the threshold of vehicles per day modeled in SCAQMD’s 20003 AQMP CO attainment demonstration. Thus, the Project will result in a less than significant impact with response to CO hotspots.
Construction and operation of future development will result in emission of toxic air contaminants (TAC). As indicated above, because specifics of a project are unknown and because health risk impacts from TACs are cumulative over the life of the nearby receptors, quantification of potential health risks would be speculative. Therefore, health risk with respect to the development anticipated by the Project is considered potentially significant.
In summary, the Project will 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 TAC emissions that could exceed the applicable significance thresholds. Implementation of MM AQ-1, MM AQ-3, MM AQ-6, and MM AQ-7 will serve to reduce the severity of the impacts to exposure of sensitive receptors to substantial pollutant concentrations. However, even with implementation of these measures, impacts could exceed the significance thresholds and impacts will be significant and unavoidable.
Cumulative Air Quality Impacts
Facts/Effects: The Project will not conflict with AQMP construction, land use, and transportation strategies that are intended to reduce construction emissions, VMT, and resulting regional mobile source emissions. In addition, construction and operation would not conflict with
Findings of Fact Required by CEQA
35 growth projections as Culver City continues to coordinate with SCAQMD and SCAG to ensure city-wide growth projections, land use planning efforts, and local development patterns are accounted for in the regional planning and air quality planning processes. As such, a cumulative impact would be less than significant under this criterion.
However, the Project will result in a potentially significant impact related to a cumulatively considerable net increase of any criteria pollutant for which the project region is non-attainment during construction and operation due to regional emissions that could exceed the SCAQMD significance thresholds (Impact AQ-2). While implementation of MM AQ-1 through MM AQ-5 would serve to reduce the severity of the effects, impacts will remain significant and unavoidable.
Cultural Resources
Draft PEIR Section 4.4 evaluates the potential impacts to cultural resources that could result from implementation of the Project.
Historical Resources (Impact CUL-1)
Facts/Effects: Future development facilitated under the Project 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. A total of 204 historic resources have been previously identified within the Planning Area; Culver City also has three designated historic districts: 11027 - 11047 Braddock Drive, 4052 - 4070 Lafayette Place, and 4128 - 4181 McConnell Boulevard. While General Plan 2045 goals and policies will help promote the preservation of historic resources, these policies do not require the identification and evaluation of historic-age properties to determine if there are historical resources within or nearby a proposed project site that could be adversely impacted by a future development, nor do they require the retention or rehabilitation of historical resources. Therefore, future development implemented as a result of the Project could result in a potentially significant impact related to historical resources during construction.
Implementation of MM CUL-1 will help to reduce the severity of the impacts. However, even with implementation of this mitigation measure, impacts will remain significant and unavoidable.
Cumulative Historical Resources Impacts
Facts/Effects: Future development in the Planning Area, including growth anticipated under the Project, 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 the General Plan 2045 policies, as well as applicable local, state, and federal laws and MM CUL-1, the Project’s contribution to this potentially significant cumulative impact will be cumulatively considerable.
Cumulative impacts to historic resources are considered significant and unavoidable.
Noise
Draft PEIR Section 4.12 evaluates the potential noise impacts that could result from implementation of the Project.
Findings of Fact Required by CEQA
36 Temporary or Permanent Increase in Ambient Noise Levels (Impact NOI-1) Facts/Effects: Construction activity noise levels will fluctuate depending on the particular type, number, and duration of use of the various pieces of construction equipment. The exact locations of future projects and construction that will occur under the Project are not known at this time, though it is assumed that some of the activities will take place in close proximity to sensitive receptors given that the City is generally built out. Even with mandatory compliance with Municipal Code requirements, it is possible that some future development projects could include construction in which multiple pieces of heavy-duty construction equipment and/or heavy-duty trucks may be required and that construction period noise levels could exceed the significance thresholds. Therefore, project-related construction activities could result in a significant impact.
With regard to operational noise, future development that will occur as a result of the Project will generate traffic that will increase noise levels along roadways. Future traffic noise levels were evaluated along 62 roadway segments within the city. Traffic noise along the analyzed roadway segments will not be discernably different for the majority of the segments when future no project levels are compared to future roadway noise levels with project levels (Table 4.12-10).
However, since noise levels could increase at the property line above the threshold along Washington Boulevard between Inglewood Boulevard and S Centinela Avenue, the impact from traffic noise will be significant and unavoidable. There are no feasible mitigation measures to reduce traffic noise levels.
With regard to railway noise, the Metro E Line passes through the northeast portion of the City with the Culver City Station located just east of the intersection of Venice Boulevard and S.
Robertson Boulevard. New or renovated noise-sensitive uses along the Metro E Line route in Culver City will be required to evaluate potential train noise levels at the individual site and, if required, incorporate building designs or mitigation measures to meet applicable exterior and/or interior noise standards. Stationary noise, such as rooftop heating, ventilation, and air conditioning units, will be required to comply with applicable regulations. Therefore, the impact from railway noise and stationary equipment will be less than significant.
Implementation of MM NOI-1 will help to reduce the potentially significant construction-related impacts resulting from a substantial temporary increase in ambient noise levels in the vicinity of future development projects in excess of the threshold. However, even with implementation of MM NOI-1, impacts could exceed the significance thresholds and impacts will be significant and unavoidable.
Excessive Groundborne Vibration or Groundborne Noise (Impact NOI-2) Facts/Effects: As indicated above, the locations of future projects and construction methods for the future projects are not known at this time. However, it is assumed that some of the activities will take place in close proximity to sensitive receptors given that the City is generally built out.
With regard to structural damage and human annoyance during construction, activities could generate excessive ground vibration and potentially exceed damage criteria for surrounding existing structures. In addition, multiple pieces of equipment or other sources of groundborne
Findings of Fact Required by CEQA
37 vibration and/or groundborne noise could cause levels to exceed the threshold. Therefore, future development projects that will occur under the Project could result in a significant impact.
During operation, future projects 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 from traffic and the operation of mechanical equipment is not expected to generate excessive vibration or noise. Therefore, impacts during operation relative to groundborne vibration and groundborne will be less than significant.
Implementation of MM NOI-2 will reduce the severity of the impacts to excessive groundborne vibration or groundborne noise during construction. However, even with implementation of MM NOI-2, impacts during construction could exceed the significance thresholds and construction impacts will be significant and unavoidable.
Cumulative Noise and Vibration Impacts
Facts/Effects: Noise is a localized phenomenon, and because the City is predominately developed with urban uses, it is possible that multiple construction projects could occur simultaneously and in close enough proximity to create significant combined noise and vibration impacts. Therefore, the contribution of the Project to any potential cumulative construction noise impact would be cumulatively considerable. Cumulative noise during construction could be significant and unavoidable.
The City is predominately developed with urban uses; thus, infill development or redevelopment of existing uses in various areas of the City is expected to occur. Through compliance with the CCMC noise control ordinance, the impact from stationary noise would not be cumulatively considerable. Cumulative impacts from stationary equipment will be less than significant.
However, the increase in traffic noise from the future development in conjunction with ambient growth in the region could result in a significant cumulative impact. The Project will result in a significant and unavoidable impact along one roadway segment. The Project buildout traffic volumes, which includes increases in traffic due to ambient growth in surrounding areas, was compared to existing traffic volumes. Sensitive receptors located near roadway segments will experience cumulative noise level increases above the threshold along two roadway segments (Slauson Avenue between Jefferson Boulevard and Sepulveda Boulevard and Slauson Avenue between W Jefferson Boulevard and Washington Boulevard) (Table 4.12-12). Therefore, the Project will contribute to cumulative traffic noise and cumulative impacts will be significant and unavoidable.
With regard to vibration, during construction it is possible that multiple construction projects could occur simultaneously and in close enough proximity to create a significant combined vibration impact. Therefore, the Project could contribute to a potential cumulative construction vibration impact. Cumulative vibration during construction could be significant and unavoidable.
Findings of Fact Required by CEQA
38 During operation, vibration from vehicles will be temporary and intermittent. Vibration levels from traffic generated by growth anticipated by the Project will be well below the thresholds for human annoyance and structural damage. Therefore, the contribution of the Project to any potential cumulative operational (traffic) vibration impact will not be cumulatively considerable.
Cumulative vibration impacts during operation will be less than significant.
Transportation
Draft PEIR Section 4.16 evaluates the potential transportation impacts that could result from implementation of the Project.
Conflict with CEQA Guideline Section 15064.3, Subdivision (b) (Impact TR-2) Facts/Effects: Fehr & Peers conducted a VMT assessment of the entire Culver City, using the Culver City Citywide Travel Demand Forecasting Model to obtain daily vehicle trips, daily VMT, and VMT per capita metrics. At buildout, the Project will result in a 0.95 percent decrease in residential VMT per capita compared to the existing conditions, a 7.26 percent decrease in work VMT per employee compared to existing conditions, and a 3.60 percent increase in total daily VMT per service population (Table 4.16-1). While there would be a resulting reduction in VMT compared with existing conditions, the Project will result in an average daily VMT per capita, VMT per employee, and total VMT per service population above the 15 percent reduction threshold. Even with implementation of all goals and policies contained in the Mobility Element that promote transit priority lanes, multimodal connectivity, integrated public transportation services, and prioritize public transit and mobility service, the Project will not meet the 15 percent VMT reduction threshold. Thus, the Project will result in significant VMT impacts.
There are no feasible mitigation measures to reduce the severity of this impact.
Cumulative Transportation Impacts
Facts/Effects: The Project will have a cumulative impact if average daily VMT per capita and VMT per employee at buildout would exceed the corresponding VMT metrics, and if total VMT would exceed the total VMT for the existing conditions. The daily VMT per capita, per employee, and per service population for the existing conditions and buildout of the Project demonstrate that all the VMT metrics are lower in the Project buildout scenario than the existing conditions, indicating that the Project buildout scenario has no cumulative impact on VMT (Table 4.16-2).
Cumulative impacts relative to VMT will be less than significant.
Mitigation Monitoring Program
CEQA requires the Lead Agency approving a project to adopt a Mitigation Monitoring Program (MMP) or the changes to the project which it has adopted or made a condition of project approval to ensure compliance with the mitigation measures during project implementation (see the attachment to these Findings and Statement of Overriding Considerations). The mitigation measures included in the PEIR as certified by the City serve that function. The MMP includes all the mitigation measures adopted by the City in connection with the approval of the Project and has been designed to ensure compliance with such measures during implementation of the Project. In accordance with CEQA, the MMP provides the means to ensure that the mitigation
Findings of Fact Required by CEQA
39 measures are fully enforceable. In accordance with the requirements of PRC Section 21081.6, the City hereby adopts the MMP.
Evaluation of Alternatives
In accordance with CEQA Guidelines Section 15126.6(a), 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 Project’s objectives are provided above in the section entitled Project Objectives. In addition, CEQA Guidelines Section 15126.6(b) states that the selection of project alternatives “shall focus on alternatives to the project or its location which are capable of avoiding or substantially lessening any significant effects of the project, even if these alternatives would impede to some degree the attainment of the project objectives, or would be more costly.” Because the Project would result in significant and unavoidable environmental impacts after implementation of the mitigation measures with regard to air quality, cultural resources, noise, and transportation. The City considered alternatives to the Project specifically to reduce those impacts. CEQA Guidelines Section 15126.6(f) further direct that “the range of alternatives required in an EIR is governed by a “rule of reason” that requires the EIR to set forth only those alternatives necessary to permit a reasoned choice.” CEQA Guidelines Section 15126.6(f) goes on to say that the “range of feasible alternatives shall be selected and discussed in a manner to foster meaningful public participation and informed decision making.” The EIR considers a total of four alternatives to the Project. Two alternatives were considered but were not selected for further analysis due to a failure to meet most of the basic Project Objectives, infeasibility, and/or an inability to avoid significant environmental impacts. Two alternatives were comprehensively evaluated in the Draft EIR, including the “no project” alternative and a corridors alternative, which clusters new development around major thoroughfares throughout the city. 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. In general, the environmentally superior alternative is the alternative with the least adverse impacts on the environment.
The alternatives considered or evaluated in the Draft PEIR include:
• Alternative 1 – No Project Alternative
• Alternative 2 – Concentrated Growth Alternative
• Alternative 3 – Modified Mixed Use High Designation
The impacts of each of alternative evaluated in detail in the Draft EIR are compared to the Project’s impacts in Draft PEIR Chapter 5, Alternatives, with a summary of comparative impacts provided in Draft PEIR Table 5-2.
Findings of Fact Required by CEQA
40 Alternatives Considered and Rejected
As set forth in CEQA Guidelines Section 15126.6(c), an EIR should identify any alternatives that were considered for analysis, but rejected as infeasible, and briefly explain the reasons for their rejection. According to the CEQA Guidelines, among the factors that may be used to eliminate an alternative from detailed consideration are the alternative’s failure to meet most of the basic project objectives, the alternative’s infeasibility, or the alternative’s inability to avoid significant environmental impacts.
As identified in PRC Section 21081(a)(3) and CEQA Guidelines Section 15091(a)(3), findings are required only for “alternatives identified in the environmental impact report.” Alternatives that are not reviewed in detail in the EIR because they have been determined to be infeasible need not be discussed in the findings (Crenshaw Subway Coalition v Los Angeles County Metro.
Transp. Auth. (CD Cal, Sept. 23, 2015, No. CV 11-9603 FMO [JCx]) 2015 US Dist Lexis 143642, 2015 WL 6150847). Therefore, findings are not provided for alternatives considered in the Draft EIR and rejected from detailed analysis.
Dispersed Densification Alternative
The Dispersed Densification Alternative would distribute 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. 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. In addition, under this alternative, incremental and moderate densification would occur in the single-family and low- density residential areas.
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. 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 was eliminated from further consideration.
Reduced Buildout Alternative
The Reduced Buildout Alternative would result in reduced residential and non-residential intensities/densities compared to the Project. The Reduced Buildout Alternative would not fully achieve the Project’s objectives, as the City may not be able to accommodate its Regional Housing Needs Assessment 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 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
Findings of Fact Required by CEQA
41 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.
Alternatives Analyzed in the PEIR
Alternative 1 – No Project Alternative
Under the No Project Alternative, future development would be subject to current land use designations in the City’s adopted 1996 General Plan as amended to date and the current Zoning Code. 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 and Zoning Code. No amendments would occur to areas identified for change under the Project and no new land use or zoning designations would be created. The City would not comprehensively update its Land Use Element or Land Use Map to increase densities or intensities across the city.
Finding. The City rejects the No Project Alternative and finds that the alternative is infeasible because, although it is environmentally superior to the Project, it would not meet most of the Project objectives and would not meet the underlying purpose of the Project since it 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 2045.
Basis for Finding. The No Project Alternative would reduce some of the significant impacts associated with the Project but significant and unavoidable impacts would remain. In addition, some impacts under the No Project Alternative, such as Aesthetics, Greenhouse Gas Emissions, Land Use, and Recreation would be greater. Under the No Project Alternative, the City would not adopt and implement a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Code to implement the General Plan 2045. Under Alternative 1, none of the land use designations and policies in the General Plan 2045 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. There would not be sufficient land capacity to fully meet the City’s allocation under the 6th cycle of the RHNA in a comprehensive, thoughtful manner. Alternative 1 would not meet the key goals of the Project to promote mixed-use development, better integrate land uses, improve alternate modes of transportation, equity (housing and health), and sustainability. Alternative 1 would not 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
Findings of Fact Required by CEQA
42 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.
Alternative 2 – Concentrated Growth Alternative
The Concentrated Growth Alternative would be similar to the Project but would result in a different land use distribution strategy and reduced growth. Under Alternative 2, all of the proposed elements except the Land Use Element of the General Plan 2045 would remain the same as under the Project. 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 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. Commercial corridors such as Washington Boulevard and Sepulveda Boulevard would be upzoned to allow for higher densities. 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 would be designated Mixed Use Medium (MUM) thereby allowing greater density along the corridor than the Project. Areas along Jefferson under Alternative 2 would have less Industrial Mixed Use 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. Similar to 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. However, 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.
Finding. The City rejects the Concentrated Growth Alternative because while it would achieve all of the Project objectives, Alternative 2 would not meet future needs based on the projected population and job growth to the same degree as the Project.
Basis for Finding. The Concentrated Growth Alternative would reduce 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, but significant and unavoidable impacts would remain. Under the Concentrated Growth Alternative, the City would result in a different land use distribution strategy than the Project. The Concentrated Growth Alternative would adopt and implement a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Code to implement the General Plan 2045. Alternative 2 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.
While Alternative 2 would achieve all of the objectives for the Project, Alternative 2 would not meet future needs based on the projected population and job growth to the same degree as the Project.
Findings of Fact Required by CEQA
43 Alternative 3 – Modified Mixed Use High Designation
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 Alternative 3, all of the proposed elements except the Land Use Element of the General Plan 2045 would remain the same as under the Project.
The Modified Mixed Use High Designation Alternative is projected to result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project.
Alternative 3 would differ from the Project in that the residential densities in the Mixed Use High designation would be reduced from 100 units per acre to 80 units per acre, and the maximum floor area ratio (FAR) would decrease from 4.0 to 3.5. The areas that would have a reduced density include areas designated Mixed Use High in Fox Hills, along Sepulveda Boulevard, on Washington Boulevard in the vicinity of the Metro Station, and at Washington Boulevard and Overland Avenue. In addition, with the reduction of residences there would be a reduction in the amount of incidental commercial floor area compared with the Project.
Finding. The City rejects the Modified Mixed Use High Designation Alternative because while it would achieve all of the Project objectives, Alternative 3 would not meet future needs based on the projected population and job growth to the same degree as the Project.
Basis for Finding. The Modified Mixed Use High Designation Alternative would reduce 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, but significant and unavoidable impacts would remain. The Modified Mixed Use High Designation would adopt and implement a comprehensive update to the Culver City General Plan and amendments to the City’s Municipal Code to implement the General Plan 2045. 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. 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.
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. The comparative impacts of the Project and the Project alternatives are summarized in Draft PEIR Table 5-2, Comparison of the Impacts of the Project and Alternatives.
Findings of Fact Required by CEQA
44 Alternative 2, the Concentrated Growth Alternative, is considered the environmentally superior alternative since 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.
45 Statement of Overriding
Considerations
The City Council finds on the basis of the Final PEIR and the record of proceedings in this matter that the significant and unavoidable impacts of the Project are acceptable when balanced against the benefits of the Project. This determination is based on the following factors and the substantial public, social, economic, and environmental benefits flowing from the Project as identified in the Final PEIR and the record of proceedings in the matter. Based on the analysis provided in Draft PEIR Chapter 4, Environmental Impact Analysis, implementation of the Project will result in significant impacts that cannot be feasibly mitigated with respect to air quality, cultural resources (historic), noise, and transportation.
Considering the information contained in and related to the Final PEIR, and pursuant to CEQA Guidelines Section 15092, the City Council finds that in approving the Project, it has eliminated or substantially lessened all significant and potentially significant effects of the Project on the environment where feasible as shown in these Findings. The City Council further finds that it has balanced the economic, social, technological and other benefits of the Project against the remaining unavoidable environmental risks in determining whether to approve the Project and has determined that those benefits outweigh the unavoidable risks and that those risks are acceptable. The City Council makes this statement of overriding considerations in accordance with CEQA Guidelines Section 15093 in support of approval of the Project. Specifically, in the City Council’s judgment, the benefits of the Project, as proposed, outweigh the significant and unavoidable impacts, and the Project should be approved. The following provides the City Council’s rationale:
California Government Code Section 65300 et seq. mandates that all counties and incorporated cities prepare a general plan that establishes policies and standards for future development, housing affordability, and resource protection. State law encourages cities to keep general plans current through regular updates. The Project includes the first comprehensive update of the Culver City General Plan. Previously, the City’s various General Plan elements have been updated between 1968 and 2014. In addition, the Project includes the Zoning Code Update necessary to implement the General Plan 2045, including the 2021-2029 Housing Element that was adopted in August 2022.
The Project will result in a comprehensive General Plan consisting of 13 elements that each focus on particular issues and provide strategies for sustainable future growth and a Zoning Code that provides the mechanism to implement the General Plan 2045. The Project will guide the evolution of the land use pattern to accommodate growth through thoughtful infill development and redevelopment. The Project provides the roadmap for the city to increase the housing supply consistent with the 6
th cycle Regional Housing Needs Assessment allocation
and allocations through the 2045 planning horizon with a mix of housing types in an equitable manner. In addition, the Project will foster harmony between people and the environment S
tatement of Overriding Considerations
46 through continued sustainability efforts in compliance with state requirements. The General Plan 2045 establishes the course for the next two decades for the city to foster a vibrant, unique, and diverse community with a strong social and economic fabric stitched together by its arts and cultural assets, creative enterprises, high-quality services, and inclusiveness. Core values include equity and inclusion; sustainability; innovation and creativity; and compassion and community. The Project will 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 future development, housing, transportation, environmental quality, public services, parks, open space, and environmental justice; • Help the City achieve compliance with applicable state and regional policies, includi ng
hous
ing 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 implementi ng
pr
ograms, such as the zoning ordinance and future specific plans.
Attachment
Mitigation Monitoring Program
EXHIBIT B
General Plan 2045 and Zoning Code Update Project 4-1 SCH No. 2022030144 City of Culver City July 2024
CHAPTER 4
Mitigation Monitoring Program
This Mitigation Monitoring Program (MMP), which is provided in Table 4-1, Mitigation Monitoring Program, below, has been prepared pursuant to Public Resources Code (PRC) Section 21081.6, which requires a Lead Agency to adopt a “reporting or monitoring program for changes to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment.” In addition, Section 15097(a) of the State California Environmental Quality Act ( CEQA) Guidelines requires that a public agency adopt a program for monitoring or reporting mitigation measures and project revisions, which it has required to mitigate or avoid significant environmental effects. The City of Culver City is the Lead Agency for the General Plan 2045 and Zoning Code Update. Collectively referred to as the Project.
The MMP provides the mitigation measures for the Project and the monitoring implementation responsibility for each measure. The MMP for the Project will be in place through all phases of implementation of the Project, including design, construction, and operation.
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-2 SCH No. 2022030144 City of Culver City July 2024
TABLE 4-1
MITIGATION MONITORING PROGRAM FOR THE GENERAL PLAN 2045 AND ZONING CODE UPDATE Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Air Quality
MM AQ-1: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of NOX, CO, PM10 and/or PM2.5 shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off-Road New Diesel Engine Emission Standards for construction equipment with more than 50 horsepower, unless it can be demonstrated to the Culver City Department of Building and Safety that such equipment is not available.
Project sponsors should also consider including zero emissions (ZE) or zero net emissions (ZNE) technologies where appropriate and feasible or higher tier standard diesel equipment as it becomes developed and feasible. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine, as defined by CARB regulations. Prior to construction, the project engineer shall ensure that all plans for construction phases (e.g., demolition, grading) that would exceed the SCAQMD significance thresholds clearly show the requirement for USEPA and/or CARB Tier 4 or higher emissions standards for construction equipment over 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the construction site for verification by the Culver City Department of Building and Safety. The construction equipment list shall state the makes, models, and numbers of construction equipment on-site. Equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with Section 2449 of the California Code of Regulations, Title 13, Article 4.8, Chapter 9.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
MM AQ-2: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of volatile organic compounds (VOCs) as a result of VOC off-gassing emissions from architectural coatings and industrial maintenance coatings shall require the construction contractor to use SCAQMD Low-VOC and/or Super Compliant VOC architectural coatings and industrial maintenance coatings such that daily volume of coatings applied would not result in emissions that exceed the SCAQMD significance threshold for VOC, unless it can be demonstrated to the City Department of Building and Safety that such coatings for a required application are not available. During construction, the construction contractor shall maintain a list of all architectural coatings and industrial maintenance coatings in use on the construction site and the daily volumes of coatings applied for verification by the Culver City Department of Building and Safety.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-3 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM AQ-3: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, show on the building plans that all major appliances (dishwashers, refrigerators, clothes washers, and dryers) to be provided/installed are Energy Star– certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star or equivalent appliances shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-4: Applicants for new residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the feature below has been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy. • For multifamily dwellings, electric vehicle charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the CALGreen Code (or its successor code).
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-5: Applicants for new non-residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the features below have been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
• Facilities shall be installed to support future electric vehicle charging at each nonresidential building with 30 or more parking spaces. Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-4 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM AQ-6: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential localized project construction-related air quality impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing localized significance thresholds (LST) air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the Planning Department.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-7: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential health risk impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing health risk impacts. If health risk impacts are determined to have the potential to exceed the SCAQMD- adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City’s Planning Department.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
Biological Resources
MM BIO-1: Baseline Biological Assessment. The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat (see Figure 34, Vegetation, of the Conservation Element) provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats. The impact analysis will aid in determining any direct, indirect, and cumulative biological impacts from construction and operations, as well as specific mitigation or avoidance measures necessary to offset significant impacts associated with future projects. The Biological Assessment shall include the following information:
a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region [State CEQA Guidelines, § 15125(c)].
b. A thorough, recent, floristic-based assessment of special status plants and natural communities, following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018); Project Applicant Prior to construction Culver City Planning and Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-5 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency c. Floristic, alliance- and/or association-based mapping and vegetation impact assessments conducted at the project site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment (Sawyer et al, 2008). Adjoining habitat areas shall be included in this assessment where site activities could lead to direct or indirect impacts off-site. Habitat mapping at the alliance level will help establish baseline vegetation conditions;
d. A complete, recent assessment of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species (Fish & Game Code, §§ 3511, 4700, 5050 and 5515). Species to be addressed should include all those which meet the CEQA definition of endangered, rare or threatened species (State CEQA Guidelines, § 15380); and,
e. Identification of focused surveys for special-status plants and/or wildlife that could be directly or indirectly impacted by the project, which shall be conducted in the appropriate season prior to any habitat disturbance.
f. Identification of any aquatic habitats such as rivers, streams, and lakes and their associated natural plant communities/habitats. This includes any culverts, ditches, storm channels that may transport water, sediment, pollutants, and discharge into rivers, streams, and lakes.
g. Avoidance and minimization measures (such as preconstruction wildlife clearance surveys) to fully avoid and otherwise protect sensitive biological resources from Project- related construction and operational impacts shall be identified and implemented. If impacts cannot be avoided, appropriate mitigation measures to offset potential special-status species and habitat impacts shall be identified and implemented.
MM BIO-2: Nesting Bird Surveys. Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any tree and/or vegetation removal within the Project site.
The nesting bird surveys shall be conducted at appropriate nesting times and concentrate on potential roosting or perch sites. Pre-construction surveys shall be conducted by a qualified biologist no more than 7 days prior to the beginning of any Project-related activity likely to impact raptors and migratory songbirds. If construction activities are delayed or suspended for more than 7 days during the breeding season, the surveys shall be repeated. If nesting raptors and migratory songbirds are identified, the following minimum no disturbance buffers shall be implemented: 100 feet around active passerine (perching birds and songbirds) nests, 300 feet around active raptor nests. These buffers should be maintained until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-6 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Cultural Resources
MM CUL-1: Prior to development of individual projects that are subject to CEQA within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Professional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center or Built Environment Resources Directory (BERD) search; a review of pertinent archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified potentially eligible historic resources will be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be fully evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mitigation for affected historical resources to be implemented prior to their demolition or alteration.
Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.
Project Applicant Prior to construction Culver City Planning and Development Department
MM CUL-2: Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a qualified archaeologist, defined as an individual meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology, to conduct an archaeological resources assessment. This assessment shall include a records search at the South Central Coastal Information Center; a Sacred Lands File search at the Native American Heritage Commission; and a pedestrian field survey of the project site. If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for eligibility in the California Register and local register. If a resource is determined to be eligible and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, archaeological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the archaeological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.
Project Applicant Prior to construction Culver City Planning and Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-7 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Geology and Soils
MM GEO-1: Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a Qualified Paleontologist, defined as an individual meeting the Society of Vertebrate Paleontology (SVP) Standard, to conduct a site-specific paleontological resources assessment. This assessment shall include a records search at the Natural History Museum of Los Angeles County and/or other appropriate facilities, geologic map and scientific literature review, and a pedestrian field survey (if deemed appropriate by the Qualified Paleontologist). If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for significance pursuant to CEQA, SVP, and/or a local register. If a resource is determined to be significant and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, paleontological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the paleontological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
Noise
MM NOI-1: Construction Noise. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) shall submit a noise study to the City Planning Department for review and approval prior to issuance of a grading or building permit.
The study shall include noise-reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards as applicable to construction (i.e., CCMC Chapter 9.07). All noise-reduction measures approved by City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during construction activities. Potential noise-reduction measures may include, but are not limited to, one or more of the following, as applicable to the project:
• Install temporary sound barriers for construction activities that occur adjacent to occupied noise-sensitive receptors.
• Equip construction equipment with effective mufflers, soundinsulating hoods or enclosures, vibration dampers, and other Best Available Control Technology (BACT). • Limit non-essential idling of construction equipment to no more than five minutes per hour.
This mitigation measure shall not apply and is superseded once a Citywide noise ordinance goes into effect that establishes construction noise standards for noise- reduction measures that ensures project construction noise compliance with the Culver City Noise Ordinance standards for development projects within the City.
Project Applicant Prior to issuance of a
grading or building permit
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-8 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM NOI-2: Construction Vibration. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that are located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) shall submit a vibration impact evaluation to the City Planning Department for review and approval prior to issuance of a grading or building permit. The evaluation shall include a list of project construction equipment and the associated vibration levels and a predictive analysis of potential project vibration impacts. If construction-related vibration is determined to exceed applicable standards, project-specific measures shall be required to ensure project compliance with vibration standards. All project-specific measures approved by the City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during project construction.
Examples of equipment vibration source-to-receptor distances at which impact evaluation should occur vary with equipment type (based on FTA reference vibration information) and are as follows:
• Jackhammer: 23 feet.
• Dozer, hoe-ram, drill rig, front-end loader, tractor, or backhoe: 43 feet. • Roller (for site ground compaction or paving): 75 feet. • Impact pile-driving: 280 feet.
This mitigation measure shall not apply and is superseded once a Citywide groundborne vibration ordinance goes into effect that establishes construction groundborne vibration standards for vibration-reduction measures that ensures project construction groundborne vibration compliance with applicable standards for development projects within the City Planning Area.
Project Applicant Prior to issuance of a
grading or building permit
Culver City Planning and
Development Department
General Plan 2045 and Zoning Code Update Project
Final Environmental Impact Report
State Clearinghouse No. 2022030144
July 2024
EXHIBIT C
LINK TO DRAFT EIR APPENDICES
Advance Planning Division Webpage - General Plan 2045
Environmental Review
PREPARED FOR:
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
PREPARED BY:
Environmental Science Associates
633 West 5th Street
Suite 830
Los Angeles, CA 90071
July 2024
General Plan 2045 and Zoning Code Update Project
Final Environmental Impact Report
State Clearinghouse No. 2022030144
General Plan 2045 and Zoning Code Update Project i SCH No. 2022030144 City of Culver City July 2024
CONTENTS
Final Environmental Impact Report
Page
Chapter 1. Introduction ...................................................................................................... 1-1
1.1 Purpose of the Final EIR .................................................................................... 1-1
1.2 Project Summary ............................................................................................... 1-1
1.3 Overview of the CEQA Public Review Process for the Draft EIR ...................... 1-2
1.4 Organization of the Final EIR ............................................................................. 1-3 Chapter 2. Comments and Responses ............................................................................. 2-1
2.1 Responses to Individual Comments .................................................................. 2-2 Chapter 3. Revisions, Clarifications, and Corrections to the Draft PEIR ...................... 3-1 Chapter 4. Mitigation Monitoring Program ...................................................................... 4-1 Figure
Figure 2-15 Proposed Zoning Map (Revised) ...................................................................... 3-5 Tables
Table 2-1 List of Commenters ............................................................................................ 2-1 Table 4-1 Mitigation Monitoring Program for the General Plan 2045 and Zoning Code Update ..................................................................................................... 4-2 Appendix
A Original Comment Letters on the Draft EIR
Contents
General Plan 2045 and Zoning Code Update Project ii SCH No. 2022030144 City of Culver City July 2024
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General Plan 2045 and Zoning Code Update Project 1-1 SCH No. 2022030144 City of Culver City July 2024
CHAPTER 1
Introduction
1.1 Purpose of the Final EIR
The City of Culver City (City), as the Lead Agency under the California Environmental Quality Act (CEQA), has prepared this Final Program Environmental Impact Report (Final PEIR) for the proposed update to the General Plan, Picture Culver City: General Plan 2045 (General Plan 2045 or General Plan Update) and the associated Zoning Code Update that is necessary to implement the General Plan 2045. The General Plan 2045 and the Zoning Code Update are collectively referred to as the Project. (Project). This document, in conjunction with the Draft Program Environmental Impact Report (Draft PEIR), comprise the Final PEIR.
As described in CEQA Guidelines Sections 15088, 15089, 15090 and 15132, the Lead Agency must evaluate comments received on the Draft EIR and prepare written responses and consider the information contained in a Final EIR before approving a project. Pursuant to CEQA Guidelines Section 15132, a Final EIR consists of: (a) the Draft EIR or a revision of the Draft; (b) comments and recommendations received on the Draft EIR either verbatim or in summary; (c) a list of persons, organizations, and public agencies commenting on the Draft EIR; (d) the responses of the Lead Agency to significant environmental points raised in the review and consultation process; and (e) any other information added by the Lead Agency.
1.2 Project Summary
As further described in Chapter 2, Project Description, of the Draft PEIR, the Project is the adoption and implementation of a comprehensive update to the Culver City General Plan and amendments to the Zoning Code to implement the General Plan 2045. The General Plan 2045 would provide a framework and vision to guide growth and development within the Planning Area, which includes the City’s jurisdictional boundaries and its Sphere of Influence (SOI), through the planning horizon year of 2045. Together with the Zoning Code Update, the General Plan 2045 would serve as the basis for planning-related decisions made by City staff, the Planning Commission, and the City Council.
By law, a general plan must be an integrated, internally consistent statement of City policies.
Government Code Section 65302 requires that a general plan include the following seven elements: Land Use, Circulation, Housing, Conservation, Open Space, Noise, and Safety. Senate Bill (SB) 1000 and Government Code Section 65302 require that since disadvantaged communities have been identified within the City, the Plan must also address Environmental Justice either as a standalone element or integrating related goals, policies, and objectives
1. Introduction
General Plan 2045 and Zoning Code Update Project 1-2 SCH No. 2022030144 City of Culver City July 2024
throughout other elements. The General Plan 2045 includes a Community Health and Environmental Justice Element. Additional elements may be included as well, at the discretion of the City. The General Plan 2045 includes the following elements: Land Use and Community Design; Mobility; Conservation; Noise; Safety; Parks, Recreation, and Public Facilities; Greenhouse Gas Reduction, Infrastructure, Community Health and Environmental Justice; Economic Development; Arts, Culture, and Creative Economy; and Governance and Leadership. (The 2021-2029 Housing Element was adopted in August 2022.)
1.3 Overview of the CEQA Public Review Process for
the Draft EIR
In compliance with the CEQA Guidelines, the City, as the Lead Agency for the Project, has provided opportunities for the public to participate in the environmental review process. As described below, throughout the environmental review process, an effort was made to inform, contact and solicit input from the public and various State, regional, and local government agencies and other interested parties on the Project.
1.3.1 Initial Study/Notice of Preparation
Pursuant to the provision of CEQA Guidelines Section 15082, the City circulated a Notice of Preparation of an Environmental Impact Report and Community Meeting/EIR Scoping Meeting (NOP) to State, regional, and local agencies, and members of the public for a 34-day review period commencing March 1, 2022, and ending April 4, 2022. The purpose of the NOP was to formally notice that the City was preparing a Draft PEIR for the General Plan 2045, to present the environmental topics preliminarily identified by the City for evaluation in the Draft PEIR, and to solicit input regarding the scope and content of the information to be included in the Draft PEIR.
In order to maintain compliance with the recently adopted Housing Element and to comply with state law, the City expanded the scope of the project to include the Zoning Code Update, which implements the proposed General Plan 2045, including the Housing Element. As a result, the City issued a Recirculated NOP for a 33-day period commencing on February 15, 2024 and ending on March 18, 2024.
The NOP and Recirculated NOP (NOPs) included notification that a public scoping meeting would be held to further inform public agencies and other interested parties of the Project and to solicit input regarding the Draft PEIR. The City posted the NOPs on the City Planning website along with information regarding the process for providing comments. The NOPs, Initial Study, and comments received during the scoping processes of the Draft PEIR are contained in the Draft PEIR Appendix A.
The City conducted a virtual public scoping meeting on March 24, 2022 at 6:00 p.m. using Zoom.
As a result of the Recirculated NOP, a second virtual public scoping meeting was held on March 7, 2024 at 6:00 p.m. using Zoom. The public scoping meetings provided interested individuals, groups and public agencies the opportunity to provide oral comments to the lead
1. Introduction
General Plan 2045 and Zoning Code Update Project 1-3 SCH No. 2022030144 City of Culver City July 2024
agency regarding the scope and focus of the Draft PEIR as described in the NOPs. The meetings included a presentation by the City and their environmental consultant that included an overview of the Project, information regarding the CEQA process and opportunities for public input, issues identified for analysis in the Draft PEIR, and solicitation of oral and written comments on environmental issues and alternatives the public would like to see evaluated in the Draft PEIR.
During the two public review periods, 16 comment letter were submitted, eight during the 2022 NOP scoping period and eight during the 2024 Recirculated NOP scoping period).
Correspondence was received from the California Department of Fish and Wildlife (CDFW), California Department of Transportation (Caltrans), Los Angeles County Sanitation Districts, Los Angeles County Metropolitan Transportation Authority (LA Metro), Southern California Association of Governments (SCAG), South Coast Air Quality Management District (SCAQMD), Department of Toxic Substances Control (DTSC), the Native American Heritage Commission (NAHC), City of Los Angeles Wastewater Engineering Services Division, interested organizations, and interested parties. All written comments are provided in Appendix A of the Draft PEIR.
1.3.2 Draft Environmental Impact Report
In accordance with the provision of CEQA Guidelines Sections 15085(a) and 15087(a), the City, serving as the Lead Agency: (1) prepared and transmitted a Notice of Completion (NOC) to the State Clearinghouse; (2) published a Notice of Availability (NOA) of a Draft PEIR which indicated that the Draft PEIR was available for public review at the City’s Current Planning Division; (3) provided copies of the NOA and Draft PEIR to the Culver City Julian Dixon Library; (4) posted the NOA and the Draft PEIR on the City’s Planning Division website at:
https://www.pictureculvercity.com/environmental-review; (5) posted a condensed version of the NOA in the Culver City News; (6) sent an email with the NOA to the last known address of all organizations and individuals who previously requested such notice in writing or attended public meetings about the Project; and (7) filed the NOA with the County Clerk. The public review period commenced on March 28, 2024, and ended on May 13, 2024, for a total of 46 days.
During the Draft PEIR public review period, the City Planning Division received sixteen (16) comment letters on the Draft PEIR from agencies, organizations, and individuals through written correspondence and emails. These comment letters are included in Appendix A, Original Comment Letters, of this Final PEIR. All written comments received during the public review period of the Draft PEIR are presented, and responses are provided in Chapter 2, Comments and Responses, of this Final PEIR.
1.4 Organization of the Final EIR
The Final EIR consists of the following four chapters:
Chapter 1, Introduction. This c hapter describes the purpose of the Final EIR, provides a summary of the Project, summarizes the Draft PEIR public review process, and presents the contents of this Final PEIR.
1. Introduction
General Plan 2045 and Zoning Code Update Project 1-4 SCH No. 2022030144 City of Culver City July 2024
Chapter 2, Comments and Responses. This chapter presents all comments received by the City during the public review period of the Draft EIR as well as the responses to those comments.
Chapter 3, Revision s, Clarifications and Corrections to the Draft PEIR. This chapter includes revisions to the Draft PEIR that represent minor changes or additions in response to some of the comments received on the Draft PEIR, and additional edits to provide a correction to the Draft PEIR text. Changes to the Draft PEIR are shown with strikethrough text for deletions and double underline text for additions. These changes do not add significant new information that would affect the analysis or conclusions presented in the Draft PEIR.
Chapter 4, Mitiga tion Monitoring Program. The Mitigation Monitoring Program (MMP) is the document that will be used by the City to ensure the implementation of the mitigation measures.
Appendix A: Original Comment Letters on the Draft PEIR. Appendix A contains the comment l
etters on the Draft PEIR that were received by the City.
General Plan 2045 and Zoning Code Update Project 2-1 SCH No. 2022030144 City of Culver City July 2024
CHAPTER 2
Comments and Responses
This chapter of the PEIR provides responses to written comments received on the Draft PEIR.
CEQA Guidelines Section 15088(a) states that: “The lead agency shall evaluate comments on environmental issues received from persons who reviewed the draft EIR and shall prepare a written response. The Lead Agency shall respond to comments that were received during the noticed comment period and any extensions and may respond to late comments.” Table 2-1, List of Commenters, provides a list of the comment letters received. Each comment letter received on the Draft PEIR is assigned a number, as indicated in Table 2-1. The body of each comment letter has been separated into individual comments, which are numbered. Each comment that requires a response within the letters is also assigned a number. This results in a numbering system whereby the first comment in the first letter is identified as Comment 1-1, 1-2, and so on. The letter is included in its entirety with the bracketing for the individual comments, followed by the corresponding responses. The letters are provided in Appendix A, Original Comment Letters, of this Final PEIR.
TABLE 2-1
LIST OF COMMENTERS
Letter No. Name
1 South Coast Air Quality Management District (SCAQMD)
21865 Copley Drive
Diamond Bar, CA 91765
2 Gabrieleno Tribe of Mission Indians – Kizh Nation
PO Box 393
Covina, CA 1723
3 Los Angeles County Metropolitan Transportation Authority (LA Metro) One Gateway Plaza
Los Angeles, CA 90012
4 Jon Bridgeman
5 Anna Budevska
6 Yihui Gould
7 Gloria Moritz
8 Melissa Korc
9 Yumi Mandt-Rauch
10 Karyn Marks
11 Gil Ramirez
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-2 SCH No. 2022030144 City of Culver City July 2024
Letter No. Name
12 Pouran Saeedi
13 Judi Sherman
13A Judi Sherman
14 Sequoia Tully
15 Louise Wechsler
16 Jeff Willis
Where responses result in a change to the Draft PEIR, it is noted and the resulting change is identified in Chapter 3, Revisions, Clarifications, and Corrections to the Draft EIR, of this Final PEIR. As required by CEQA Guidelines Section 15088 (c), the focus of the responses to comments is on “the disposition of significant environmental issues raised.” Therefore, detailed responses are not provided for comments that do not relate to environmental issues.
2.1 Responses to Individual Comments
Responses to individual comments are included on the following pages.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-3 SCH No. 2022030144 City of Culver City July 2024
Letter 1
South Coast Air Quality Management District (SCAQMD)
21865 Copley Drive
Diamond Bar, CA 91765
Dated May 2, 2024
Comment 1-1
South Coast Air Quality Management District (South Coast AQMD) staff appreciates the opportunity to comment on the above-mentioned document. The City of Culver City is the California Environmental Quality Act (CEQA) Lead Agency for the Proposed Project. To provide context, South Coast AQMD staff has provided a brief summary of the project information and prepared the following comments organized by topic of concern.
South Coast AQMD Staff’s Summary of Project Information in the Draft PEIR Based on the Draft PEIR, the Proposed Project would replace the existing General Plan in its entirety to establish a long-term vision.
1 The land use designations in the Proposed Project are residential, mixed-use, and special purpose.2 The residential designation ranges from single-family homes to multi-family housing; mixed-use designations provide areas for a range of residential and commercial uses; and the special purpose designations are for a range of institutional uses and public facilities.
3 The Proposed Project would result in an estimated 12,700 new housing units4 and a net increase of 3.7 million square feet of non-residential development by 2045.5 1 Draft PEIR. Page 2-8.
2 Ibid. Page 2-13.
3 Ibid.
4 Ibid. Page 2-19.
5 Ibid. Page 2-20.
Response to Comment 1-1
This comment is introductory in nature and provides a summary of the Project. Responses to the specific comments raised are provided below in Responses to Comments 1-2 through 1-5.
Comment 1-2
South Coast AQMD Staff’s Comments on the Draft PEIR
Emission Reductions from Health Risk Strategies
When certifying an EIR for a project, retain the authority to include any additional information deemed relevant to assessing and mitigating the environmental impacts. South Coast AQMD is concerned about the potential public health impacts of sitting [sic] sensitive populations within the proximity of existing air pollution sources (e.g., freeways and railroads). For this reason, prior to approving future development projects, the Lead Agency is recommended to consider the impacts of air pollutants on people who will live in a new project and provide effective mitigation. Additionally, South Coast AQMD suggests that the Lead Agency review and apply the
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-4 SCH No. 2022030144 City of Culver City July 2024
guidance provided in 1) the California Air Resources Board (CARB) Air Quality Land Use and Handbook: A Community Health Perspective,6 which provides criteria for evaluating and reducing air pollution impacts associated with new projects involving land use decisions; and 2) CARB’s technical advisory which contains strategies to reduce air pollution exposure near high-volume roadways.
7 6 California Air Resources Board (CARB), Air Quality Land Use and Handbook: A Community Health Perspective, April 2005. Available at: https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf 7 CARB’s Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways. Available at:
https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf Response to Comment 1-2
This comment requests that the City of Culver City apply the guidance provided in CARB’s Air Quality Land Use and Handbook: A Community Health Perspective1 and CARB’s technical advisory.2 Draft PEIR Section 4.2, Air Quality, provides discussion of CARB’s Air Quality and Land Use Handbook and the Technical Advisory supplement on page 4.2-17. As discussed in the Draft PEIR, the Community Health Perspective and Technical Advisory serve as general guidance for considering impacts to sensitive receptors from facilities that emit TACs and infill development that may place them next to high volume roadways, which may occur as a result of future development under the General Plan and Zoning Code Update. Since these documents are guidance documents and do not constitute a requirement or mandate, the General Plan Update includes specific policies that reflect the guidance in these documents. The applicable General Plan policies that address the guidance in CARB’s handbook are CHEJ-2.7, Sensitive land uses, page 4.2-37 of the Draft PEIR, and C-4.4, Siting of uses near IOF, page 4.2-38. The applicable General Plan policy that addresses CARB’s Technical Advisory is C-4.3, Siting uses near freeways, on page 4.2-38 of the Draft PEIR. As demonstrated in the Draft PEIR, Section 4.2, Air Quality, the City of Culver City will utilize CARB’s Air Quality Land Use and Handbook and Technical Advisory to reduce potential health impacts from siting potential sensitive populations within the proximity of existing air pollution sources (e.g., freeways and railroads) and will incorporate strategies to reduce air pollution exposure near high-volume roadways.
Comment 1-3
Many strategies are available for residential receptors to reduce being exposed to particulate matter, including, but not limited to, HVAC systems equipped with filters rated at a minimum efficiency reporting value (MERV) 13 or higher air filtration capabilities. In some cases, MERV 15 or better is recommended for building design, orientation, location, vegetation barriers, landscaping screening, etc. Enhanced filtration units are capable of reducing exposure. However, enhanced filtration systems have limitations. For example, filters rated MERV 13 or higher are able to screen out greater than or equal to 50% of DPM, 8 but they have no ability to filter out
volatile organic compound (VOC) emissions. Also, in a study that South Coast AQMD conducted to investigate filters rated at MERV 13 or better in classrooms, 9,10 a cost burden is expected to
1 California Air Resources Board (CARB), Air Quality Land Use and Handbook: A Community Health Perspective, April 2005. Available: https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf. 2 CARB, Technical Advisory Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways. Available:
https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-5 SCH No. 2022030144 City of Culver City July 2024
be within the range of $120 to $240 per year to replace each filter panel. The initial start-up cost could substantially increase if an HVAC system needs to be installed and if standalone filter units are required. Installation costs may vary, including costs for conducting site assessments and obtaining permits and approvals before filters can be installed. Other costs may include filter life monitoring, annual maintenance, and training for conducting maintenance and reporting. In addition, the filters would not have any effect unless the HVAC system is running. Therefore, when in use, the increased energy consumption from each HVAC system should be evaluated in the Draft PEIR. While the filters operate 100 percent of the time when the HVAC is in use while the residents are indoors, the environmental analysis does not generally account for the times when the residents are not using their HVAC and instead have their windows or doors open or are moving throughout the common space outdoor areas of the Proposed Project. Furthermore, when used filters are replaced with new filters, emissions associated with trucks delivering the new filters and waste disposal trucks transporting the used filters to disposal sites should be evaluated in Draft PEIR. Therefore, any presumed effectiveness and feasibility of a particular HVAC filter should be carefully evaluated in more detail based on supporting evidence before assuming they will sufficiently alleviate exposure to DPM emissions. 8 U.S. EPA, “What is a MERV rating?” Available at: https://www.https://www.epa.gov/indoor-air-quality-iaq/what- merv-rating
9 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009.
Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf 10 International Journal of Indoor Environment and Health, Pilot Study of High-Performance Air Filtration for Classroom Applications, November 2012. Available at: https://onlinelibrary.wiley.com/doi/10.1111/ina.12013 Response to Comment 1-3
This comment discusses the use of HVAC equipped with MERV 13 to 15 filters in new development to reduce the exposure of residential receptors to particulate matter. The comment suggests that the environmental analysis include the increased energy use from incorporation of the MERV filters as well as emissions associated with trucks delivering new filters and trucks transporting used filters to disposal sites. The comment states that the effectiveness of a particular HVAC filter should be evaluated in more detail based on supporting evidence before assuming the filter will sufficiently alleviate exposure to DPM emissions.
As indicated in Chapter 1, Introduction, the Draft PEIR is a program-level document and as such does not evaluate the project-specific impacts of individual developments that would occur in the future under the Project. Therefore, an analysis of specific HVAC and MERV filters and associated impacts was not conducted. However, as discussed in Section 4.2, Air Quality (page
4.2-37), General Plan policy
CHEJ-2.7, Sensitive land uses, limits siting new sensitive land uses, such as schools, daycare centers, and playgrounds within 500 feet of freeways and the IOF. For sensitive land uses that cannot be sited at least 500 feet away, design mitigations are required, which include but are not limited to:
• Locate air intake systems for HVAC systems as far away from existing air pollution sources as possible.
• Use HEPA filters in the heating, ventilation, and air conditioning systems and develop a maintenance plan to ensure the filtering system is properly maintained.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-6 SCH No. 2022030144 City of Culver City July 2024
• For nonresidential buildings, consider using only fixed windows next to any existing sources of pollution.
• Plant landscape barriers between highways and residential areas to reduce noise and air pollution for residents.
Specific projects developed under the General Plan and Zoning Code Update would follow the siting guidelines of General Plan policy
CHEJ-2.7, and if required, an HVAC and MERV analysis
would be conducted. Therefore, discussion of the HVAC and MERV analysis is not appropriate in this PEIR as there is not a specific development project being evaluated. The appropriate analysis will be conducted, if necessary, in subsequent environmental documents for specific projects.
Comment 1-4
South Coast AQMD Air Permits and Role as a Responsible Agency If the implementation of the Proposed Project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, spray booths, etc., air permits from South Coast AQMD will be required, and the role of South Coast AQMD would change from a Commenting Agency to a Responsible Agency under CEQA. In addition, if South Coast AQMD is identified as a Responsible Agency, per CEQA Guidelines Sections15086, the Lead Agency is required to consult with South Coast AQMD. In addition, CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of evaluating the applications for air permits. For these reasons, the Final EIR should include a discussion about any new stationary and portable equipment requiring South Coast AQMD air permits and identify South Coast AQMD as a Responsible Agency for the Proposed Project.
Response to Comment 1-4
The comment states that permits from the SCAQMD would be required if new stationary or portable sources are required, and that the SCAQMD would become a Responsible Agency under CEQA instead of a Commenting Agency. As indicated in Response to Comment 1-3, the Draft PEIR is a program-level document and as such does not evaluate project-specific impacts of individual developments since no development is proposed at this time. Therefore, the details regarding the use of stationary or portable sources that would occur with future development under the General Plan and Zoning Code Update are unknown. As necessary, subsequent environmental documents for specific projects will include an analysis of stationary and portable sources. In addition, Chapter 1 indicates that the SCAQMD would be a Responsible Agency for future development projects under the General Plan 2045 and Zoning Code Update.
Therefore, while analysis of stationary and portable sources is not appropriate in this PEIR, future development would be required to comply with CEQA and obtain applicable permits.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-7 SCH No. 2022030144 City of Culver City July 2024
Comment 1-5
The Final EIR should also include calculations and analyses for construction and operation emissions for the new stationary and portable sources, as this information will also be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385 for questions regarding what types of equipment would require air permits. For more general information on permits, please visit South Coast AQMD’s webpage at http://www.aqmd.gov/home/permits.
Response to Comment 1-5
This comment states that the Final EIR should include calculations and analyses for construction and operation emissions of new stationary and portable sources. However, as discussed above in Response to Comment 1-4, the Draft PEIR is a program level document and there are no specific projects proposed at this time. Therefore, the specifics of development, including the use of stationary or portable sources, are unknown. environmental documents prepared for future development projects will provide an analysis, as needed, including calculation of construction and operational emissions of stationary and portable sources that would require a permit from the SCAQMD.
Comment 1-6
Conclusion
As set forth in California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b), the Lead Agency shall evaluate comments from public agencies on the environmental issues and prepare a written response at least 10 days prior to certifying the Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c), if the Lead Agency’s position is at variance with recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.
Thank you for the opportunity to provide comments. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter. Please contact Danica Nguyen, Air Quality Specialist, at [email protected] should you have any questions.
Response to Comment 1-6
In accordance with California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a-b), the City, as lead agency, has addressed environmental issues raised in this letter as well as other letters received. The issues raised by the SCAQMD are addressed in detail and in good faith. In addition, the City will provide written responses to all public agencies, including the SCAQMD, at least 10 days prior to certification of the PEIR.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-8 SCH No. 2022030144 City of Culver City July 2024
Letter 2
Gabrieleno Tribe of Mission Indians – Kizh Nation
PO Box 393
Covina, CA 91723
Dated March 22, 2024
Comment 2-1
Thank you for your letter dated March 28, 2024. Regarding the project above. This is to concur that we agree with the Specific Plan Amendment. However, our Tribal government would like to request consultation for all future projects within this location.
Response to Comment 2-1
The City assumes the comment is referring to the NOA for the Draft PEIR for the General Plan 2045 and Zoning Code Update, which was circulated on March 28, and not a proposed Specific Plan Amendment as stated in the comment. As indicated in Draft PEIR Section 4.17, Tribal Cultural Resources, the City sent notification and request to consult letters to seven individuals and organizations pursuant to AB 52 and SB 18. On March 4, 2022, February 28, 2024, and March 6, 2024, the City received responses from the Gabrieleño Band of Mission Indians – Kizh Nation (Kizh Nation). The Kizh Nation indicated they are in agreement with the General Plan 2045. As part of the consultation and as indicated in the comment, the Tribal government would like to request consultation for all future projects in the City, but it is the City’s assumption that this would apply only in instances where there would be the potential for ground disturbance.
As indicated in Section 4.17, future projects would be required to comply with the provisions of SB 18 and AB 52, as necessary, to incorporate tribal consultation into the review process to ensure that tribal cultural resources are properly identified and that mitigation measures are identified to reduce impacts on these resources. General Plan Policy C-1.16 also reinforces the continuation of consultation with Native American groups per the requirements of SB 18 and AB 52. Furthermore, the City would continue to implement standard conditions of approval that require and specify the steps to be taken to avoid damage and promote preservation if tribal cultural resources are uncovered during construction in support of the City’s goals for protection of cultural resources. As indicated in the Draft PEIR, with adherence to the regulations and consistency with the proposed General Plan policies and implementation actions, impacts with respect to tribal cultural resources would be less than significant.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-9 SCH No. 2022030144 City of Culver City July 2024
Letter 3
Los Angeles County Metropolitan Transportation Authority (LA Metro) One Gateway Plaza
Los Angeles, CA 90012
Dated May 10, 2024
Comment 3-1
Thank you for coordinating with the Los Angeles County Metropolitan Transportation Authority (Metro) regarding the proposed General Plan 2045 (Plan) located in the City of Culver City (City).
Metro’s mission is to provide a world-class transportation system that enhances quality of life for all who live, work, and play within Los Angeles County. As the County’s mass transportation planner, builder and operator, Metro is constantly working to deliver a regional system that supports increased transportation options and associated benefits, such as improved mobility options, air quality, health and safety, and access to opportunities.
Metro is committed to working with local municipalities, developers, and other stakeholders across Los Angeles County on transit-supportive planning and developments to grow ridership, reduce driving, and promote walkable neighborhoods. Transit Oriented Communities (TOCs) are places (such as corridors or neighborhoods) that, by their design, allow people to drive less and access transit more. TOCs maximize equitable access to a multi-modal transit network as a key organizing principle of land use planning and holistic community development.
Per Metro’s area of statutory responsibility pursuant to sections 15082(b) and 15086(a) of the Guidelines for Implementation of the California Environmental Quality Act (CEQA: Cal. Code of Regulations, Title 14, Ch. 3), for the purpose of this letter is to provide the City with specific detail on the scope and content of environmental information that should be included in the Environmental Impact Report (EIR) for the Project. Effects of a project on transit systems and infrastructure are within the scope of transportation impacts to be evaluated under CEQA. 1 Metro and the City have collaborated closely on several project [sic], including the Ivy Station Joint Development, Platform Greenspace, and active transportation improvements. We are committed to continuing a collaborative approach with respect to this Plan and future development projects adjacent to the E Line (Expo) in the City.
Project Description
The Project includes an update to the General Plan to respond to the changing needs and conditions of the conditions of the City and region to reflect new state laws. The General Plan will consist of 14 Elements. In addition to Elements required by the state, the General Plan Update (GPU) will also include Governance and Leadership; Arts and Culture; Reimagining Public Safety; Economic Development; Parks, Recreation, and Public Facilities; Climate Change and Sustainability; and Infrastructure.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-10 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 3-1
This comment provides an introduction to LA Metro and a description of the Project. Responses to the specific comments raised are provided below in Responses to Comments 3-2 through 3-11.
Comment 3-2
Recommendations for EIR Scope and Content
Transit Services and Facilities
The Plan and EIR should include updated information on existing and planned transit services and facilities within the Plan area. In particular, Metro’s NextGen Bus Plan (completed in December 2021) should be used as a resource to determine the location of high-frequency bus services and stops within the Plan area. For more information, visit to NextGen Bus Plan’s website at https://www.metro.net/projects/nextgen/. Please also refer to Metro’s 2020 Long Range Transportation Plan and Measure M Expenditure Plan.
Response to Comment 3-2
The comment states that the EIR should include updated information on existing and planned transit services and facilities within the Plan area, utilizing Metro’s transportation plans. Draft PEIR Section 4.16, Transportation, provides a description of the existing and planned transit within the Transportation section, under “Transit Conditions.” Specifically, the section details existing transit centers, fixed-route transit services, bus, and shuttle services.
The City is aware of NextGen network recommendations and expressed interest in partnering with LA Metro to increase the number of high frequency routes operating on proposed MOVE Culver transit priority corridors (particularly Sepulveda). A description of NextGen Bus Plan has been added to PEIR Subsection 4.16.3.
The General Plan designates Transit Priority Corridors that reallocate public right-of-way to support high-frequency transit service and other alternative modes. Improvements along these roadways may include installing transit priority lanes or other transit speed and reliability treatments. These corridors include Washington Boulevard, Sepulveda Boulevard, and Jefferson Boulevard. The Plan also calls for the City to explore candidate corridors that already serve local and regional high-frequency transit service recommended in subsidiary plans and studies including regional transit plans (like Next Gen), and the Transit Oriented Development Visioning Plan.
Impact Statement TR-1 in Draft PEIR Section 4.16 addresses any conflicts with adopted circulation programs, plans, ordinances, or policies. More specifically, Mobility Element Policy M-3.4 would prioritize transit capital investments and improvements that align with local plans as well as regional studies, and LA Metro’s Long Range Transportation Plan (LRTP). In addition, Mobility Element Policies M-3.4 (High-quality transit service), M-4.5 (Equitable transit access), and M-6.2 (Coordination with other jurisdictions to improve arterials, including neighboring jurisdictions, LA Metro, Southern California Association of Governments, and Caltrans) support
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-11 SCH No. 2022030144 City of Culver City July 2024
coordinating connections to Metro regional bus and rail services. The Threshold TR-1 discussion has been revised to address NextGen Bus Plan. Please see Chapter 3, Revisions, Clarifications, and Corrections to the Draft PEIR, of this Final PEIR for the revisions regarding NextGen Bus Plan.
These clarifications added to Section 4.16 do not affect the conclusions in the PEIR.
Comment 3-3
Adjacency to Metro-owned Right-of-Way (ROW) and Facilities The Plan area includes Metro-owned ROW and transit facilities for Metro Rail and Metro Bus.
This includes the E Line (Expo). Buses and trains operate 24 hours a day, seven days a week in these facilities.
The EIR’s transportation section should analyze potential impacts on Metro facilities within the Plan area, and identify mitigation measures or project design features as appropriate. Metro recommends reviewing the Metro Adjacent Development Handbook (available at https://www.metro.net/devreview) to identify issues and best practices for development standards arising from adjacency to Metro infrastructure. In addition, Metro recommends that the Plan includes a policy encouraging applicants to coordinate with Metro during the City’s Planning review if the subject parcel is within a 100-foot buffer of Metro infrastructure. Such projects should also comply with the Adjacent Development Handbook.
Response to Comment 3-3
Draft PEIR Section 4.16, Transportation, provides information regarding transit facilities, including buses lines, rail lines, and the E Line (pages 4.16-6 through 4.16-10). Culver City acknowledges connectivity to Metro Rail stations and Transit Centers as a high priority for the Culver CityBus network as well as other modes of transportation. In addition, as discussed in the Draft PEIR, in 2017 the City completed the Transit-Oriented Development Visioning Study and Recommendations, which aims to provide more and better choices for circulation by increasing the viability of alternative mobility mode choices to allow people to drive less and walk, bike, and take transit more. Please see Response to Comment 3-4 below for a discussion regarding connectivity.
Draft PEIR Section 4.16 includes a consistency analysis with adopted circulation programs, plans, ordinances, or policies. The analysis included a review of the Culver City Short Range Mobility Plan, Bicycle and Pedestrian Action Plan, Complete Streets Policy, and the Local Road Safety, which encourage use of active transportation and connections to Metro facilities. Policy M-3.1 addresses regional mobility coordination and prescribes that the City continue to coordinate with Metro and other municipal mobility service providers. In addition, Policy M-3.4 directs the City to prioritize capital investments and improvements to achieve high-quality transit service that aligns with the City’s Short Range Mobility Plan, regional studies, and LA Metro’s Long Range Transportation Plan. The Draft PEIR concludes that the Project would not conflict with any applicable program, plan, or ordinance on the circulation system, including transit, roadway, bicycle, and pedestrian facilities, and the impact would be less than significant.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-12 SCH No. 2022030144 City of Culver City July 2024
The General Plan’s Governance and Leadership Element addresses regional partnerships with outside agencies, including LA Metro, that the City has formed and will continue to strengthen.
Culver City actively participates in and maintains its regional partnerships. The City will continue to coordinate with LA Metro regarding the regional transportation system and will ensure coordination with Metro when development applications are submitted that are within proximity of Metro infrastructure.
Comment 3-4
Transit Supportive Planning: Recommendations and Resources Considering the Plan area’s inclusion of Culver City Station and key bus lines, Metro would like to identify the potential synergies associated with transit-oriented development:
1. Land Use: Me
tro supports development of commercial and residential properties near transit stations and understands that increasing development near stations represents a mutually beneficial opportunity to increase ridership and enhance transportation options for the users of developments. Metro encourages the City to be mindful of the Culver City Station within the Plan area and include strategies in proposed developments to orient pedestrian pathways towards the Station.
Response to Comment 3-4
The City acknowledges the benefits of locating commercial and residential properties near transit stations. The comment encourages Culver City to include strategies in proposed developments to orient pedestrian pathways towards Culver City Station. As discussed in Draft PEIR Section 4.10, Land use and Planning, the land use patterns associated with the General Plan 2045 help establish a clear multimodal network throughout the City by focusing on both community destinations as well as the efficiency, safety, and convenience of the modes of transportation in between. Higher densities, especially in areas with mixed-use designations, increase capacity for residential development near community-serving commercial, retail, and office uses as well as schools, parks, and recreational facilities. The Project identifies planned pedestrian, multimodal, and transit improvements for the City, which would improve mobility between neighborhoods and allow residents to travel throughout the city. The General Plan 2045 includes policies to allow higher residential density and intensity in mixed use developments to support walkability and transit use (Policy LU 1.1); and incentivize jobs and housing growth around high-quality transit stops and along transit corridors (Policy LU 1.3).
With regard to connectivity, policies in the General Plan 2045 aim to connect transit-oriented communities through strong pedestrian, Culver CityBus, other public transit, and bicycle connections to and from transit stops via pedestrian-oriented building design, safe and convenient road crossings, and street furniture and amenities (Policy LU 1.4). Further, the General Plan 2045 would ensure that new project applications foster pedestrian and bicycle access by providing safe, accessible pedestrian connections and creating secure and convenient bike storage (Policy LU 9.5). The General Plan 2045 also includes policies to create walkable connections in multifamily development (Policy LU 2.6); encourage more variety of public- and neighborhood-serving uses and affordable housing (Policy LU 8.1); and create community
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-13 SCH No. 2022030144 City of Culver City July 2024
gathering spaces in mixed use districts to provide publicly accessible, centrally located private open space (Policy LU 8.2).
The Mobility Element also contains policies that address the benefits of locating commercial and residential properties near transit stations and connectivity. Draft PEIR Section 4.16, Transportation, includes a discussion of existing and proposed pedestrian facilities as well as the Culver City Bicycle and Pedestrian Action Plan, which establishes a long-term vision for improving walking in Culver City. In addition, the Draft PEIR provides a discussion of the Transit- Oriented Development (TOD) Visioning Study and Recommendations, which was adopted in 2017 to foster multimodal connectivity and provide pedestrian connections at the Metro E Line Culver City Station. As discussed in Draft PEIR Section 4.16, the General Plan 2045 contains Goal M-5, which calls for a sustainable and accessible transportation system and transit-oriented communities. The City’s goal, as expressed in M-5, is to establish and promote a sustainable and accessible transportation system that provides great multimodal travel experiences for residents, workers, and visitors through mobility planning, transportation demand management, and transit-oriented districts, corridors, and developments. This goal is supported by policies, including Policy M-5.1 to continue to implement the 2017 TOD Visioning Study and Recommendations. With regard to connectivity, the General Plan 2045 includes policies that would improve connections to local and regional transit services (Policy M-2.3) and encourage the use of alternative modes of transportation (Policy M-5.2), including walking and biking through supportive land use development.
The comment does not raise any issues with respect to the content or adequacy of the Draft EIR, and thus no further response is necessary.
Comment 3-5
2. Transit Connections and Access: Given the Plan area’s proximity to Culver City Station, the Plan should include policies and/or design standards to accommodate transfer activity between bus and rail customers that will occur along the sidewalks and public spaces. Metro completed the Metro Transfers Design Guide, a best practice document on transit improvements. This can be accessed online at https://www.metro.net/about/station-design-projects/
Response to Comment 3-5
The City concurs with the comment. Metro’s Culver City Station provides transfers at street level on Metro Routes 33 and 617 to E Line light rail service. In addition, the station is designed to accommodate transfer activity to Culver CityBus, LADOT Commuter Express, and Santa Monica Big Blue Bus service.
The Mobility Element provides policies to prioritize transit transfers for future stop designs and station area enhancements. For example, Policy M- 2.5 would transform traditional bus stops into mobility-centric locations that facilitate connectivity between modes of transportation, and Policy M-3.1 would improve and influence regional mobility service quality through coordination with Metro and other municipal mobility service providers. Further, Policy M-3.4 aims to
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-14 SCH No. 2022030144 City of Culver City July 2024
prioritize capital investments and improvements to enhance transit reliability and rider experience to make transit competitive with driving, Policy M-4.2 would prioritize investments to reduce first/last mile transit barriers, and Policy M-4.6 would construct accessible and compliant pedestrian facilities.
The comment does not raise any issues with respect to the content or adequacy of the Draft EIR, and therefore, no further response is necessary.
Comment 3-6
4. [sic] Walkability: Metro strongly encourages the installation of wide sidewalks, pedestrian lighting, a continuous canopy of shade trees, enhances crosswalks with ADA-compliant curb ramps, and other amenities along all public street frontages of the development site to improve pedestrian safety and comfort to access the Culver City Station. The City should consider requiring the installation of such amenities as part of the conditions of approval of projects within the Plan area.
Response to Comment 3-6
Draft PEIR Section 4.16, Transportation, addresses consistency of the Project with programs, plans, ordinances, or policies addressing the circulation system, including transit, roadway, bicycle, and pedestrian facilities under Impact Statement TR-1. As discussed in Section 4.16, in the past, transportation analysis focused on the level of service metric, which measured congestion at local intersections and roadway segments, with an emphasis on ensuring that the street grid network functioned well and allowed for the efficient movement of vehicles. The current focus is to encourage active transportation (e.g., walking, biking, etc.) and transit, and to limit increases in vehicle miles traveled. This analysis was also conducted with review of the Culver City Short Range Mobility Plan, Bicycle and Pedestrian Action Plan, Complete Streets Policy, and the Local Road Safety Plan. Implementation of the General Plan 2045 would improve connections to local and regional transit services (Policy M-2.3) and encourage the use of alternative modes of transportation (Policy M-5.2), including walking and biking through supportive land use development. The General Plan 2045 would enhance pedestrian infrastructure by providing improvements to existing pedestrian facilities, constructing planned pedestrian facilities, and prioritizing pedestrian safety. More specifically, Policy M-1.3 would improve transportation network safety as improvements would be designed with the most vulnerable users in mind to ensure accessibility to all travelers regardless of age, race, gender, or ability. In addition, Policy M-4.6 would construct pedestrian facilities, including sidewalks and controlled crossings, that are ADA-compliant and connect with key land uses and regional and local transit services. The General Plan 2045 also includes an implementation action (IA.M-4) which directs the City to complete and adopt complete streets guidelines in coordination with City Departments and stakeholders.
Comment 3-7
5. Access: The Plan should address first-last mile connections to transit, encouraging development that is transit accessible with bicycle and pedestrian-oriented street design connecting transportation with housing and employment centers. For reference, please view the
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-15 SCH No. 2022030144 City of Culver City July 2024
First Last Mile Strategic Plan, authored by Metro and the Southern California Association of Governments (SCAG), available on-line at:
http://media.metro.net/docs/sustainability_path_design_guidelines.pdf Response to Comment 3-7
This comment addresses inclusion of first-last mile connections to transit which encourage development that is transit-accessible. The Mobility Element provides several policies to prioritize first/last-mile connectivity and access to transit stops. These include policies which would provide multimodal connectivity through transformation of traditional bus stops (Policy M-2.5) and align with the Bicycle and Pedestrian Action Plan to facilitate and interconnected citywide bicycle network (Policy M-8.5). In particular, Policy M-4.2 would prioritize investments that reduce first/last-mile barriers to transit stops and encourage alternative transportation, and Policy M-4.7 would prioritize the expansion of alternative mobility services and resources to communities with limited access to transit. Further, the proposed General Plan 2045 mobility network identifies segments of National Boulevard, Robertson Boulevard, and Washington Boulevard around the Culver City E Line station which could become special designated Active Transportation Corridors.
The comment does not raise any issues with respect to the content or adequacy of the Draft EIR, and thus no further response is necessary.
Comment 3-8
6. Active Transportation: Metro encourages the City to promote bicycle use through adequate short-term bicycle parking, such as ground-level bicycle racks, as well as secure and enclosed long-term bicycle parking, such as bike lockers or a secured bike room, for guests, employees, and residents. Bicycle parking facilities should be designed with best practices in mind, including: high visibility siting, effective surveillance, easy to locate, and equipment installed with preferred spacing dimensions, so they can be conveniently accessed. Additionally, the Plan should help facilitate safe and convenient connections for pedestrians, people riding bikes, and transfer users to/from the destinations within the Plan area.
Response to Comment 3-8
The comment encourages the City to promote bicycle parking and facilities as well as the provision of safe and convenient connections for people walking, biking, and rolling. As discussed in Draft PEIR Section 4.16, the City’s Municipal Code (CCMC) Section 7.05.015, Transportation Demand and Trip Reduction Measures, includes bicycle parking and pedestrian pathway. In addition, the City requires short-term and long-term bicycling parking for multi- family residential and non-residential developments (Municipal Code Section 17.320.045).
As discussed in Section 4.16, in June 2020 the City adopted the Bicycle and Pedestrian Action Plan, which establishes a long-term vision for improving walking and bicycling in Culver City. (The 2020 Plan updates the previous Bicycle and Pedestrian Master Plan adopted by the City Council in 2010.) The 2020 Plan, like the previous plan, seeks to ensure comfortable, safe, and attractive places to hike and walk so that these forms of active transportation become first
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-16 SCH No. 2022030144 City of Culver City July 2024
choices for travelling around the City. The plan’s vision is that “Culver City will be a community where bicycling and walking provide affordable, safe, and healthy mobility options for all residents. New projects and programs will work to enhance multi-modal mobility.” Goals include access and connectivity, healthier and safer communities, affordability, collaboration, and equitability.
The Mobility Element prioritizes active transportation. The Mobility Element supports and complements the measures, objectives, and policies in the City’s Bicycle and Pedestrian Action Plan (Policies M-2.1, M-2.2, M-4.4, M-8.5). In addition, Policies M-2.1, M-4.4, and M-7.4 seek to identify gaps in the existing bicycle network and prioritize multimodal projects, provide additional bicycle parking, and implement bicycle detection at crossing signals.
With regard to connectivity, as discussed in Response to Comment 3-4, the General Plan 2045 would ensure that new project applications foster pedestrian and bicycle access by providing safe, accessible pedestrian connections and creating secure and convenient bike storage (Policy LU 9.5). In addition, policies in the General Plan 2045 aim to connect transit-oriented communities through strong pedestrian, Culver CityBus, other public transit, and bicycle connections to and from transit stops via pedestrian-oriented building design, safe and convenient road crossings, and street furniture and amenities (Policy LU 1.4).
Comment 3-9
7. Wayfinding: Wayfinding signage should be considered as part of the Plan to help people navigate through the Plan area to all modes of transportation. Any temporary or permanent wayfinding signage with content referencing Metro services, or featuring the Metro brand and/or associated graphics (such as bus or rail pictograms) requires review and approval by Metro Art & Design.
Response to Comment 3-9
The comment identifies the importance of wayfinding signage to help people navigate all modes of transportation. The City understands the need for signage. Mobility Element Policy M-8.3 addresses the need for human-scale lighting along pedestrian thoroughfares, trails and at transit stops. If the City develops signage with contract referencing Metro services or using Metro brand or graphics, the City would coordinate with Metro to obtain the necessary approval.
The comment does not raise any issues with respect to the content or adequacy of the Draft EIR, and thus no further response is necessary.
Comment 3-10
8. Multi-modal Connections: With an anticipated increase in traffic, Metro encourages an analysis of impacts on non-motorized transportation modes and consideration of improved non- motorized access to the Plan area and nearby transit services, including pedestrian connections and bike lands/paths. Appropriate analyses could include multi-modal LOS calculations, pedestrian audits, etc.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-17 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 3-10
This comment encourages an analysis of impacts on non-motorized transportation modes as a result of the anticipated increase in traffic from Project implementation. The comment urges that such analysis should consider improved non-motorized access to the Plan area and nearby transit services. The Mobility Element provides policies to proactively improve person- throughput on arterials and collectors. These policies would prioritize new street designs and transportation modes with higher people-moving capacity such as transit lanes, protected bikeways, and sidewalks (Policy M-6.1), coordinate with other neighboring jurisdictions to improve arterial person-throughput (Policy M-6.2), and evaluate multimodal project performance based on Key Performance Indicators (Policy M-8.6). Additionally, Policy M-3.3 would aim to improve existing mobility services including CityBus and CityRide, Policy M-5.2 would shift the mobility paradigm toward sustainable modes, and Policies M-5.3 and M-5.4 would deploy transportation demand management measures, among others.
Additionally, the Project includes Implementation Action recommendations in support of increasing active transportation trip production. These include IA.M-8 and IA.M-9, which would establish a comprehensive Transportation Demand Management (TDM) Plan and TDM Ordinance update.
Draft PEIR Section 4.16, Transportation, includes a discussion of impacts to non-motorized transportation under Impact TR-1, which addresses any conflicts with programs, plans, ordinances, or policies addressing the circulation system. The analysis concluded that the Project supports the improvement and expansion of non-motorized transit within the Plan area.
The analysis includes a discussion of the policies listed above.
Comment 3-11
9. Parking: Metro encourages the incorporation of transit-oriented, pedestrian-oriented parking provision strategies such as the reduction or removal of minimal parking requirements for specific areas and the exploration of shared parking opportunities. These strategies could be pursued to reduce automobile-orientation in design and travel demand.
Response to Comment 3-11
This comment encourages the incorporation of parking provision strategies to reduce automobile-orientation in design and travel demand. The Draft PEIR discusses Mobility Element policies such as Policy M-5.7, which would deploy parking management strategies to manage parking, improve transit-oriented districts, and support the mobility paradigm shift away from single-occupancy vehicles. Further, the Draft PEIR discusses adherence to the Culver City Municipal Code, which states that no minimum parking is required for any use except as may be determined through a Comprehensive Plan. These regulatory guidelines would ensure that future development under the Plan would incorporate transit- and pedestrian-oriented parking provision strategies.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-18 SCH No. 2022030144 City of Culver City July 2024
Comment 3-12
Metro looks forward to continuing to collaborate with the City to effectuate policies and implementation activities that promote transit-oriented communities. If you have any questions regarding this letter, please contact me by phone at 213.547.4326, by email at [email protected], or by mail at the following address:
Metro Development Review
One Gateway Plaza
MS 99-22-1
Los Angeles, CA 90012
Response to Comment 3-12
This comment provides a general conclusion as well as additional information regarding LA Metro. In accordance with Public Resources Code Section 21092.5(a), the City will provide written proposed responses to comments from public agencies, including LA Metro, at least 10 days prior to certification of the Final PEIR.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-19 SCH No. 2022030144 City of Culver City July 2024
Letter 4
Jon Bridgeman
Received May 13, 2024
Comment 4-1
I am an environmental consultant who lives in Fox Hills and works across Los Angeles. I understand housing is an issue for all Culver City residents and with that in mind, I want to stress these responses to the General Plan EIR.
Here are my concerns:
Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need to account for the density bonus (doubles the allowed density)
Response to Comment 4-1
The comment is introductory and expresses an opinion regarding the proposed density in Fox Hills. The comment will be forwarded to the decision makers for consideration. The comment does not raise an issue on the content of the Draft EIR. Therefore, no further response is warranted.
Comment 4-2
Fox Hills' current buildings are older and either have no capability of adding AC systems or are cost-prohibitive. The current cooling system for Fox Hills relies on natural ocean breeze. In my unit, our windows and sliding doors are open over 12 hours a day, sometimes 24 hours a day to make use of the ocean breeze. It is the most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. There needs to be a study to assess the effect these new developments will have on the ocean breeze by a climate/weather expert. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
Response to Comment 4-2
The comment raises concerns regarding the potential effects resulting from the increase in density and building height in Fox Hills that would occur as a result of the Project relative to ocean breezes and requests a study be undertaken. As indicated in Draft PEIR Section 4.1, Aesthetics, the City received comments during the scoping process regarding ocean breezes.
The comments were specific to the Fox Hills neighborhood and concern that the increase in density and building height could affect ocean breezes. A study and more detailed analysis was
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-20 SCH No. 2022030144 City of Culver City July 2024
not provided in the Draft PEIR since the CEQA Guidelines do not provide a threshold pertinent to ocean breezes.
For informational purposes, a review of wind rose maps from the National Oceanic and Atmospheric Administration (NOAA) for the Santa Monica Airport and Los Angeles International Airport show that wind patterns during the warmer summer months (July to September) primarily hail from a southwesterly direction in the coastal region of Los Angeles, but it is also acknowledged that a minor percentage of the wind comes directly from the west. Some of the roads in Fox Hills run generally in a southwesterly to northeasterly direction, which would allow the majority of the winds out of the southwest to pass through the area without significant obstruction. As indicated in the Draft PEIR, the City anticipates that given the topography as well as the setbacks and building articulation required in the Zoning Code Update standards, breezes would not be notably obstructed. Regardless, as this is not considered an impact under CEQA, no further response is necessary on this topic.
Comment 4-3
The EIR shows “Unavoidable Significant Impact” (air quality, noise, transportation). Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
Response to Comment 4-3
As indicated in Draft PEIR Executive Summary, Section ES.4, the Project would result in significant unavoidable impacts with regard to air quality, cultural resources (historic), noise, and transportation. As discussed in Draft PEIR Chapter 2, Project Description, the Project analyses contained in the PEIR are based on assumptions pertaining to future growth through the horizon year 2045. The growth projections are based on an understanding of historic, current, and projected demographic and economic conditions in the City through 2045, rather than full buildout. The full buildout scenario would assume that every parcel would be developed with the maximum amount allowed under the General Plan 2045. Actual development that may occur by the horizon year is typically less than the theoretical maximum of development. The growth projections are not done on a parcel-by-parcel basis but rather, the projections allocate a total amount of growth for the City overall and by TAZ zone. These projections are used for planning and analysis purposes.
Table 2-3 in Draft PEIR Chapter 2 provides the growth projections for population, housing, and jobs under the General Plan 2045. The General Plan 2045 is projected to result in a population of 62,400 persons in 2045 (an increase of 21,600 persons compared to the 2020 population); 28,310 households (an increase of 11,310 households compared to 2019 household count; and 84,300 jobs (an increase of 16,260 jobs compared to 2019 job count). The Draft PEIR evaluates this level of growth through the year 2045. In addition, it should be noted that the General Plan 2045 assumes residential growth to meet the next three Regional Housing Needs Assessment (RHNA) cycles that will occur during the timeframe of this General Plan.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-21 SCH No. 2022030144 City of Culver City July 2024
With regard to the density bonuses, it is unknown whether a developer would choose to apply a density bonus to a particular project. While one developer may choose to do that, another developer may not develop a property to its maximum allowed density. Therefore, it is speculative to assume that density bonuses would be used in all projects throughout the City.
Comment 4-4
The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
Response to Comment 4-4
As discussed above, the growth projections are based on an understanding of historic, current, and projected demographic and economic conditions in the City through 2045. As acknowledged in Chapter 2, Project Description, in the discussion regarding residential land use designations (page 2-16), under limited circumstances, an increase in density above the maximum allowable density can occur, such as density bonuses for affordable housing, as well as other incentive-based local ordinances that implement the goals of the General Plan. As indicated above, it is unknown whether a developer would choose to apply a density bonus to a particular project. Since there is no specific project at this time it would be speculative to assume particular densities at the parcel level.
Comment 4-5
Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 3 to 6 times from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,….), city services, schools, etc). In summary, our quality of life.
Response to Comment 4-5
Under the adopted General Plan, the Fox Hills area of the City currently has various land use designations, with the area south of Slauson including Planned Residential Development, Regional Center, Cemetery and Open Space and the north of Slauson General Corridor, Low Density Multiple Family and Industrial Park. The adopted Land Use Element acknowledges that the Planned Residential Development designation average densities exceed the densities allowed in the current General Plan and are up to 72 du/ac in Fox Hills and up to 43.5 du/ac along Jefferson Boulevard.
Draft PEIR Figure 2-6 shows the proposed General Plan Land Use Map and Table 2-2 provides the proposed land use designations and general development parameters, such as maximum residential density and non-residential FAR. The residential and mixed use designations allow varying ranges of residential density. As shown in Figure 2-6, the Mixed Use High designation, which would allow 100 dwelling units per acre (du/ac), is located primarily in the Culver City Metro E Line station area and existing larger commercial and office centers. In Fox Hills, this
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-22 SCH No. 2022030144 City of Culver City July 2024
designation would occur primarily in areas that are designated Regional Center in the existing Land Use Map. Other areas within Fox Hills south of Slauson Avenue are designated as Medium Density Multifamily, which would allow a maximum of 50 du/ac, and High Density Multifamily, which would allow a maximum of 70 du/ac, as well as Open Space and Cemetery. The Fox Hills area north of Slauson would be designated Mixed Use Corridor 2 and Medium Density Multifamily, which would allow a maximum of 50 du/ac.
The Draft PEIR evaluates at a program level the projected growth that would likely occur based on an understanding of historic, current, and projected demographic and economic conditions in the City through 2045. Individual developments are not proposed at this time and whether or not a site would be developed to the maximum density or intensity allowed by the General Plan 2045 is unknown. The comment provides a list of environmental issues, including air quality, noise, traffic, street parking, ocean breeze, infrastructure and services. Please see Draft PEIR Section 4.2, Air Quality; 4.12, Noise; 4.16, Transportation; 4.18, Utilities and Service Systems;
4.14, Public Services; and 4.15, Recreation for analyses of these issues. As discussed in Response 4-2, ocean breezes is not an environmental issue in the CEQA Guidelines. As indicated in Section
4.16, the City’s Municipal Code Section 17.320.020, Number of Parking Spaces Required, no minimum parking is required for any use except as may be determined through a Comprehensive Plan. In addition, parking is not an issue in the CEQA Guidelines.
Comment 4-6
Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
Response to Comment 4-6
The majority of Fox Hills residences are located south of Slauson although there are some existing residences north of Slauson. This comment relates to the General Plan 2045 and does not raise any issues with respect to the content or adequacy of the Draft EIR. Therefore, no further response is necessary. However, the comment is forwarded to decision makers for their consideration.
Comment 4-7
Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
Response to Comment 4-7
As indicated in Draft PEIR Chapter 2, Project Description, the General Plan 2045 establishes the long-range vision that reflects the aspirations of the community and provides policies to support
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-23 SCH No. 2022030144 City of Culver City July 2024
that vision by guiding the physical growth of the City. The comment relates to the General Plan and does not raise any issues with respect to the content or adequacy of the Draft EIR.
Therefore, no further response is necessary. However, the comment is forwarded to decision makers for their consideration.
Comment 4-8
We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots to build on. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre. (their plan is 75-100 units affordable units of the 1105 they are planning)
Response to Comment 4-8
The comment expresses an opinion and relates to the General Plan 2045. The comment does not raise any issues with respect to the content or adequacy of the Draft EIR. Therefore, no further response is necessary. However, the comment is forwarded to decision makers for their consideration.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-24 SCH No. 2022030144 City of Culver City July 2024
Letter 5
Anna Budevska
Received May 13, 2024
Comment 5-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City.
The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
Response to Comment 5-1
The comment expresses an opinion with regard to the density in Fox Hills and relates to the General Plan. The comment does not raise any issues with respect to the content or adequacy of the Draft EIR. Therefore, no further response is necessary. However, the comment is forwarded to decision makers for their consideration.
Comment 5-2
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
Response to Comment 5-2
The comment raises concerns regarding the potential effects resulting from the increase in density and building height in Fox Hills that would occur as a result of the Project relative to ocean breezes and requests a study be undertaken. As indicated in Draft PEIR Section 4.1, Aesthetics, the City received comments during the scoping process regarding ocean breezes.
The comments were specific to the Fox Hills neighborhood and concern that the increase in density and building height could affect ocean breezes. A study and more detailed analysis was not provided in the Draft PEIR since the CEQA Guidelines do not provide a threshold pertinent to ocean breezes.
For informational purposes, a review of NOAA wind rose maps for the Santa Monica Airport and Los Angeles International Airport show that wind patterns during the warmer summer months (July to September) primarily hail from a southwesterly direction in the coastal region of Los
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-25 SCH No. 2022030144 City of Culver City July 2024
Angeles, but it is also acknowledged that a minor percentage of the wind comes directly from the west. Some of the roads in Fox Hills run generally in a southwesterly to northeasterly direction, which would allow the majority of the winds out of the southwest to pass through the area without significant obstruction. As indicated in the Draft PEIR, the City anticipates that given the topography as well as the setbacks and building articulation required in the Zoning Code Update standards, breezes would not be notably obstructed. Regardless, as this is not considered an impact under CEQA, no further response is necessary on this topic.
Comment 5-3
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question:
Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
Response to Comment 5-3
As indicated in Response 4-3, the Project would result in significant unavoidable impacts with regard to air quality, cultural resources (historic), noise, and transportation. As discussed in Draft PEIR Chapter 2, Project Description, the Project analyses contained in the PEIR are based on assumptions pertaining to future growth through the horizon year 2045. Table 2-3 provides the growth projections for population, housing, and jobs under the General Plan 2045. In addition, it should be noted that the General Plan 2045 assumes residential growth to meet the next three Regional Housing Needs Assessment (RHNA) cycles that will occur during the timeframe of this General Plan. With regard to the density bonuses, it is unknown whether a developer would choose to apply a density bonus to a particular project. While one developer may choose to do that, another developer may not develop a property to its maximum allowed density. Therefore, it is speculative to assume that density bonuses would be used in all projects throughout the City. Please see Response 4-3 and Draft PEIR Chapter 2 for more detail.
Comment 5-4
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
Response to Comment 5-4
This comment is the same as Comment 4-4. Please see Responses to Comment 4-4.
Comment 5-5
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-26 SCH No. 2022030144 City of Culver City July 2024
quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
Response to Comment 5-5
This comment is the same as Comment 4-5. Please see Response 4-5.
Comment 5-6
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
Response to Comment 5-6
This comment is the same as Comment 4-6. Please see Response to Comment 4-6.
Comment 5-7
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
Response to Comment 5-7
This comment is the same as Comment 4-7. Please see Response to Comment 4-7.
Comment 5-8
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
Response to Comment 5-8
This comment is the same as Comment 4-8. Please see Response to Comment 4-8.
Comment 5-9
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-27 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 5-9
The comment seems to refer to the 2021-2029 Housing Element, which was adopted by the City on August 8, 2022 and certified by California Department of Housing and Community Development (HCD) on October 10, 2022. At this time, no amendments are being proposed to the adopted 2021-2029 Housing Element.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-28 SCH No. 2022030144 City of Culver City July 2024
Letter 6
Yihui Gould
Received May 12, 2024
Comment 6-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-29 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 6-1
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-30 SCH No. 2022030144 City of Culver City July 2024
Letter 7
Gloria Mortitz
Received May 12, 2024
Comment 7-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact” (air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-31 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 7-1
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-32 SCH No. 2022030144 City of Culver City July 2024
Letter 8
Melissa Korc
Received May 13, 2024
Comment 8-1
This is a response to the General Plan EIR.
Here are my concerns:
Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need to account for the density bonus (doubles the allowed density)
Response to Comment 8-1
The comment expresses an opinion regarding the proposed density in Fox Hills. The comment will be forwarded to the decision makers for consideration. The comment does not raise an issue on the content of the Draft EIR. Therefore, no further response is warranted.
Comment 8-2
The CA law for composting is very difficult to meet in our buildings. Our buildings were built so long ago that we don’t have enough space for trash, recycling and organic bins. This requires us to get the small cart which is not ideal in large buildings.
Response to Comment 8-2
The comment indicates that due to space constraints in older buildings in Fox Hills, it is difficult to meet state requirements for composting. Since the comment describes an existing condition and does not raise any issues with respect to the content or adequacy of the Draft EIR, no further response is necessary. However, the Greenhouse Gas Reduction Element acknowledges the role of composting in waste diversion from landfills. Goal GHG-5, Zero waste, is to increase resource capture and decrease waste sent to landfills. Implementation Action GHG-18 and GHG- 19 include steps to increase organics and food waste diversion.
Comment 8-3
Our older buildings do not allow for EV charging. We tried adding it our building through a program with SCE. However, we were told it would require a transformer outside and the city denied the request. It makes us homeowners trying to keep our value of condo and help the environment be put in a tough spot. The new buildings would be built this [sic] with no consideration for us in older buildings.
Response to Comment 8-3
The comment raises challenges that exist with retrofitting older buildings with EV charging stations. Since the comment describes an existing condition and does not raise any issues with respect to the content or adequacy of the Draft EIR, no further response is necessary. However,
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-33 SCH No. 2022030144 City of Culver City July 2024
the Infrastructure Element and Greenhouse Gas Element acknowledge the importance of renewable energy. As discussed in the Infrastructure Element, the transition to all-electric infrastructure powered by renewable, carbon-free energy and associated energy conservation will require phased in requirements for new development and existing residences and businesses (General Plan 2045, page 177).
Comment 8-4
Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. There needs to be a study to assess the effect these new developments will have on the ocean breeze by a climate/weather expert.
We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
Response to Comment 8-4
This comment is the similar to Comment 5-2. Please see Response to Comment 5-2.
Comment 8-5
The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation). Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and200 units/acre fully developed Fox Hills.
The reason we are demanding the 200 units/acre
scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
Response to Comment 8-5
This comment is the same as Comments 4-3 and 4-4. Please see Responses to Comment 4-3 and 4-4.
Comment 8-6
Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 3 to 6 times from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-34 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 8-6
This comment is the same as Comment 4-5. Please see Response to Comment 4-5.
Comment 8-7
Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
Response to Comment 8-7
This comment is the same as Comment 4-6. Please see Response to Comment 4-6.
Comment 8-8
Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
Response to Comment 8-8
This comment is the same as Comment 4-7. Please see Response to Comment 4-7.
Comment 8-9
We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots to build on. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre. (their plan is 75-100 units affordable units of the 1105 they are planning)
Response to Comment 8-9
This comment is the same as Comment 4-8. Please see Response to Comment 4-8.
Comment 8-10
FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 8-10
This comment is the same as Comment 5-9. Please see Response to Comment 5-9.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-35 SCH No. 2022030144 City of Culver City July 2024
Letter 9
Yumi Mandt-Rauch
Received May 13, 2024
Comment 9-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-36 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
Response to Comment 9-1
This letter is identical to Comments 5-1 through 5-8 within Letter 5. Please see Responses to Comments 5-1 through 5-8 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-37 SCH No. 2022030144 City of Culver City July 2024
Letter 10
Karyn Marks
Received May 12, 2024
Comment 10-1
I know it’s easier to just throw all housing to Fox Hills. Fox Hills has ALWAYS been the “Redheaded Stepchild” of Culver City.
When you throw ALL of the housing to our area. You Clearly destroy our quality of life.
There is NO WAY the traffic will be acceptable. It is already impossible.
The architects told us to "fight all you want but this is a done deal.” They said (and I quote) “The City Council plans to pack Fox Hills with housing.”
This is a blatant disregard for all who live here, for all who supported you! Response to Comment 10-1
The comment expresses an opinion regarding the General Plan 2045 and the increase in housing that would occur in Fox Hills. For clarification, the General Plan 2045 would introduce greater flexibility of uses, such as mixed-use, and allow residential uses in more areas of the City, including within industrial areas of the City. New mixed-use designations in activity centers and along commercial corridors would also enable greater opportunities for future residential development. Draft PEIR Figure 2-6 shows the proposed General Plan Land Use Map and Table 2-2 provides the proposed land use designations.
Comment 10-2
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-38 SCH No. 2022030144 City of Culver City July 2024
City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-39 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 10-2
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-40 SCH No. 2022030144 City of Culver City July 2024
Letter 11
Gil Ramirez
Received May 24, 2024
Comment 11-1
I am writing in response to the concerns raised about the General Plan EIR regarding the proposed zoning density changes in Fox Hills. It's my understanding that I missed the May 13th deadline to submit such comments, but I thought it best to submit them nonetheless. While I understand and appreciate the apprehensions of my fellow residents, I believe there are significant benefits to the proposed plan that warrant consideration. Below, I address the specific concerns highlighted.
Response to Comment 11-1
The comment is introductory and expresses support for the Project. Responses to the specific comments are provided below in Responses to Comments 11-2 through 11-9.
Comment 11-2
1. Zoning Density: The proposed density increase to 100 units/acre with the potential for a density bonus may seem excessive at first glance. However, it is essential to recognize the pressing need for housing in Culver City and the broader region. Higher density zoning can help address the housing shortage, reduce housing costs, and provide more affordable housing options. Moreover, modern urban planning techniques can mitigate the potential negative impacts on infrastructure and quality of life.
Response to Comment 11-2
The comment provides support for the density of up to 100 du/ac allowed by the Mixed Use High proposed in Fox Hills south of Slauson. As the comment does not raise an issue with the content or adequacy of the Draft PEIR, no further response is needed. The comment will be forwarded to the decision makers for their review and consideration.
Comment 11-3
2. Cooling Systems and Ocean Breeze: The concern about blocking ocean breezes and increasing temperatures is valid, but it is important to note that new developments can be designed to minimize these effects. Architects and planners can incorporate designs that allow for airflow and utilize advanced cooling technologies that are energy-efficient and environmentally friendly. Additionally, a study by climate and weather experts can be conducted to ensure that new developments do not significantly impact the natural cooling benefits currently enjoyed by residents.
Response to Comment 11-3
The comment indicates that future developments can incorporate designs to allow airflow and use cooling technologies that are energy-efficient and environmentally friendly. The comment
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-41 SCH No. 2022030144 City of Culver City July 2024
suggests that a study could be prepared to ensure that future developments do not significantly impact the ocean breezes. For informational purposes, a review of NOAA wind rose maps for the Santa Monica Airport and Los Angeles International Airport show that wind patterns during the warmer summer months (July to September) primarily hail from a southwesterly direction in the coastal region of Los Angeles, but it is also acknowledged that a minor percentage of the wind comes directly from the west. Some of the roads in Fox Hills run generally in a southwesterly to northeasterly direction, which would allow the majority of the winds out of the southwest to pass through the area without significant obstruction. As indicated in the Draft PEIR, the City anticipates that given the topography as well as the setbacks and building articulation required in the Zoning Code Update standards, breezes would not be notably obstructed. However, as indicated in Draft PEIR Section 4.1, Aesthetics, comments received during the scoping process regarding ocean breezes were specific to the Fox Hills neighborhood and concern that the increase in density and building height could affect ocean breezes. A study and more detailed analysis were not provided in the Draft PEIR since the CEQA Guidelines do not provide a threshold pertinent to ocean breezes.
Comment 11-4
3. Environmental Impact: The Environmental Impact Report (EIR) acknowledges “Unavoidable Significant Impact” in areas such as air quality, noise, and transportation. It is crucial to ensure that the EIR fully accounts for maximum development scenarios, including potential density bonuses. This transparency allows for better planning and the implementation of mitigation strategies to minimize these impacts. However, increased density can also lead to more efficient land use, reducing sprawl and preserving open spaces elsewhere.
Response to Comment 11-4
As indicated in Draft PEIR Executive Summary, Section ES.4, the Project would result in significant unavoidable impacts with regard to air quality, cultural resources (historic), noise, and transportation. As discussed in Draft PEIR Chapter 2, Project Description, the Project analyses contained in the PEIR are based on assumptions pertaining to future growth through the horizon year 2045. The growth projections are based on an understanding of historic, current, and projected demographic and economic conditions in the City through 2045. The growth projections are not done on a parcel by parcel basis but rather, the projections allocate a total amount of growth for the City overall and by TAZ zone.
Table 2-3 provides the growth projections for population, housing, and jobs under the General Plan 2045. The General Plan 2045 is projected to result in a population of 62,400 persons in 2045 (an increase of 21,600 persons compared to the 2020 population); 28,310 households (an increase of 11,310 households compared to 2019 household count; and 84,300 jobs (an increase of 16,260 jobs compared to 2019 job count). The Draft PEIR evaluates this level of growth through the year 2045.
With regard to the density bonuses, it is unknown whether a developer would choose to apply a density bonus to a particular project. While one developer may choose to do that, another developer may not develop a property to its maximum allowed density. Therefore, it is
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-42 SCH No. 2022030144 City of Culver City July 2024
speculative to assume that density bonuses would be used in all projects throughout the City.
Rather growth is projected for the City overall and assumes residential growth to meet the next three Regional Housing Needs Assessment (RHNA) cycles that will occur during the timeframe of this General Plan.
As indicated in Draft PEIR Chapter 2, Project Description, the General Plan 2045 establishes the long-range vision that reflects the aspirations of the community and provides policies to support that vision by guiding the physical growth of the city. The Land Use and Community Design Element articulates the vision and strategies relative to the proposed land use pattern.
Comment 11-5
4. Quality of Life and Community Character: While concerns about losing Fox Hills's unique character are valid, it is important to recognize that neighborhoods' character naturally evolves over time. Fox Hills has undergone numerous changes over the years, adapting to its residents' needs and the broader societal trends. This evolution is a testament to our community's resilience and dynamism.
Historically, Fox Hills has seen various phases of development, from its early days with single- family homes to the introduction of multifamily units and commercial spaces. Each phase brought new amenities, infrastructure improvements, and a broader mix of residents, enhancing the area's vibrancy and economic diversity. This continuous evolution has enriched the community, making it more inclusive and dynamic.
Response to Comment 11-5
The comment addresses the evolution of areas that occur over time. As indicated in Draft PEIR Chapter 2, 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. Land Use and Community Design Element Goal LU-7 focuses on Fox Hills to address the changes that are anticipated under the General Plan 2045. The comment does not raise an issue with the content or adequacy of the Draft PEIR and no further response is needed.
Comment 11-6
Cities are living entities that must evolve to meet the changing needs of their inhabitants. With the current housing crisis and increasing urban populations, higher-density developments are essential to provide affordable housing, reduce urban sprawl, and promote sustainable living.
Thoughtful urban planning can ensure that these developments are integrated seamlessly with the existing environment, preserving the unique character of Fox Hills while accommodating new growth.
Additionally, higher-density housing can bring numerous benefits to the community, such as:
• Increased Economic Activity: More residents can support local businesses, leading to a more vibrant local economy.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-43 SCH No. 2022030144 City of Culver City July 2024
• Enhanced Public Amenities: Higher density can justify the development of better public amenities, including parks, community centers, and public transportation, improving the quality of life for all residents.
• Sustainability: Concentrating development within existing urban areas helps preserve open spaces and reduces the environmental impact of suburban sprawl. Modern construction techniques and green building standards can further mitigate environmental concerns.
It is also worth noting that other cities that have embraced higher-density development have successfully maintained their unique character while providing much-needed housing and amenities. Examples from cities like Portland, OR, and Vancouver, BC, demonstrate that with careful planning and community involvement, it is possible to balance growth with preservation.
Response to Comment 11-6
The comment addresses the need for housing and provides benefits that can occur as a result of higher-density housing. The comment does not raise an issue with the content or adequacy of the Draft PEIR, and no further response is needed.
Comment 11-7
5. Development Location and Density Allocation: The proposal to concentrate higher density north of Slauson and limit density south of Slauson is a reasonable compromise. However, it is essential to balance this with the need for equitable development across the city. Ensuring that new developments include a mix of market-rate and affordable housing is crucial. Incentivizing developers to provide affordable units through density bonuses can be an effective strategy if properly managed.
Response to Comment 11-7
Draft PEIR Figure 2-6 shows the proposed General Plan Land Use Map. The Mixed Use High designation, which would allow up to 100 du/ac, is located south of Slauson. In addition, areas south of Slauson would be designated Medium Density Multifamily (maximum of 50 du/ac) and High Density Multifamily (maximum of 70 du/ac). The Fox Hills area north of Slauson would be designated Mixed Use Corridor 2 and Medium Density Multifamily, both of which allow a maximum of 50 du/ac. Land Use and Community Design Element Goal LU-1 and associated policies address affordable housing.
Comment 11-8
6. State Compliance and Developer Incentives: It is true that state regulations require cities to plan for adequate housing across all income levels. Reducing density too much could jeopardize compliance with these requirements. However, the city has leverage in negotiating with developers to ensure that new projects meet community needs while still providing sufficient housing units.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-44 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 11-8
The Housing Element, which was adopted by the City on August 8, 2022 and certified by HCD on October 10, 2022, addresses the provision of adequate housing across all income levels. The Project would amend the land use designations and zoning to implement the adopted Housing Element. The comment does not raise issue with respect to the content or adequacy of the Draft EIR and no further response is necessary.
Comment 11-9
In conclusion, while the concerns raised about the proposed density increases in Fox Hills are valid, they can be addressed through careful planning and community engagement. Increased density, if managed well, can bring numerous benefits, including more affordable housing, better land use, and a more vibrant community. It is crucial for the city to conduct thorough studies, engage with residents, and implement measures to mitigate any adverse impacts, ensuring that the development benefits all members of the community.
Response to Comment 11-9
The comment is conclusionary and provides a general summary of the issues raised. The comment does not raise issue with respect to the content or adequacy of the Draft EIR and no further response is necessary.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-45 SCH No. 2022030144 City of Culver City July 2024
Letter 12
Pouran Saeedi
Received May 12, 2024
Comment 12-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-46 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 12-1
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-47 SCH No. 2022030144 City of Culver City July 2024
Letter 13
Judi Sherman
Comment 13-1
Per the Advance Planning Division, the 100 units/acre density designation was not put on the north side of Slauson, which presently has no housing and far less traffic than the south side of Slauson, because of developer preference for larger parcels, thus the south side of Slauson is presently designated for 100 units/acre under the city’s Draft GP. This decision resulted in thus far, 3 developers, proposing a total of 1706 units with most likely more proposals to be submitted to include a probable large development in the former site of CVS on Bristol Parkway, adding most likely another proposed 700 to 1000 units. All these proposals are concentrated on the south side of Hannum, which is even a smaller area of concentration than just the south side of Slauson. Presently all of the 2800 units in 26 complexes in Fox Hills, located south of Hannum, make it the densest housing area in Culver City.
Response to Comment 13-1
The majority of Fox Hills residences are located south of Slauson although there are some existing residences north of Slauson. As discussed in Draft PEIR Chapter 2, Project Description, the Project analyses contained in the PEIR are based on assumptions pertaining to future growth through the horizon year 2045. The growth projections are based on an understanding of historic, current, and projected demographic and economic conditions in the City through 2045.
The total housing unit number was calculated by considering existing housing units as of 2019, the City’s ADU permitting history, the Housing Element’s projection of SB 9 unit construction, pipeline projects (projects that are under construction, have been entitled, or are in the planning stage), and projected new housing units.
This comment relates to the General Plan 2045 and does not raise any issues with respect to the content or adequacy of the Draft EIR. Therefore, no further response is necessary. However, the comment is forwarded to decision makers for their consideration.
Comment 13-2
According to the results of the EIR, there will be a potential for Unavoidable Significant Impact on several areas to include air quality, noise and transportation. Based on the above results of the EIR, please clarify, if the same significant impact on air quality would occur with development of 100 units per acre as with 50 units per acre? Or, let's say, that a bulk of the units would be on the north side of Slauson. Would that also produce the same unavoidable impact on air quality for the south side of Slauson, where all the building is being proposed now? Please be specific with documented proof.
Response to Comment 13-2
As indicated in the comment, the Draft PEIR identifies a potential for significant unavoidable air quality, noise, and transportation impacts as a result of buildout of future development that would occur under the Project. For clarification, as indicated in the Draft PEIR Executive
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-48 SCH No. 2022030144 City of Culver City July 2024
Summary, Section ES.4, the Project would also result in a significant unavoidable impact with regard to cultural resources (historic).
The construction air quality analysis is based on the size of the construction site, the number of construction equipment operating at a time, distance to sensitive receptors, as well as other variables. The operational air quality analysis is based on the operational intensity of the development and if there are any new stationary or portable sources. As indicated in Draft PEIR Chapter 1, Introduction, the document provides a program-level analysis and as such does not evaluate the project-specific impacts of individual developments that would be allowed under the Project.
With regard to construction, as discussed in Draft PEIR Section 4.2, Air Quality (page 4.2-39), there are no specific projects currently proposed under the General Plan and Zoning Code Update and the timing of construction, location or the exact nature of future projects is unknown. Therefore, a project-specific analysis of construction emissions would be speculative.
In addition, at a program level the analysis is a general analysis of impacts that could occur in a large geographical area as a result of buildout within the area, and not specific impacts that would occur in a smaller area from a specific project. Information regarding specific development projects, including buildings and facilities proposed to be constructed, construction schedules, quantities of grading, and other related information is necessary in order to provide a detailed estimate of emissions. Absent this information, emissions modeling is not feasible.
With regard to operations, as shown in Draft PEIR Table 4.2-7 (page 4.2-41), the net change in operational emissions from existing conditions (2019) compared to existing plus buildout of new development under the General Plan 2045 and Zoning Code Update would not exceed the SCAQMD regional significance thresholds, with the exception of VOC emissions that would exceed the threshold. Applicants for future projects developed under the General Plan 2045 and Zoning Code Update would be required to comply with SCAQMD rules and regulations as well as conduct CEQA analyses, if necessary, in order to determine significance based on the individual project specifics. The subsequent environmental documents for specific projects under the General Plan 2045 and Zoning Code Update would include, if necessary, an air quality analysis that will contain the calculations of construction and operational emissions, to determine the significance of impacts. Therefore, at the program level, the analysis of air quality impacts that could occur from specific projects under the Project is not feasible.
Comment 13-3
As verified by the Advance Planning manager, the reason that the 100 unit/acre designation was not placed on the north side of Slauson in Fox Hills is developer preference for larger parcels and that he said that was the only reason he could think of. The Community Development Director stated: “An EIR requires the study of a reduced density alternative. As there is already a designation of 65 units/acre, 80 units/acre was selected as there needs to be a significant difference between existing densities (in this case, between 65 and 100). ESA, in conjunction with City staff, developed that option.” This response was emailed to me when I wrote: “We know about the housing element and that if the land use element is changed to decrease
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-49 SCH No. 2022030144 City of Culver City July 2024
density designation in certain areas it would have to be done by City Council. The "option"of 80 units/acre, as you know, would not significantly decrease the density south of Slauson and is not a serious option at all.”
Response to Comment 13-3
As indicated in Draft PEIR Chapter 5, Alternatives, the identification and analysis of alternatives to a project is a fundamental aspect of the environmental review process for an EIR, which is intended to consider ways to mitigate or avoid the significant environmental effects of a project.
CEQA Guidelines Section 15126.6(a) states that an EIR must describe and evaluate a reasonable range of alternatives to a project that would feasibly attain most of the project’s basic objectives but avoid or substantially lessen any identified significant adverse environmental effects of the project. In addition, an EIR is not required to consider every conceivable alternative to a project or alternatives that are infeasible. Rather, it must consider a reasonable range of potentially feasible alternatives that will foster informed decision-making and public participation.
The Draft PEIR discusses the process of the selection of alternatives and describes alternatives that were considered by the City and eliminated from further evaluation. The Draft PEIR describes and evaluates three alternatives: No Project Alternative, Concentrated Growth Alternative, and Modified Mixed Use High Designation Alternative. Table 5-1 provides a comparison of the population, housing units, and jobs that would occur under the Project and the three alternatives.
As described in Draft PEIR Section 5.5.3, the Modified Mixed Use High Designation Alternative would have a maximum density of 80 units per acre (rather than 100 units per acre) in the 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. The Modified Mixed Use High Designation Alternative would result in 1,230 fewer residents compared to the Project, 970 fewer housing units, and 210 fewer jobs than the Project.
The Draft PEIR provides a qualitative analysis of the alternatives compared to the Project. Table 5-2 provides a comparison of the impacts of the Project and the alternatives. As shown in Table 5-2, while the reduction in growth that would occur under Alternatives 2 and 3 would reduce potentially significant environmental impacts, significant unavoidable impacts would occur relative to air quality, cultural resources (historic), noise, and transportation.
Comment 13-4
You must give a logical explanation (not developer preference) as to why the 100 units/acre designation will not be changed to the north side of Slauson in Fox Hills. Then, the lower density could go on the south side of Slauson. If the city was really concerned about air quality and its impact on citizens, tell us why it is not being done. 50 units/acre would be most desirable, as we know now that the developers can get their density doubled anyway.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-50 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 13-4
The comment expresses an opinion regarding the proposed density in Fox Hills. The comment will be forwarded to the decision makers for consideration.
As indicated in Draft PEIR Chapter 1, Introduction, the document provides a program-level analysis and as such does not evaluate the project-specific impacts of individual developments that would be allowed under the Project. The analyses are based on growth projections, based on an understanding of historic, current, and projected demographic and economic conditions in the City, through 2045.
With regard to air quality, Section 4.2, Air Quality, evaluates the potential construction and operational air quality impacts that would occur as a result of the Project. As discussed in Response to Comment 13-2, at a program level the analysis is a general analysis of impacts that could occur in a large geographical area as a result of buildout within the area, and not specific impacts that would occur in a smaller area from a specific project. Please see Response to Comment 13-2 for a more detailed discussion regarding the air quality analysis in the Draft PEIR.
Comment 13-5
Presently, the residents in Fox Hills have natural breeze to cool their units and the present infrastructure have either no capacity for air conditioning or only for portable air conditioning.
Given the air blockage that will occur with these new developments, reaching 7 stories high, this will affect residents tremendously. When I asked how the city is addressing this issue, I received the following comment from Advance Planning: ““CEQA Guidelines do not provide a threshold pertinent to ocean breezes. The City anticipates that given the topography as well as the setbacks and articulation required in the Zoning Code Update standards, that breezes would not be obstructed.” Documented scientific proof from a weather/climate expert is needed and not a general statement. Please address responsibly.
Response to Comment 13-5
The comment raises concerns regarding the potential effects resulting from the increase in building height in Fox Hills that would occur as a result of the Project relative to ocean breezes.
As indicated in the comment and in Draft PEIR Section 4.1, Aesthetics, CEQA Guidelines do not address ocean breezes. As indicated in the Draft PEIR, the City received comments during the scoping process regarding ocean breezes specific to the Fox Hills neighborhood and the concern that the increase in density and building height could affect ocean breezes.
For informational purposes, a review of NOAA wind rose maps for the Santa Monica Airport and Los Angeles International Airport show that wind patterns during the warmer summer months (July to September) primarily hail from a southwesterly direction in the coastal region of Los Angeles, but it is also acknowledged that a minor percentage of the wind comes directly from the west. Some of the roads in Fox Hills run generally in a southwesterly to northeasterly direction, which would allow the majority of the winds out of the southwest to pass through the area without significant obstruction. As indicated in the Draft PEIR, the City anticipates that given the topography as well as the setbacks and building articulation required in the Zoning
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-51 SCH No. 2022030144 City of Culver City July 2024
Code Update standards, breezes would not be notably obstructed. Regardless, as this is not considered an impact under CEQA, no further response is necessary on this topic.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-52 SCH No. 2022030144 City of Culver City July 2024
Letter 13A
Judi Sherman
The following comments were submitted by email over the course of a few days. Please also see written comments above from this individual.
Comment 13A-1
I was under the impression that ESA did the report and they identified the significant impact problems and not the city. Is that correct?
To clarify, for example, the same significant impact on air quality would occur with development of 100 units per acre as with 50 units per acre? FYI: South of Hannum, the tally is up to 1709 units of mixed-use development with more than likely, another 1000 units to be proposed at the Fox Hills Plaza site, which would total 2700 units. Or, let’s say, that a bulk of the units would be on the north side of Slauson. Would that also produce the same unavoidable impact on air quality for the south side of Slauson, where all the building is being proposed now? Response to Comment 13A-1
As discussed in Draft PEIR Chapter 1, Introduction, the City of Culver City is the Lead Agency. The public agency can either prepare the EIR or have a third party prepare the document under contract to the agency in accordance with Public Resources Code Section 21082.1(a). In this case, ESA prepared the PEIR under contract to the City. However, the City, as Lead Agency, is required to review the document and ensure that the document reflects the City’s independent judgement. Please also see Response to Comment 13-2 for a discussion regarding the air quality analysis in the Draft PEIR relative to geographic areas.
Comment 13A-2
Also, who in “The City” determined the conclusions regarding the ocean breeze? Were they climate scientists or someone with expertise in the field of weather/climate? Please let us know who actually showed documented proof that ocean breezes would not be obstructed by the magnitude of development proposed in Fox Hills on the south side of Slauson.
Response to Comment 13A-2
Please see Response to Comment 13-5 for a discussion regarding ocean breezes.
Comment 13A-3
So, at this point with air quality, noise, and the other items that have been analyzed by ESA as having significant impact that is unavoidable, what is the city obligated to do regarding these problem areas.
I realize that ESA listed the ocean breeze issue as a concern, so how is the city planning to address this issue? Actually that is the question I meant to ask.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-53 SCH No. 2022030144 City of Culver City July 2024
Response to Comment 13A-3
As indicated in Draft PEIR Chapter 1, Introduction, in accordance with CEQA Guidelines Section 15093, if a public agency approves a project that has significant impacts that cannot be mitigated to less than significant levels, the agency must state in writing the specific reasons for approving the project, based on the Final PEIR and any other information in the public record for the project. More specifically, as indicated in CEQA Guidelines Section 15093(a) the Guidelines require “… the decision-making agency to balance, as applicable, the economic, legal, social, technological, or other benefits, including region-wide or statewide environmental benefits, of a proposed project against its unavoidable environmental risks when determining whether to approve the project.”
With regard to the ocean breezes, please see Response to Comment 13-5.
Comment 13A-4
As always, thanks so much for your responses.
The blockage of ocean breeze due to the proposed housing projects and its effect on climate control in Fox Hills was included in the comments as a problem (Appendix 3). Is that issue addressed anywhere by the ESA in the EIR? I believe that was not covered in the EIR although maybe I missed it.
Response to Comment 13A-4
As indicated in Draft PEIR Executive Summary, Section ES.3, ocean breezes were raised as an issue in the scoping comments received by the city in response to the Recirculated Notice of Preparation (NOP). The ocean breeze issue was specific to Fox Hills. The comments received are provided in Appendix A-3. Please see Response to Comment 13-5 for a discussion regarding ocean breezes.
Comment 13A-5
Can you please verify that I am interpreting the analysis correctly re: Air Quality and Noise sections of the EIR as follows?
When the report is explaining that there is unavoidable significant impact regarding the air quality and noise, I assume they mean to be addressing the General Plan as it is presently. Is that correct?
Then, when they go on to say that any mitigating strategies would not reduce the significant impact on air quality and noise, I am again assuming they mean that as the GP is now, nothing would really result in any improvement in air quality or noise abatement. Is that correct? Response to Comment 13A-5
Draft PEIR Chapter 2, Project Description, describes the General Plan 2045 and Zoning Code Update (Project) that are evaluated in the Draft PEIR. The analyses in the Draft PEIR evaluate the growth that would occur under the proposed General Plan 2045 and the Zoning Code Update.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-54 SCH No. 2022030144 City of Culver City July 2024
Table 2-3 provides the growth projections for population, housing, and jobs under the General Plan 2045. If significant environmental effects are identified, mitigation measures are recommended. As indicated in the Draft PEIR, even with the implementation of mitigation measures the Project would result in significant unavoidable impacts with regard to air quality, cultural resources (historic), noise, and transportation.
Comment 13A-6
Lastly, the section in the Executive Summary regarding “Issues raised during the preparation process and areas of controversy” there is a statement that these issues would be addressed later on. When will that be, if you have any idea of that timeline? Response to Comment 13A-6
As indicated above Draft PEIR Section ES.3 lists the issues raised during the scoping process. The text does not suggest that these issues would be addressed later.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-55 SCH No. 2022030144 City of Culver City July 2024
Letter 14
Sequoia Tully
Received May 12, 2024
Comment 14-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-56 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 14-1
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-57 SCH No. 2022030144 City of Culver City July 2024
Letter 15
Louise Wechsler
Received May 7, 2024
Comment 15-1
I am a 16 year resident of Fox Hills and condo owner who is opposed to the proposed housing developments planned for our neighborhood. We already have one of the densest housing areas in Culver City. The proposed new housing will only add to our traffic and noise issues.
Please reconsider, and move the proposed new housing (which certainly is needed) to the northern side of Slauson, which lacks residential buildings.
Response to Comment 15-1
The comment provides an opinion regarding the proposed density in Fox Hills and indicates that the new housing should be located north of Slauson. The comment expresses concern regarding traffic and noise impacts but does not raise any specific issues related to these topics. Please see Draft PEIR Section 4.12, Noise, and Section 4.16, Transportation, for the respective analyses of these issues.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-58 SCH No. 2022030144 City of Culver City July 2024
Letter 16
Jeff Willis
Received May 12, 2024
Comment 16-1
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-59 SCH No. 2022030144 City of Culver City July 2024
should beno more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Response to Comment 16-1
This letter is identical to Letter 5. Please see Responses to Comments 5-1 through 5-9 for detailed responses.
2. Comments and Responses
General Plan 2045 and Zoning Code Update Project 2-60 SCH No. 2022030144 City of Culver City July 2024
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General Plan 2045 and Zoning Code Update Project 3-1 SCH No. 2022030144 City of Culver City July 2024
CHAPTER 3
Revisions, Clarifications, and Corrections to
the Draft PEIR
In accordance with California Environmental Quality Act (CEQA) Guidelines Section 15132 (a), this Chapter of the Final EIR provides changes to the Draft PEIR that have been made to clarify, correct, or supplement the information provided in that document. The changes described in this Chapter do not add significant new information to the Draft PEIR that would require recirculation of the Draft PEIR. More specifically, CEQA requires recirculation of a Draft EIR only when “significant new information” is added to a Draft EIR after public notice of the availability of the Draft EIR has occurred (refer to California Public Resources Code Section 21092.1 and CEQA Guidelines Section 15088.5), but before the EIR is certified. CEQA Guidelines Section 15088.5 specifically states: “New information added to an EIR is not ‘significant’ unless the EIR is changed in a way that deprives the public of a meaningful opportunity to comment upon a substantial adverse environmental effect of the project or a feasible way to mitigate or avoid such an effect (including a feasible project alternative) that the project’s proponents have declined to implement. ‘Significant new information’ requiring recirculation includes, for example, a disclosure showing that:
• A new significant environmental impact would result from the project or from a new mitigation measure proposed to be implemented.
• A substantial increase in the severity of an environmental impact would result unless mitigation measures are adopted to reduce the impact to a level of insignificance. • A feasible project alternative or mitigation measure considerably different from others previously analyzed would clearly lessen the significant environmental impacts of the project, but the project’s proponents decline to adopt it. • The draft EIR was so fundamentally and basically inadequate and conclusory in nature that meaningful public review and comment were precluded.”
CEQA Guidelines Section 15088.5 also provides that “[re]circulation is not required where the new information added to the EIR merely clarifies or amplifies or makes insignificant modifications in an adequate EIR... A decision not to recirculate an EIR must be supported by substantial evidence in the administrative record.”
As demonstrated in this Final PEIR, the changes presented in this Chapter do not constitute new significant information warranting recirculation of the Draft EIR as set forth in CEQA Guidelines Section 15088.5. Rather, the Draft PEIR is comprehensive and has been prepared in accordance with CEQA.
3. Revisions, Clarifications, and Corrections to the Draft PEIR
General Plan 2045 and Zoning Code Update Project 3-2 SCH No. 2022030144 City of Culver City July 2024
Changes to the Draft PEIR are indicated below under the respective EIR section heading, page number, and paragraph. Paragraph reference is to the first full paragraph on the page. Deletions are shown with strikethrough and additions are shown with double underline.
Executive Summary
1. Subsection ES.6, Summary of Environmental Impacts, Table ES-1, Summary of Project Impacts and Mitigation Measures, the following revisions are made to MM BIO-1 in the first sentence:
MM BIO-1. Bas eline Biological Assessment: The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat (see Figure 34, Vegetation, of the Conservation Element) provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats.
2. Subsection ES.6, Summary of Environmental Impacts, Table ES-1, S ummary of Project
Impacts and Mitigation Measures the following revisions are made to MM BIO-2 in the second sentence:
MM BIO-2. Nes
ting Bird Surveys: Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any tree and/or vegetation removal within the Project site.
3. Subsection ES.6, Summary of Environmental Impacts, Table ES-1, Summary of Project Impacts and Mitigation Measures the following revisions are made to MM CUL-1:
MM CUL-1. Pr ior to development of any individual projects that are subject to CEQA within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Professional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center or Built Environment Resources Directory (BERD) search; a review of pertinent archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified potentially eligible historic resources will be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be fully evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mitigation for affected historical resources to be implemented prior to their demolition or alteration. Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant
3. Revisions, Clarifications, and Corrections to the Draft PEIR
General Plan 2045 and Zoning Code Update Project 3-3 SCH No. 2022030144 City of Culver City July 2024
impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.
Chapter 2, Project Description
1. Page 2-16, Subsection entitled High Density Residential, revise the sentence as follows:
High Density Multifamily designation allows a maximum density of 70100 du /ac. These dwelling units can be configured into a variety of multifamily housing types.
2. Subsection 2.4.2, Zoning Code Update, update Figure 2-1 5, Proposed Zoning Map, to change the publicly owned land in the northeastern portion of the City, from Single Family to Open Space. This includes the Los Angeles County Stoneview Nature Center and the Baldwin Hills Conservancy hiking trail. In addition, change the color of the Planned Development areas from tan to blue.
See updated Figure 2-15 at the end of this chapter.
Section 4.3, Biological Resources
1. Subsection 4.3.4, Project Impact Analysis, under Mitigation Measures the following revisions are made to MM BIO-1 in the first sentence:
MM BIO-1. Bas eline Biological Assessment: The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat (see Figure 34, Vegetation, of the Conservation Element) provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats.
2. Subsection 4.3.4, Project Impact Analysis, under Mitigation Measures the following revisions ar
e made to MM BIO-2 in the second sentence:
MM BIO-2. Nes ting Bird Surveys: Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any tree and/or vegetation removal within the Project site.
Section 4.4, Cultural Resources
1. Subsection 4.3.4, Project Impact Analysis, under Mitigation Measures the following revisions are made to MM CUL-1:
MM CUL-1. Pr
ior to development of any individual projects that are subject to CEQA within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Professional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center or Built Environment Resources Directory (BERD) search; a review of pertinent archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified potentially eligible historic resources will
3. Revisions, Clarifications, and Corrections to the Draft PEIR
General Plan 2045 and Zoning Code Update Project 3-4 SCH No. 2022030144 City of Culver City July 2024
be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be fully evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mitigation for affected historical resources to be implemented prior to their demolition or alteration. Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.
Section 4.16, Transportation
1. Subsection 4.16.3, Regulatory Framework, under Regional the following text is added to the end of the section:
LA Metro NextGen Bus Plan
The NextGen Bus Plan was approved by the Metro Board of Directors in October 2020. The plan was developed to implement a new competitive bus system in Los Angeles County that is fast, frequent, reliable, and accessible. The proposed improvements will double the number of frequent metro bus lines; provide more than 80 percent of current bus riders with 10 minute or better frequency; improve and expand midday, evening, and weekend service, creating an all-day, 7-day-a-week service; ensure a quarter mile walk to a bus stop for 99 percent of current riders; and create a more comfortable and safer waiting environment.
2. Page 4.16-19 under Impact TR-1, the fifth paragraph is revised as follows:
The General Plan 2045 would not preclude the implementation of the Short Range Mobility Pla
n, and would provide complimentary goals, policies, and implementation actions that would include transit improvements (Goal M-3). Additionally, the Mobility Element would support and complement the measures, objectives, and policies in the City’s Bicycle and Pedestrian Action Plan (Policies M-2.1, M-2.2, M-4.4, M-8.5). Further, the Mobility Element places an emphasis on Complete Streets and a layered transportation network consistent with the City’s Complete Streets Policy (Goal M-2). The City’s Local Road Safety Plan (LRSP) establishes a series of goals and objectives to identify high-risk roadways and create continued safety. The Mobility Element would establish the goal of providing a transportation network that is safe and accessible for all travel modes (Goal M-1). As the Mobility Element aims to provide more reliable, safe, affordable, convenient, clean, and connected mobility options for people of all ages and abilities, it is consistent with the goals and objectives outlined in the CTP 2050 as described above. Lastly, the Mobility Element would provide policies in support of coordinating connections to Metro regional bus and rail services, consistent with LA Metro’s NextGen Bus Plan (Policies M-3.1, M-3.4, M-4.5, M-6.2).
Culver City General Plan 2045
Figure 2-15
Proposed Zoning Map
(Revised)
SOURCE: City of Culver City, 2024; County of Los Angeles, 2021; ESRI, 2021D180517.00 - Culver City General Plan Update\05 Graphics-GIS-Modeling\Illustrator 8 BUFSCPEZ
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3. Revisions, Clarifications, and Corrections to the Draft PEIR
General Plan 2045 and Zoning Code Update Project 3-6 SCH No. 2022030144 City of Culver City July 2024
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General Plan 2045 and Zoning Code Update Project 4-1 SCH No. 2022030144 City of Culver City July 2024
CHAPTER 4
Mitigation Monitoring Program
This Mitigation Monitoring Program (MMP), which is provided in Table 4-1, Mitigation Monitoring Program, below, has been prepared pursuant to Public Resources Code (PRC) Section 21081.6, which requires a Lead Agency to adopt a “reporting or monitoring program for changes to the project or conditions of project approval, adopted in order to mitigate or avoid significant effects on the environment.” In addition, Section 15097(a) of the State California Environmental Quality Act ( CEQA) Guidelines requires that a public agency adopt a program for monitoring or reporting mitigation measures and project revisions, which it has required to mitigate or avoid significant environmental effects. The City of Culver City is the Lead Agency for the General Plan 2045 and Zoning Code Update. Collectively referred to as the Project.
The MMP provides the mitigation measures for the Project and the monitoring implementation responsibility for each measure. The MMP for the Project will be in place through all phases of implementation of the Project, including design, construction, and operation.
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-2 SCH No. 2022030144 City of Culver City July 2024
TABLE 4-1
MITIGATION MONITORING PROGRAM FOR THE GENERAL PLAN 2045 AND ZONING CODE UPDATE Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Air Quality
MM AQ-1: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of NOX, CO, PM10 and/or PM2.5 shall require the construction contractor to use equipment that meets the US Environmental Protection Agency (USEPA) and/or California Air Resources Board (CARB) Tier 4 Final or better Off-Road New Diesel Engine Emission Standards for construction equipment with more than 50 horsepower, unless it can be demonstrated to the Culver City Department of Building and Safety that such equipment is not available.
Project sponsors should also consider including zero emissions (ZE) or zero net emissions (ZNE) technologies where appropriate and feasible or higher tier standard diesel equipment as it becomes developed and feasible. Any emissions control device used by the contractor shall achieve emissions reductions that are no less than what could be achieved by a Level 3 diesel emissions control strategy for a similarly sized engine, as defined by CARB regulations. Prior to construction, the project engineer shall ensure that all plans for construction phases (e.g., demolition, grading) that would exceed the SCAQMD significance thresholds clearly show the requirement for USEPA and/or CARB Tier 4 or higher emissions standards for construction equipment over 50 horsepower. During construction, the construction contractor shall maintain a list of all operating equipment in use on the construction site for verification by the Culver City Department of Building and Safety. The construction equipment list shall state the makes, models, and numbers of construction equipment on-site. Equipment shall be properly serviced and maintained in accordance with the manufacturer’s recommendations. Construction contractors shall also ensure that all nonessential idling of construction equipment is restricted to five minutes or less in compliance with Section 2449 of the California Code of Regulations, Title 13, Article 4.8, Chapter 9.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
MM AQ-2: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District (SCAQMD) significance thresholds during construction for emissions of volatile organic compounds (VOCs) as a result of VOC off-gassing emissions from architectural coatings and industrial maintenance coatings shall require the construction contractor to use SCAQMD Low-VOC and/or Super Compliant VOC architectural coatings and industrial maintenance coatings such that daily volume of coatings applied would not result in emissions that exceed the SCAQMD significance threshold for VOC, unless it can be demonstrated to the City Department of Building and Safety that such coatings for a required application are not available. During construction, the construction contractor shall maintain a list of all architectural coatings and industrial maintenance coatings in use on the construction site and the daily volumes of coatings applied for verification by the Culver City Department of Building and Safety.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-3 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM AQ-3: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, show on the building plans that all major appliances (dishwashers, refrigerators, clothes washers, and dryers) to be provided/installed are Energy Star– certified appliances or appliances of equivalent energy efficiency. Installation of Energy Star or equivalent appliances shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-4: Applicants for new residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the feature below has been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy. • For multifamily dwellings, electric vehicle charging shall be provided as specified in Section A4.106.8.2 (Residential Voluntary Measures) of the CALGreen Code (or its successor code).
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-5: Applicants for new non-residential development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and that exceed the South Coast Air Quality Management District significance thresholds during operations shall, prior to issuance of a building permit, indicate on the building plans that the features below have been incorporated into the design of the building(s). Proper installation of these features shall be verified by the City Department of Building and Safety prior to issuance of a certificate of occupancy.
• Preferential parking for low-emitting, fuel-efficient, and carpool/van vehicles shall be provided as specified in Section A5.106.5.1 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
• Facilities shall be installed to support future electric vehicle charging at each nonresidential building with 30 or more parking spaces. Installation shall be consistent with Section A5.106.5.3 (Nonresidential Voluntary Measures) of the CALGreen Code (or its successor code).
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-4 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM AQ-6: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential localized project construction-related air quality impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing localized significance thresholds (LST) air quality impacts. If construction-related criteria air pollutants are determined to have the potential to exceed the SCAQMD-adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the Planning Department.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
MM AQ-7: Applicants for new development projects within the City Planning Area that are subject to CEQA (California Environmental Quality Act) review (i.e., non-exempt projects) and are within one-quarter mile (1,320 feet) of a sensitive land use shall, prior to issuance of a building permit, submit a construction-related air quality study that evaluates potential health risk impacts to the City Planning Department for review and approval. The evaluation shall be prepared in conformance with South Coast Air Quality Management District (SCAQMD) methodology for assessing health risk impacts. If health risk impacts are determined to have the potential to exceed the SCAQMD- adopted thresholds of significance, the City shall require that applicants for new development projects incorporate mitigation measures to reduce air pollutant emissions during construction activities. These identified measures shall be incorporated into all appropriate construction documents (e.g., construction management plans) submitted to the City and shall be verified by the City’s Planning Department.
Project Applicant Prior to issuance of a
building permit
Culver City Planning and
Development Department
Biological Resources
MM BIO-1: Baseline Biological Assessment. The City shall require that applicants of proposed projects located within or adjacent to natural plant or wildlife habitat (see Figure 34, Vegetation, of the Conservation Element) provide a complete assessment and impact analysis of the flora and fauna within and adjacent to the project area, with emphasis upon identifying endangered, threatened, sensitive, regionally and locally unique species, and sensitive habitats. The impact analysis will aid in determining any direct, indirect, and cumulative biological impacts from construction and operations, as well as specific mitigation or avoidance measures necessary to offset significant impacts associated with future projects. The Biological Assessment shall include the following information:
a. Information on the regional setting that is critical to an assessment of environmental impacts, with special emphasis on resources that are rare or unique to the region [State CEQA Guidelines, § 15125(c)].
b. A thorough, recent, floristic-based assessment of special status plants and natural communities, following CDFW's Protocols for Surveying and Evaluating Impacts to Special Status Native Plant Populations and Natural Communities (CDFW 2018); Project Applicant Prior to construction Culver City Planning and Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-5 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency c. Floristic, alliance- and/or association-based mapping and vegetation impact assessments conducted at the project site and within the neighboring vicinity. The Manual of California Vegetation, second edition, should also be used to inform this mapping and assessment (Sawyer et al, 2008). Adjoining habitat areas shall be included in this assessment where site activities could lead to direct or indirect impacts off-site. Habitat mapping at the alliance level will help establish baseline vegetation conditions;
d. A complete, recent assessment of rare, threatened, and endangered, and other sensitive species on site and within the area of potential effect, including California Species of Special Concern and California Fully Protected Species (Fish & Game Code, §§ 3511, 4700, 5050 and 5515). Species to be addressed should include all those which meet the CEQA definition of endangered, rare or threatened species (State CEQA Guidelines, § 15380); and,
e. Identification of focused surveys for special-status plants and/or wildlife that could be directly or indirectly impacted by the project, which shall be conducted in the appropriate season prior to any habitat disturbance.
f. Identification of any aquatic habitats such as rivers, streams, and lakes and their associated natural plant communities/habitats. This includes any culverts, ditches, storm channels that may transport water, sediment, pollutants, and discharge into rivers, streams, and lakes.
g. Avoidance and minimization measures (such as preconstruction wildlife clearance surveys) to fully avoid and otherwise protect sensitive biological resources from Project- related construction and operational impacts shall be identified and implemented. If impacts cannot be avoided, appropriate mitigation measures to offset potential special-status species and habitat impacts shall be identified and implemented.
MM BIO-2: Nesting Bird Surveys. Construction activity for individual projects occurring within the Planning Area shall take place outside of the nesting season, if feasible. If not feasible, for future development occurring between January 1 through September 15, a nesting bird and raptor survey shall be conducted within a 500-foot radius of the construction site, prior to any ground-disturbing activities (e.g., staging, mobilization, grading) as well as prior to any tree and/or vegetation removal within the Project site.
The nesting bird surveys shall be conducted at appropriate nesting times and concentrate on potential roosting or perch sites. Pre-construction surveys shall be conducted by a qualified biologist no more than 7 days prior to the beginning of any Project-related activity likely to impact raptors and migratory songbirds. If construction activities are delayed or suspended for more than 7 days during the breeding season, the surveys shall be repeated. If nesting raptors and migratory songbirds are identified, the following minimum no disturbance buffers shall be implemented: 100 feet around active passerine (perching birds and songbirds) nests, 300 feet around active raptor nests. These buffers should be maintained until the breeding season has ended or until a qualified biologist has determined that the birds have fledged and are no longer reliant upon the nest or parental care for survival.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-6 S CH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Cultural Resources
MM CUL-1: Prior to development of individual projects that are subject to CEQA within areas that contain properties more than 45 years old, the project proponent shall retain a qualified architectural historian, defined as meeting the Secretary of the Interior’s Professional Qualification Standards for architectural history, to conduct a historic resources assessment including: a records search at the South Central Coastal Information Center or Built Environment Resources Directory (BERD) search; a review of pertinent archives, databases, and sources; a pedestrian field survey; recordation of all identified historic resources on California Department of Parks and Recreation 523 forms; and preparation of a technical report documenting the methods and results of the assessment. All identified potentially eligible historic resources will be assessed for the project’s potential to result in direct and/or indirect effects on those resources and any historic resource that may be affected shall be fully evaluated for its potential significance under national and state criteria prior to the City’s approval of project plans and publication of subsequent CEQA documents. The qualified architectural historian shall provide recommendations regarding additional work, treatment, or mitigation for affected historical resources to be implemented prior to their demolition or alteration.
Impacts on historical resources shall be analyzed using CEQA thresholds to determine if a project would result in a substantial adverse change in the significance of a historical resource. If a potentially significant impact would occur, the City shall require appropriate mitigation to lessen the impact to the degree feasible.
Project Applicant Prior to construction Cul
ver City Planning and
Development Department
MM CUL-2: Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a qualified archaeologist, defined as an individual meeting the Secretary of the Interior’s Professional Qualification Standards for archaeology, to conduct an archaeological resources assessment. This assessment shall include a records search at the South Central Coastal Information Center; a Sacred Lands File search at the Native American Heritage Commission; and a pedestrian field survey of the project site. If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for eligibility in the California Register and local register. If a resource is determined to be eligible and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, archaeological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the archaeological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.
Project Applicant
Prior to construction Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-7 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency Geology and Soils
MM GEO-1: Prior to development of individual projects that are subject to CEQA review and involve ground disturbance, the project proponent shall retain a Qualified Paleontologist, defined as an individual meeting the Society of Vertebrate Paleontology (SVP) Standard, to conduct a site-specific paleontological resources assessment. This assessment shall include a records search at the Natural History Museum of Los Angeles County and/or other appropriate facilities, geologic map and scientific literature review, and a pedestrian field survey (if deemed appropriate by the Qualified Paleontologist). If resources are identified during the assessment, then their boundaries shall be determined and they shall be evaluated for significance pursuant to CEQA, SVP, and/or a local register. If a resource is determined to be significant and the Project would cause a potentially significant impact to the resource, then mitigation measures shall be prescribed to reduce impacts from the Project to that resource. An analysis regarding the Project’s potential to encounter buried resources during construction shall be conducted. If there is potential to encounter resources during construction of the Project, paleontological construction monitoring shall be prescribed as a mitigation measure. The methods and results of the paleontological assessment shall be included in a technical report that is prepared prior to the city’s approval of project plans and publication of subsequent CEQA documents.
Project Applicant Prior to and during
construction
Culver City Planning and
Development Department
Noise
MM NOI-1: Construction Noise. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that are located within 500 feet of noise-sensitive receptors (e.g., residences, hospitals, schools) shall submit a noise study to the City Planning Department for review and approval prior to issuance of a grading or building permit.
The study shall include noise-reduction measures, if necessary, to ensure project construction noise will be in compliance with the City’s Noise Ordinance standards as applicable to construction (i.e., CCMC Chapter 9.07). All noise-reduction measures approved by City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during construction activities. Potential noise-reduction measures may include, but are not limited to, one or more of the following, as applicable to the project:
• Install temporary sound barriers for construction activities that occur adjacent to occupied noise-sensitive receptors.
• Equip construction equipment with effective mufflers, soundinsulating hoods or enclosures, vibration dampers, and other Best Available Control Technology (BACT). • Limit non-essential idling of construction equipment to no more than five minutes per hour.
This mitigation measure shall not apply and is superseded once a Citywide noise ordinance goes into effect that establishes construction noise standards for noise- reduction measures that ensures project construction noise compliance with the Culver City Noise Ordinance standards for development projects within the City.
Project Applicant Prior to issuance of a
grading or building permit
Culver City Planning and
Development Department
4. Mitigation Monitoring Program
General Plan 2045 and Zoning Code Update Project 4-8 SCH No. 2022030144 City of Culver City July 2024
Mitigation Measures Implementing Party Monitoring Phase Responsible Monitoring Agency MM NOI-2: Construction Vibration. Applicants for new development projects within the City that are subject to CEQA (California Environmental Quality Act) review (i.e., non- exempt projects) and that are located within 300 feet of groundborne vibration receptors and that utilize vibration-intensive construction equipment (e.g., pile drivers, jack hammers, large dozer, or vibratory rollers) shall submit a vibration impact evaluation to the City Planning Department for review and approval prior to issuance of a grading or building permit. The evaluation shall include a list of project construction equipment and the associated vibration levels and a predictive analysis of potential project vibration impacts. If construction-related vibration is determined to exceed applicable standards, project-specific measures shall be required to ensure project compliance with vibration standards. All project-specific measures approved by the City Planning Department shall be incorporated into appropriate construction-related plans (e.g., demolition plans, grading plans and building plans) and implemented during project construction.
Examples of equipment vibration source-to-receptor distances at which impact evaluation should occur vary with equipment type (based on FTA reference vibration information) and are as follows:
• Jackhammer: 23 feet.
• Dozer, hoe-ram, drill rig, front-end loader, tractor, or backhoe: 43 feet. • Roller (for site ground compaction or paving): 75 feet. • Impact pile-driving: 280 feet.
This mitigation measure shall not apply and is superseded once a Citywide groundborne vibration ordinance goes into effect that establishes construction groundborne vibration standards for vibration-reduction measures that ensures project construction groundborne vibration compliance with applicable standards for development projects within the City Planning Area.
Project Applicant Prior to issuance of a
grading or building permit
Culver City Planning and
Development Department
Appendix A
Original Comment Letters on
the Draft EIR
SENT VIA E-MAIL: May 2, 2024
[email protected]
Troy Evangelho, Advance Planning Manager
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
Draft Program Environmental Impact Report (Draft PEIR) for the Proposed Picture Culver City: General Plan 2045 and Zoning Code Update (Proposed Project) (SCH No. 2022030144)
South Coast Air Quality Management District (S outh Coast AQMD) staff appreciates the opportunity to comment o n the above -mentioned document. The City of Culver City is the California Environmental Quality Act (CEQA) Lead Agency for the Proposed Project. To provide context, South Coast AQMD staff has provided a brief summary of the project information and prepared the following comments organized by topic of concern.
South Coast AQMD Staff’s Summary of Project Information in the Draft PEIR Based on the Draft PEIR, the Proposed Project would replace the existing General Plan in its entirety to establish a long -term vision. 1 The land use designation s in the Proposed Project are residential, mixed-use, and special purpose.2 The residential designation ranges from single-family homes to multi -family housing; mixed -use designations provide areas for a range of residential and commercial uses; and the special purpose designations are for a range of institutional uses and public facilities.3 The Proposed Project would result in an estimated 12,700 new housing units 4 and a net increase of 3.7 million square feet of non-residential development by 2045.5 South Coast AQMD Staff’s Comments on the Draft PEIR
Emission Reductions from Health Risk Strategies
When certifying an EIR for a project , retain the authority to include any additional information deemed relevant to assessing and mitigating the environmental impacts. South Coast AQMD is concerned about the potential public health impacts of sitting sensitive populations within the proximity of existing air pollution sources (e.g., freeways and railroads ). For this reason, prior to approving future development projects, the Lead Agency is recommended to consider the impacts of air pollutants on people who will live in a new project and provide effective mitigation.
Additionally, South Coast AQMD suggests that the Lead Agency review and apply the guidance provided in 1) the California Air Resources Board (CARB) Air Quality Land Use and Handbook:
1 Draft PEIR. Page 2-8.
2 Ibid. Page 2-13.
3 Ibid.
4 Ibid. Page 2-19.
5 Ibid. Page 2-20.
1-1
1-2
Troy Evangelho May 2, 2024
2 A Community Health Perspective , 6 which provides criteria for evaluating and reducing air pollution impacts associated with new projects involving land use decisions; and 2) CARB’s technical advisory which contains strategies to reduce air pollution exposure near high -volume roadways.7
Many strategies are available for residential receptors to reduce being exposed to particulate matter, including, but not limited to, HVAC systems equipped with filters rated at a minimum efficiency reporting value (MERV) 13 or higher air filtration capabi lities. In some cases, MERV 15 or better is recommended for building design, orientation, location, vegetation barriers, landscaping screening, etc. Enhanced filtration units are capable of reducing exposure. However, enhanced filtration systems have limit ations. For example, filters rated MERV 13 or higher are able to screen out greater than or equal to 50% of DPM ,8 but they have no ability to filter out volatile organic compound (VOC) emissions. Also, in a study that South Coast AQMD conducted to investigate filters rated at MERV 13 or better in classrooms, 9,10 a cost burden is expected to be within the range of $120 to $240 per year to replace each filter panel. The initial start-up cost could substantially increase if an HVAC system needs to be installed and if standalone filter units are required. Installation costs may vary, including costs for conducting site assessments and obtaining permits and approvals before filters can be installed. Other costs may include filter life monitoring, annual maintenance, and training for conducting maintenance and reporting. In addition, the filters would not have any effect unless the HVAC system is running. Therefore, when in use, the increased energy consumption from each HVAC system should be evaluated in the Draft PEIR.
While the filters operate 100 percent of the time when the HVAC is in use while the residents are indoors, the environmental analysis does not generally account for the times when the residents are not using their HVAC and instead have their windows or doors open or are moving throughout the common space outdoor areas of the Proposed Project. Furthermore, when used filters are replaced with new filters, emissions associated with trucks delivering the new filters and waste disposal trucks transporting the used filters to disposal sites should be evaluated i n Draft PEIR.
Therefore, any presumed effectiveness and feasibility of a particular HVAC filter should be carefully evaluated in more detail based on supporting evidence before assuming they will sufficiently alleviate exposure to DPM emissions.
South Coast AQMD Air Permits and Role as a Responsible Agency If the implementation of the Proposed Project would require the use of new stationary and portable sources, including but not limited to emergency generators, fire water pumps, boilers, spray booths, etc., air permits from South Coast AQMD will be required, and the role of South Coast AQMD would change from a Commenting Agency to a Responsible Agency under CEQA. In addition, if South Coast AQMD is identified as a Responsible Agency, per CEQA Guidelines Sections15086, the Lead Agency is required to consult w ith South Coast AQMD. In addition, 6 California Air Resources Board (CARB), Air Quality Land Use and Handbook: A Community Health Perspective, April 2005.
Available at: https://ww2.arb.ca.gov/sites/default/files/2023-05/Land%20Use%20Handbook_0.pdf 7 CARB’s Strategies to Reduce Air Pollution Exposure Near High-Volume Roadways. Available at:
https://ww2.arb.ca.gov/sites/default/files/2017-10/rd_technical_advisory_final.pdf 8 U.S. EPA, “What is a MERV rating?” Available at: https://www.https://www.epa.gov/indoor-air-quality-iaq/what-merv-rating 9 South Coast AQMD, Draft Pilot Study of High-Performance Air Filtration For Classroom Applications, October 2009.
Available at: https://www.aqmd.gov/docs/default-source/ceqa/handbook/aqmdpilotstudyfinalreport.pdf 10 International Journal of Indoor Environment and Health, Pilot Study of High-Performance Air Filtration for Classroom Applications, November 2012. Available at: https://onlinelibrary.wiley.com/doi/10.1111/ina.12013 1-2
cont.
1-3
1-4
Troy Evangelho May 2, 2024
3 CEQA Guidelines Section 15096 sets forth specific procedures for a Responsible Agency, including making a decision on the adequacy of the CEQA document for use as part of evaluating the applications for air permits. For these reasons, the Final EIR should include a discussion about any new stationary and portable equipment requiring South Coast AQMD air permits and identify South Coast AQMD as a Responsible Agency for the Proposed Project.
The Final EIR should also include calculations and analyses for construction and operation emissions for the new stationary and portable sources, as this information will also be relied upon as the basis for the permit conditions and emission limits for the air permit(s). Please contact South Coast AQMD’s Engineering and Permitting staff at (909) 396-3385 for questions regarding what types of equipment would require air permits. For more general information on permits, please visit South Coast AQMD’s webpage at http://www.aqmd.gov/home/permits.
Conclusion
As set forth in California Public Resources Code Section 21092.5(a) and CEQA Guidelines Section 15088(a -b), the Lead Agency shall evaluate comments from public agencies on the environmental issues and prepare a written response at least 10 days prior to ce rtifying the Final EIR. As such, please provide South Coast AQMD written responses to all comments contained herein at least 10 days prior to the certification of the Final EIR. In addition, as provided by CEQA Guidelines Section 15088(c), if the Lead Agen cy’s position is at variance with recommendations provided in this comment letter, detailed reasons supported by substantial evidence in the record to explain why specific comments and suggestions are not accepted must be provided.
Thank you for the opportunity to provide comments. South Coast AQMD staff is available to work with the Lead Agency to address any air quality questions that may arise from this comment letter.
Please contact Danica Nguyen, Air Quality Specialist, at [email protected] should you have any questions.
Sincerely,
Sam Wang
Sam Wang
Program Supervisor, CEQA-IGR
Planning, Rule Development & Implementation
SW:DN
LAC240402-04
Control Number
1-4
cont.
1-5
1-6
GABRIELENO BAND OF MISSION INDIANS - KIZH NATION
Historically known as The San Gabriel Band of Mission Indians recognized by the State of California as the aboriginal tribe of the Los Angeles basin March 22, 2024
Project Name: General Plan 2045 and Zoning Code Update, Culver City Thank you for your letter dated March 28,2024. Regarding the project above. This is to concur that we agree with the Specific Plan Amendment. However, our Tribal government would like to request consultation for all future projects within this location.
Andrew Salas, Chairman
Gabrieleno Band of Mission Indians – Kizh Nation
Andrew Salas, Chairman Nadine Salas, Vice-Chairman Dr. Christina Swindall Martinez, secretary Albert Perez, treasurer I Martha Gonzalez Lemos, treasurer II Richard Gradias, Chairman of the council of Elders PO Box 393 Covina, CA 91723 [email protected] [email protected] 2-1
3-1
3-1
cont.
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3-8
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3-11
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cont.
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Metro Adjacent Development Handbook | a
METRO ADJACENT
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Metropolitan Transportation Authority
February 2021
A GUIDE FOR CITIES AND DEVELOPERS
b | Metro Adjacent Development Handbook
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13 1.3 Building Setback
14 1.4 Overhead Cat
enary System (OCS) Clearance 15
1.5 Underground St
ation Portal Clearance 16
1.6 Shared Barrier Construction & Main
tenance 17
1.7 Project Orient
ation & Noise Mitigation 18
1.8 At-Gr
ade Rail Crossings
19 1.9 Sight-Lines a
t Crossings
20 1.10 Drivew
ay/Access Management
21 1.11 Bus Stop & Zones Design
22 2. Engineering & Technical R
eview 25
2.1 Exca
vation Support System Design
26 2.2 Proximity t
o Tunnels
27 2.3 Protection fr
om Explosion/Blast
28 3. Construction Safe
ty & Management 31
3.1 Pre-Cons
truction Coordination
32 3.2 Track Access and Sa
fety
33 3.3 Construction Hours
34 3.4 Exca
vation/Drilling Monitoring
35 3.5 Crane Opera
tions
36 3.6 Construction Barriers & Ov
erhead Protection 37
3.7 Pedestrian & Emer
gency Access
38 3.8 Impacts to Bus Rout
es & Stops
39 3.9 Utility Coordination
40 3.10 Air Quality & Ventila
tion Protection 41
Glossary 42
Table of Contents
d | Metro Adjacent Development Handbook
Metro Adjacent Development Handbook | 1
Quick Overview
Purpose of Handbook
The Metro Adjacent Development Handbook
(Handbook) is intended to provide information and guide coordination for projects adjacent to, below, or above
Metro transit facilities (e.g. right-of-way, stations, bus stops) and services.
Overarching Goal
By providing information and encouraging early
coordination, Metro seeks to reduce potential conflicts with transit services and facilities, and identify potential synergies to expand mobility and improve access to
transit.
Intended Audience
The Handbook is a resource for multiple stakeholder
groups engaged in the development process, including:
•
Local jurisdictions who revie
w, entitle, and permit
development projects,
• Developers,
• Property owners,
• Architects, engineers, and other t
echnical
consultants,
• Builders/con
tractors,
• Utility companies, and
• other Third Parties.
Handbook Cont
ent
The Handbook includes:
•
Introduction of Metr
o’s Development Review
coordination process, common concerns, and typical
stages of review.
•
Information
on best practices during three key
coordination phases to avoid potential conflicts or
create compatibility with the Metro transit system:
•
Planning & Conceptual Design,
• Engineering & Technical Re
view, and
• Construction Safe
ty & Monitoring.
• Glossary with
definitions for key terms used
throughout the Handbook.
RULE OF THUMB: 100 FEET
Me
tro’s Development Review process applies to
projects that are within 100 feet of Metro transit
facilities.
While the Handbook summarizes key concerns and
best practices for adjacency conditions, it does
not replace Metro’s technical requirements and
standards.
Prior to receiving approval for any construction
activities adjacent to, above, or below Metro
facilities, Third Parties must comply with the Metro
Adjacent Construction Design Manual, available on
Metro’s website.
Contact Us
For questions, contact the Development Review Team:
•
Email: devrevie
[email protected]
• Phone: 213.418.3484
• Online In-take Form: h
ttps://jpropublic.metro.net/
in-take-form
Additional Information & Resources
•
Metro Dev
elopment & Construction Coordination
website:
https://www.metro.net/devreview
•
Metro GIS/KML ROW Files:
h
ttps://developer.metro.net/portfolio-item/metro-
right-of-way-gis-data
• Metrolink Standar
ds and Procedures:
https://www.metrolinktrains.com/about/agency/
engineering--construction
Metro will continue to revise the Handbook, as needed,
to reflect updates to best practices in safety, operations, and transit-supportive development.
2 | Metro Adjacent Development Handbook
Who is Metro?
The Los Angeles County Metropolitan Transportation Authority (Metro) plans, funds, builds, and operates rail, bus, and other mobility services (e.g. bikeshare, microtransit) throughout Los Angeles County (LA County). On average, Metro moves 1.3 million people each day on buses and trains. With funding from the passage of Measure R (2008) and Measure M (2016), the Metro system is expanding. Over the next 40 years, Metro will build over 60 new stations and over 100 miles of transit right-of-way (ROW). New and expanded transit lines will improve mobility across LA County, connecting riders to more destinations and expanding opportunities for development that supports transit ridership. Metro facilities include:
Metro Rail: Metro operates heavy rail (HRT) and light rail (LRT) transit lines in underground tunnels, along streets, off-street in dedicated ROW, and above street level on elevated structures. Heavy rail trains are powered by a “third rail” along the tracks. Light rail vehicles are powered by overhead catenary systems (OCS). To support rail operations, Metro owns and maintains traction power substations (TPSS), maintenance yards, and other infrastructure.
Metro Bus Rapid Transit (BRT): Metro operates accelerated bus transit, which acts as a hybrid between rail and traditional bus service. Metro BRT may operate in a dedicated travel lane within a street or freeway, or off-street along dedicated ROW. Metro BRT stations may be located on sidewalks within the public right-of-way, along a median in the center of streets, or off-street on Metro-owned property.
Metro Bus: Metro operates 170 bus lines across more than 1,400 square miles in LA County. The fleet serves over 15,000 bus stops with approximately 2,000 buses. Metro operates “Local” and “Rapid” bus service within the street, typically alongside vehicular traffic, though occasionally in “bus-only” lanes.
Metro bus stops are typically located on sidewalks within the public right-of- way, which is owned and maintained by local jurisdictions. Metro’s NextGen Bus Plan re-envisions bus service across LA County to make service improvements that better serve riders.
Metrolink/Regional Rail: Metro owns a majority of the ROW within LA County on which the Southern California Regional Rail Authority (SCRRA) operates Metrolink service. Metrolink is a commuter rail system with seven lines that span 388 miles across five counties, including: Los Angeles, Orange, Riverside, San Bernardino, Ventura, and North San Diego. As a SCRRA member agency and property owner, Metro reviews development activity adjacent to Metro-owned ROW on which Metrolink operates, and coordinates with Metrolink on any comments or concerns. Metrolink has its own set of standards and processes, see link on page 1.
Background
Metro Adjacent Development Handbook | 3
Why is Metro interested in adjacent development?
Metro Supports Transit Oriented Communities: Metro is redefining the role of the transit agency by expanding mobility options, promoting sustainable urban design, and helping transform communities throughout LA County. Metro seeks to partner with local, state, and federal jurisdictions, developers, property owners and other stakeholders across LA County on transit-supportive planning and developments to grow ridership, reduce driving, and promote walkable neighborhoods. Transit Oriented Communities (TOCs) are places (such as corridors or neighborhoods) that, by their design, allow people to drive less and access transit more. TOCs maximize equitable access to a multi-modal transit network as a key organizing principle of land use planning and holistic community development.
Adjacent Development Leads to Transit Oriented Communities: Metro supports private development adjacent to transit as this presents a mutually beneficial opportunity to enrich the built environment and expand mobility options. By connecting communities, destinations, and amenities through improved access to public transit, adjacent developments have the potential to:
• reduce auto dependency
,
• reduce greenhouse g
as emissions,
• promote w
alkable and bikeable communities that accommodate more healthy and active lifestyles, • improv
e access to jobs and economic opportunities, and
• creat
e more opportunities for mobility – highly desirable features in an increasingly urbanized environment.
Opportunity: Acknowledging an unprecedented opportunity to influence how the built environment develops along and around transit and its facilities, Metro has created this document. The Handbook helps ensure compatibility between private development and Metro’s transit infrastructure to minimize operational, safety, and maintenance issues. It serves as a crucial first step to encourage early and active collaboration with local stakeholders and identify potential partnerships that leverage Metro initiatives and support TOCs across LA County.
4 | Metro Adjacent Development Handbook
Metro Purview for Review & Coordination
Metro is interested in reviewing development, construction, and utility projects within 100 feet of Metro transit facilities, real estate assets, and ROW – as measured from the edge of the ROW outward – both to ensure the structural safety of existing or planned transit infrastructure and to maximize integration opportunities with adjacent development. The Handbook seeks to:
• Improv
e communication and coordination between developers, jurisdictions, and Metro. • Identify c
ommon concerns associated with developments adjacent to Metro ROW. • Highlight Metr
o operational needs and requirements to ensure safe, continuous service. • Prev
ent potential impacts to Metro transit service or infrastructure. • Maintain access t
o Metro facilities for riders and operational staff.
• Avoid pr
eventable conflicts resulting in increased development costs, construction delays, and safety impacts.
• Streamline the re
view process to be transparent, clear, and efficient.
• Assist in the crea
tion of overall marketable and desirable developments.
Key Audiences for Handbook
The Handbook is intended to be used by:
• Local jurisdictions who re
view, entitle, and permit development projects and/or develop policies related to land use, development standards, and mobility,
• Developer
s, property owners,
• Architects, engineer
s, design consultants,
• Builders/c
ontractors,
• Entitlement c
onsultants,
• Environmen
tal consultants,
• Utility companies, and
• other Third Parties.
Metro Assets & Common Concerns for Adjacent Development The table on the facing page outlines common concerns for development projects and/or construction activities adjacent to Metro transit facilities and assets. These concerns are discussed in greater detail in the following chapters of the Handbook.
Metro Purview & Concerns
Metro Adjacent Development Handbook | 5
METRO ASSETS
AT-GRADE ROW
NON-REVENUE/OPERATIONAL
BUS STOPS
Transit operates below ground in
tunnels.
Transit operates on elevated
guideway, typically supported by
columns.
Transit operates in dedicated
ROW at street level; in some
cases tracks are separated from
adjacent property by fence or
wall.
Metro operates bus service on
city streets. Bus stops are located
on public sidewalks.
Metro owns and maintains
property to support operations
(e.g. bus and rail maintenance
facilities, transit plazas, traction
power substations, park-and-ride
parking lots).
• Exca
vation near tunnels and infrastructure
• Clearance from support s
tructures (e.g. tiebacks,
shoring, etc)
• Coordination with utilities
• Clearance from v
entilation shafts, surface
penetrations (e.g. emergency exits)
• Surcharg
e loading of adjacent construction
• Explosions
• Noise and vibration/
ground movement
• Storm wa
ter drainage
• Exca
vation near columns and support structures
• Column foundations
• Clearance from OCS
• Overhead prot
ection and crane swings
• Setbacks fr
om property line for maintenance activities
to occur without entering ROW
• Coordination with utilities
• Noise reduction (e.g. double-paned window
s)
• Pedestrian and bicy cle movements and safety
• Operat
or site distance/cone of visibility
• Clearance from OCS
• Crane swings and o
verhead protection
• Trackbed s
tability
• Storm wa
ter drainage
• Noise/vibration
• Drivew
ays near rail crossings
• Setbacks fr
om property line for maintenance
activities to occur without entering ROW
• Utility coordina
tion
• Lane closures and re-r
outing service during
construction
• Temporar
y relocation of bus stops
• Impacts to access to bus s
tops
• Exca
vation and clearance from support structures
(e.g. tiebacks, shoring, etc)
• Ground mov
ement
• Drainage
• Utility coordina
tion
• Access to property
UNDER
GROUND ROW
AERIAL ROW
COMMON ADJACENCY CONCERNS
6 | Metro Adjacent Development Handbook
Typical Stages of Metro Review and Coordination
Early coordination helps avoid conflicts between construction activities and transit operations and maximizes opportunities to identify synergies between the development project and Metro transit services that are mutually beneficial.
Metro Coordination Process
*Phases above may include fees for permits and reimbursement of Metro staff time for review and coordination.
Coordination Goal: Metro encourages developers to consult with the Development Review Team early in the design process to ensure compatibility with transit infrastructure and minimize operational, safety, and maintenance issues with adjacent development. The Development Review team will serve as a case manager to developers and other Third Parties to facilitate the review of plans and construction documents across key Metro departments.
Level of Review: Not all adjacent projects will require significant review and coordination with Metro. The level of review depends on the Project’s proximity to Metro, adjacency conditions, and the potential to impact Metro facilities and/or services. For example, development projects that are excavating near Metro ROW or using cranes near transit facilities require a greater level of review and coordination. Where technical review and construction monitoring is needed, Metro charges fees for staff time, as indicated by asterisk in the above diagram.
Permit Clearance: Within the City of Los Angeles, Metro reviews and clears Building & Safety permits for projects within 100 feet of Metro ROW, pursuant to Zoning Information 1117. To ensure timely clearance of these permits, Metro encourages early coordination as noted above.
To begin consultation, submit project information via an online In-Take Form, found on Metro’s website. Metro staff will review project information and drawings to screen the project for any potential impacts to transit facilities or services, and determine if require further review and coordination is required. The sample sections on the facing page illustrate adjacency condition information that helps Metro complete project screening.
Contact:
Metro Development Review Team
Website: https://www.metro.net/devreview
Online In-take Form: https://jpropublic.metro.net/in-take-form Email: [email protected]
Phone: 213.418.3484
Early Planning/
Conceptual Design
Technical
Review*
Real Estate
Agreements*
& Permits
Construction
Safety &
Monitoring*
Metro Adjacent Development Handbook | 7
Sample Section: Adjacency Conditions
LVL 1
LVL 2
LVL 3
LVL 4
B
AT-GRADE CONDITION
A
PL
OCS C
D
BUILDING
LVL 1
PL 3
PL 2
PL 1
CL CL
E
SOLDIER PILE
PL
TIEBACK
F
G
BELOW-GRADE CONDITION
GGGGG
FFF
L
EEE
LCC
KT BEBE AABB KKK
SS LLO PPDIERERLLDOOSOS ELELE
LVL 2
LVL 3BUILDING
E. Vertical distance from top of Metro tunnel
to closest temporary and/or permanent
structure (e.g. tiebacks, foundation). Refer
to Section 2.2, Proximity to Tunnels &
Underground Infrastructure of Handbook.
F. Horizontal distance from exterior tunnel
wall to nearest structure.
G. Horizontal distance from Metro track
centerline to nearest structure.
A. Distance from property line to nearest
permanent structure (e.g. building facade,
balconies, terraces). Refer to Section 1.3
Building Setback of Handbook.
B. Distance from property line to nearest
temporary construction structures (e.g.
scaffolding).
C. Distance from property line to nearest
Metro facility.
D. Clearance from nearest temporary
and/or permanent structure to overhead
catenary system (OCS). Refer to Section
1.4, OCS Clearance of Handbook.
8 | Metro Adjacent Development Handbook
Best Practices for Developer Coordination
Metro encourages developers of projects adjacent to Metro ROW and/or Real Estate Assets to take the following steps to facilitate Metro project review and approval:
1. Revie
w Metro resources and policies: The Metro Development & Construction Coordination website and Handbook provide important information for those interested in constructing on, adjacent, over, or under Metro ROW, non-revenue property, or transit facilities. Developers and other Third Parties should familiarize themselves with these resources and keep in mind common adjacency concerns when planning a project.
2. Contact Me
tro early during design process: Metro welcomes the opportunity to provide feedback early in project design, allowing for detection and resolution of important adjacency issues, identification of urban design and system integration opportunities, and facilitation of permit approval. Metro encourages project submittal through the online In-Take Form to begin consultation.
3. Maintain c
ommunication: Frequent communication with Metro during project design and construction will reinforce relationships and allow for timely project completion. Contact us at [email protected] or at 213.418.3484.
Best Practices
Metro Adjacent Development Handbook | 9
Best Practices for Local Jurisdiction Notification
To improve communication between Metro and the development community, Metro suggests that local jurisdictions take the following steps to notify property owners of coordination needs for properties adjacent to Metro ROW by:
• Updating GIS and parcel da
ta: Integrate Metro ROW files into the City/County GIS and/or Google Earth Files for key departments (e.g. Planning, Public Works, Building & Safety) to notify staff of Metro adjacency and need for coordination during development approval process.Download Metro’s ROW files here.
• Flag Parcels:
Create an overlay zone as part of local Specific Plan(s) and/or Zoning Ordinance(s) to tag parcels that are within 100 feet Metro ROW and require coordination with Metro early during the development process [e.g. City of Los Angeles Zone Information and Map Access System (ZI-1117)]. • Provide R
esources: Direct all property owners and developers interested in parcels within 100 feet of Metro ROW to Metro’s resources (e.g. website, Handbook).
Site Plan
& Conceptual
Design
12 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.1 Supporting Transit Oriented Communities
Transit-oriented communities (TOCs) are places that, by their design, make it more convenient to take transit, walk, bike or roll than to drive. By working closely with the development community and local jurisdictions, Metro seeks to ensure safe construction near Metro facilities and improve compatibility with adjacent development to increase transit ridership.
RECOMMENDATION: Consider site planning and building design strategies to that support transit ridership, such as:
• Lever
aging planning policies and development incentives to design a more compelling project that capitalizes on transit adjacency and economy of scales.
• Programming a mix of uses t
o create lively, vibrant places that are
active day and night.
• Utilizing Metro policies and pr
ograms that support a healthy,
sustainable, and welcoming environment around transit service and facilities.
• Prioritizing pedestrian-scaled elemen
ts to create spaces that are
comfortable, safe, and enjoyable.
• Activating gr
ound floor with retail and outdoor seating/activities
to bring life to the public environment.
• Reducing and screening parking t
o focus on pedestrian activity.
• Incorpora
ting environmental design elements that help reduce
crime (e.g. windows and doors that face public spaces, lighting).
The Wilshire/Vermont Metro Joint Development
project leveraged existing transit infrastructure
to catalyze a dynamic and accessible urban
environment. This project accommodates portal
access into the Metro Rail system and on-street
bus facilities.
Metro Adjacent Development Handbook | 13
1.2 Enhancing Access to Transit
Metro seeks to create a comprehensive, integrated transportation network and supports infrastructure and design that allows safe and convenient access to its multi-modal services. Projects in close proximity to Metro’s services and facilities present an opportunity to enhance the public realm and connections to/from these services for transit riders as well as users of the developments.
RECOMMENDATION: Design projects with transit access in mind.
Project teams should capitalize on the opportunity to improve the built environment and enhance the public realm for pedestrians, bicyclists, persons with disabilities, seniors, children, and users of green modes. Metro recommends that projects:
• Orient major entr
ances to transit service, making access and travel
safe, intuitive, and convenient.
• Plan for a con
tinuous canopy of shade trees along all public
right-of-way frontages to improve pedestrian comfort to transit facilities.
• Add pedestrian lighting along pa
ths to transit facilities and nearby
destinations.
• Integr
ate wayfinding and signage into project design.
• Enhance nearby cross
walks and ramps.
• Ensure new w
alkways and sidewalks are clear of any obstructions,
including utilities, traffic control devices, trees, and furniture. • Design for seamless, multi-modal pedestrian c
onnections, making
access easy, direct, and comfortable.
The City of Santa Monica leveraged investments
in rail transit and reconfigured Colorado Avenue
to form a multi-modal first/last mile gateway to
the waterfront from the Downtown Santa Monica
Station. Photo by PWP Landscape Architecture
14 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.3 Building Setback
Buildings and structures with a zero lot setback that closely abut Metro ROW can pose concerns to Metro during construction.
Encroachment onto Metro property to construct or maintain buildings is strongly discouraged as this presents safety hazards and may disrupt transit service and/or damage Metro infrastructure.
RECOMMENDATION: Include a minimum setback of five (5) feet from the property line to building facade to accommodate the construction and maintenance of structures without the need to encroach upon Metro property. As local jurisdictions also have building setback requirements, new developments should comply with the greater of the two requirements.
Entry into the ROW by parties other than Metro and its affiliated partners requires written approval. Should construction or maintenance of a development necessitate temporary or ongoing access to Metro ROW, a Metro Right of Entry Permit must be requested and obtained from Metro Real Estate for every instance access is required. Permission to enter the ROW is granted solely at Metro’s discretion.
Coordination between property owners of fences, walls, and other barriers along property line is recommended. See Section 1.5.
Refer to Section 3.2 – Track Access and Safety for additional information pertaining to ROW access in preparation for construction activities.
Property Line
Adjacent
Building
A minimum setback of five (5) feet between an
adjacent structure and Metro ROW is strongly
encouraged to allow project construction and
ongoing maintenance without encroaching on
Metro property.
5’
Min. Setback
Metro Adjacent Development Handbook | 15
1.4 Overhead Catenary System (OCS) Clearance
Landscaping and tree canopies can grow into the OCS above light rail lines, creating electrical safety hazards as well as visual and physical impediments for trains. Building appurtenances facing rail ROW, such as balconies, may also pose safety concerns to Metro operations as objects could fall onto the OCS.
RECOMMENDATION: Design project elements facing the ROW to avoid potential conflicts with Metro transit vehicles and infrastructure. Metro recommends that projects:
• Plan for landscape main
tenance from private property and prevent
growth into Metro ROW. Property owners will not be permitted to access Metro property to maintain private development.
• Design buildings such that balconies do not pr
ovide building users
direct access to Metro ROW.
• Maintain building appurt
enances and landscaping at a minimum
distance of ten (10) feet from the OCS and support structures.
If Transmission Power (TP) feeder cable is present, twenty (20) feet from the OCS and support structures is required. Different standards will apply for Metro Trolley Wires, Feeder Cables (wires) and Span Wires.
Adjacent structures and landscaping should be
sited and maintained to avoid conflicts with the
rail OCS.
R = 20’
R = 20’
Scaffolding and construction equipment should be
staged to avoid conflicts with the rail OCS.
R = 20’
R = 20’
Scaffolding
16 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.5 Underground Station Portal Clearance
Metro encourages transit-oriented development. Where development is planned above station entrances, close coordination is needed for structural safety as well as access for patrons, operations, and maintenance. Below are key design rules of thumb for development planned to cantilever over an entrance to an underground Metro Rail station.
RECOMMENDATION:
1. Preserv
e 25 feet clearance at minimum from plaza grade and the building structure above.
2. Preserv
e 10 feet clearance at minimum between portal roof and
building structure above.
3. Coordinat
e structural support system and touchdown points to
ensure a safe transfer of the building loads above the station portal.
4. Coordinat
e placement of structural columns and amenities (e.g.
signage, lighting, furnishings) at plaza level to facilitate direct and safe connections for people of all mobile abilities to and from station entrance(s).
5. Develop a main
tenance plan for the plaza in coordination with
Metro.
25’ 10’
Station Box
Projects that propose to cantilever over Metro
subway portals require close coordination with
Metro Engineering.
Structural
Touch
Point
Station Entrance
Metro Adjacent Development Handbook | 17
1.6 Shared Barrier Construction & Maintenance
In areas where Metro ROW abuts private property, barrier construction and maintenance responsibilities can be a point of contention with property owners. When double barriers are constructed, the gap created between the Metro-constructed fence and a private property owner’s fence can accumulate trash and make regular maintenance challenging without accessing the other party’s property.
RECOMMENDATION: Coordinate with Metro Real Estate to create a single barrier condition along the ROW property line. With an understanding that existing conditions along ROW boundaries vary throughout LA County, Metro recommends the following, in order of preference:
• Enhance existing Me
tro barrier: if structural capacity allows,
private property owners and developers should consider physically affixing improvements onto and building upon Metro’s existing barrier. Metro is amenable to barrier enhancements such as increasing barrier height and allowing private property owners to apply architectural finishes to their side of Metro’s barrier. • Replace exis
ting barrier(s): if conditions are not desirable, remove and replace any existing barrier(s), including Metro’s, with a new single “shared” barrier built on the property line.
Metro is amenable to sharing costs for certain improvements that allow for clarity in responsibilities and adequate ongoing maintenance from adjacent property owners without entering Metro’s property.
Metro Real Estate should be contacted with case-specific questions and will need to approve shared barrier design, shared financing, and construction.
Metro prefers a single barrier condition along its
ROW property line.
Shared Barrier
Adjacent
Building
Double barrier conditions allow trash
accumulation and create maintenance challenges
for Metro and adjacent property owners.
Private Wall
Metro Barrier
Adjacent
Building
Property LineProperty Line
18 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.7 Project Orientation & Noise Mitigation
Metro may operate in and out of revenue service 24 hours per day, every day of the year, which can create noise and vibration (i.e. horns, power washing). Transit service and maintenance schedules cannot be altered to avoid noise for adjacent developments. However, noise and vibration impacts can be reduced through building design and orientation.
RECOMMENDATION: Use building orientation, programming, and design techniques to reduce noise and vibration for buildings along Metro ROW:
• Locat
e secondary or “back of house” rooms (e.g. bathrooms,
stairways, laundry rooms) along ROW, rather than primary living spaces that are noise sensitive (e.g. bedrooms and family rooms). • Use upper level se
tbacks and locate living spaces away from ROW.
• Enclose balconies.
• Install double-pane windo
ws.
• Include language disclosing poten
tial for noise, vibration, and
other impacts due to transit proximity in terms and conditions for building lease or sale agreements to protect building owners/ sellers from tenant/buyer complaints.
Developers are responsible for any noise mitigation required, which may include engineering designs for mitigation recommended by Metro or otherwise required by local municipalities. A recorded Noise Easement Deed in favor of Metro may be required for projects within 100 feet of Metro ROW to ensure notification to tenants and owners of any proximity issues.
Building orientation can be designed to face away
from tracks, reducing the noise and vibration
impacts.
Strategic placement of podiums and upper-level
setbacks on developments near Metro ROW can
reduce noise and vibration impacts.
Podium helps buffer
sound from ROW
Landscaping
absorbs sound
from ROW
Primary rooms/spaces do
not face tracks
Enclosed balcony
buffers sound
Metro Adjacent Development Handbook | 19
1.8 At-Grade Rail Crossings
New development is likely to increase pedestrian activity at rail crossings. Safety enhancements may be needed to upgrade existing rail crossings to better protect pedestrians.
RECOMMENDATION: Coordinate with Metro, the California Public Utilities Commission (CPUC), and any other transit operators using the crossing (e.g. Metrolink) to determine if safety enhancements are needed for nearby rail crossings.
While Metro owns and operates the rail ROW, the CPUC regulates all rail crossings. Contact the CPUC early in the design process to determine if they will require any upgrades to existing rail crossings.
The CPUC may request to review development plans and hold a site visit to understand future pedestrian activity. Metro’s Corporate Safety Department can support the developer in coordination with the CPUC.
Gates and pedestrian arms are common types of
safety elements for pedestrians at rail crossings.
Safety elements of a gate and pedestrian arms have
been constructed at the Monrovia Station.
20 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.9 Sight-Lines at Crossings
Developments adjacent to Metro ROW can present visual barriers to transit operators approaching vehicular and pedestrian crossings.
Buildings and structures in close proximity to transit corridors can reduce sight-lines and create blind corners where operators cannot see pedestrians. This requires operations to reduce train speeds, which decreases efficiency of transit service.
RECOMMENDATION: Design buildings to maximize transit service sight-lines at crossings, leaving a clear cone of visibility to oncoming vehicles and pedestrians.
Metro Rail Operations will review, provide guidance, and determine the extent of operator visibility for safe operations. If the building envelope overlaps with the visibility cone near pedestrian and vehicular crossings, a building setback may be necessary to ensure safe transit service. The cone of visibility at crossings and required setback will be determined based on vehicle approach speed. Limited sight-lines for trains approaching street crossings create unsafe conditions.
Visibility cones allow train operators to respond to
safety hazards.
Minimum
Setback from
Property Line
Train Operator
Visibility Cone
Additional
Setback for
Visibility
Limited Visibility
for Train Operator
PED X-ING
Property Line
Metro Adjacent Development Handbook | 21
1.10 Driveway/Access Management
Driveways adjacent to on-street bus stops can create conflict for pedestrians walking to/from or waiting for transit. Additionally, driveways accessing parking lots and loading zones at project sites near Metro Rail and BRT crossings can create queuing issues along city streets and put vehicles in close proximity to fast moving trains and buses, which pose safety concerns.
RECOMMENDATION: Site driveways and other vehicular entrances to avoid conflicts with pedestrians, bicycles, and transit vehicles by:
• Placing drivew
ays along side streets and alleys, away from on-
street bus stops and transit crossings to minimize safety conflicts between active ROW, transit vehicles, and people, as well as queuing on streets.
• Locating v
ehicular driveways away from transit crossings or areas that are likely to be used as waiting areas for transit services. • Placing loading docks aw
ay from sidewalks where transit bus stop
activity is/will be present.
• Consolidating vehicular en
trances and reduce width of driveways.
• Using speed tables to slo
w entering/exiting automobiles near
pedestrians.
• Separating pedes
trian walkways to minimize conflict with vehicles.
• Encouraging sa
fe non-motorized travel.
Driveways in close proximity to each other
compromise safety for those walking to/from
transit and increase the potential for vehicle-
pedestrian conflicts.
22 | Metro Adjacent Development Handbook
Site Plan & Conceptual Design
1.11 Bus Stop & Zones Design
Metro Bus serves over 15,000 bus stops throughout the diverse landscape that is LA County. Typically located on sidewalks within public right-of-way owned and maintained by local jurisdictions, existing bus stop conditions vary from well-lit and sheltered spaces to uncomfortable and unwelcoming zones. Metro is interested in working with developers and local jurisdictions to create a vibrant public realm around new developments by strengthening multi-modal access to/ from Metro transit stops and enhancing the pedestrian experience.
RECOMMENDATION: When designing around existing or proposed bus stops:
• Revie
w Metro’s Transit Service Policy, which provides standards for design and operation of bus stops and zones for near-side, far- side, and mid-block stops.
• Revie
w Metro’s Transfers Design Guide for more information at https://www.metro.net/projects/station-design-projects/ • Accommodat
e 5’ x 8’ landing pads at bus doors (front and back
door, which are typically 23 to 25 feet apart).
• Locat
e streetscape elements (e.g. tree planters, street lamps, benches, shelters, trash receptacles and newspaper stands) outside of bus door zones to protect transit access and ensure a clear path of travel.
• Install a c
oncrete bus pad within each bus stop zone to avoid
street asphalt damage.
• Replace st
and-alone bus stop signs with bus shelters that include benches and adequate lighting.
• Design wide sidewalk
s (15’ preferred) that accommodate bus
landing pads as well as street furniture, landscape, and user travel space.
• Consider tree species, height, and c
anopy shape (higher than 14’
preferred) to avoid vehicle conflicts at bus stops. Trees should be set back from the curb and adequately maintained to prevent visual and physical impediments for buses when trees reach maturity. Avoid planting of trees that have an invasive and shallow root system.
Well-designed and accessible bus stops are
beneficial amenities for both transit riders and
users of adjacent developments.
A concrete bus pad should be located at bus stops
and bus shelters should be located along sidewalks
to ensure an accessible path of travel to a clear
boarding area.
Bus Pad Clear Boarding Zone
8’ clear sidewalk to
accommodate
5’ x 8’ pad at bus doors
Metro Adjacent Development Handbook | 23
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Engineering
& Technical
Review
26 | Metro Adjacent Development Handbook
Engineering & Technical Review
2.1 Excavation Support System Design
Excavation near Metro ROW has the potential to disturb adjoining soils and jeopardize support of existing Metro infrastructure. Any excavation which occurs within the geotechnical foul zone relative to Metro infrastructure is subject to Metro review and approval and meet Cal/OSHA requirements. This foul zone or geotechnical zone of influence shall be defined as the area below a track-way as measured from a 45-degree angle from the edge of the rail track ballast.
Construction within this vulnerable area poses a potential risk to Metro service and requires additional Metro Engineering review.
RECOMMENDATION: Coordinate with Metro Engineering staff for review and approval of the excavation support system drawings and calculations prior to the start of excavation or construction. Tiebacks encroaching into Metro ROW may require a tieback easement or license, at Metro’s discretion.
Any excavation/shoring within Metrolink operated and maintained ROW will require compliance with SCRRA Engineering standards and guidelines.
See page 7 for a sample section showing Metro adjacent conditions.
An underground structure located within the
ROW foul zone would require additional review by
Metro.
Property Line
Adjacent
Building
Parking
Tiebacks
ROW
45 Foul Zone
Metro Adjacent Development Handbook | 27
Tiebacks
2.2 Proximity to Tunnels & Underground
Infrastructure
Construction adjacent to, over, or below underground Metro facilities (tunnels, stations and appendages) is of great concern and should be coordinated closely with Metro Engineering.
RECOMMENDATION: Coordinate with Metro early in the design process when proposing to build near underground Metro
infrastructure. Metro typically seeks to maintain a minimum eight (8) foot clearance from existing Metro facilities to new construction (shoring or tiebacks). It will be incumbent upon the developer to demonstrate, to Metro’s satisfaction, that both the temporary support of construction and the permanent works do not adversely affect the structural integrity, safety, or continued efficient operation of Metro facilities.
Dependent on the nature of the adjacent construction, Metro will need to review the geotechnical report, structural foundation plans, sections, shoring plan sections and calculations.
Metro may require monitoring where such work will either increase or decrease the existing overburden (i.e. weight) to which the tunnels or facilities are subjected. When required, the monitoring will serve as an early indication of excessive structural strain or movement. See Section 3.4, Excavation Drilling/Monitoring for additional information regarding monitoring requirements.
See page 7 for a sample section showing Metro adjacent conditions.
Adjacent project structures in close proximity to
underground Metro infrastructure will require
additional review by Metro.
ParkingFoundation
Building
Building
R=8’
Min. from tunnels
28 | Metro Adjacent Development Handbook
Engineering & Technical Review
An underground structure proposed within twenty
(20) feet of a Metro structure may require a Threat
Assessment and Blast/Explosion Study.
Parking
Property Line
2.3 Protection from Explosion/Blast
Metro is obligated to ensure the safety of public transit infrastructure from potential explosive sources which could originate from adjacent underground structures or from at-grade locations, situated below elevated guideways or near stations. Blast protection setbacks or mitigation may be required for large projects constructed near critical Metro facilities.
RECOMMENDATION: Avoid locating underground parking or
basement structures within twenty (20) feet from an existing Metro tunnel or facility (exterior face of wall to exterior face of wall).
Adjacent developments within this 20-foot envelope may be required to submit a Threat Assessment and Blast/Explosion Study for Metro review and approval.
20’
BLAST
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Construction
Safety &
Management
32 | Metro Adjacent Development Handbook
Construction Safety & Management
3.1 Pre-Construction Coordination
Metro is concerned with impacts to service requiring rail single line tracking, line closures, speed restrictions, and bus bridging occurring as a result of adjacent project construction. Projects that will require work over, under, adjacent, or on Metro property or ROW and include operation of machinery, scaffolding, or any other potentially hazardous work are subject to evaluation in preparation for and during construction to maintain safe transit operations and passenger well- being.
RECOMMENDATION: Following an initial screening of the project, Metro may determine that additional on-site coordination may be necessary. Dependent on the nature of the adjacent construction, developers may be requested to perform the following as determined on a case-by-case basis:
• Submit a construction w
ork plan and related project drawings and
specifications for Metro review.
• Submit a conting
ency plan, show proof of insurance coverage, and
issue current certificates.
• Provide documen
tation of contractor qualifications.
• Complete pr
e-construction surveys, perform baseline readings,
and install movement instrumentation.
• Complete r
eadiness review and perform practice run of transit
service shutdown per contingency plan.
• Designate a R
OW observer or other safety personnel and an
inspector from the project’s construction team.
• Establish a
coordination process for access and work in or adjacent to ROW for the duration of construction.
Project teams will be responsible for the costs of adverse impacts to Metro transit operations caused by work on adjacent developments, including remedial work to repair damage to Metro property, facilities, or systems. Additionally, a Construction Monitoring fee may be assessed based on an estimate of required level of effort provided by Metro.
All projects adjacent to Metrolink infrastructure will require compliance with SCRRA Engineering Standards and Guidelines.
Metro may need to monitor development
construction near Metro facilities.
Metro Adjacent Development Handbook | 33
3.2 Track Access and Safety
Permission from Metro is required to enter Metro property for rail construction and maintenance along, above, or under Metro ROW as these activities can interfere with Metro utilities and service and pose a safety hazard to construction teams and transit riders. Track access is solely at Metro’s discretion and is discouraged to prevent electrocution and collisions with construction workers or machines.
RECOMMENDATION: Obtain and/or complete the following to work in or adjacent to Metro Rail ROW:
1. Construction Work Plan:
Dependent on the nature of adjacent
construction, Metro may request a construction work plan, which describes means and methods and other construction plan details, to ensure the safety of transit operators and riders.
2. Safe
ty Training: All members of the project construction team will be required to attend Metro Rail Safety Training before commencing work activity. Training provides resources and procedures when working near active rail ROW.
3. Right of Entr
y Permit/Temporary Construction Easement: All
access to and activity on Metro property, including easements necessary for construction of adjacent projects, must be approved through a Right-of-Entry Permit and/or a Temporary Construction Easement obtained from Metro Real Estate and may require a fee.
4. Track Alloc
ation: All work on Metro Rail ROW must receive prior
approval from Metro Rail Operations Control. Track Allocation identifies, reserves, and requests changes to normal operations for a specific track section, line, station, location, or piece of equipment to allow for safe use by a non-Metro entity. If adjacent construction is planned in close proximity to active ROW, flaggers must be used to ensure safety of construction workers and transit riders.
Trained flaggers ensure the safe crossing
of pedestrians and workers of an adjacent
development.
34 | Metro Adjacent Development Handbook
Construction Safety & Management
3.3 Construction Hours
Building near active Metro ROW poses safety concerns and may require limiting hours of construction which impact Metro ROW to night or off-peak hours so as not to interfere with Metro revenue service. To maintain public safety and access for Metro riders, construction should be planned, scheduled, and carried out in a way to avoid impacts to Metro service and maintenance.
RECOMMENDATION: In addition to receiving necessary construction approvals from the local jurisdiction, all construction work on or in close proximity to Metro ROW must be scheduled through the Track Allocation Process, detailed in Section 3.2.
Metro prefers that adjacent construction with potential to impact normal, continuous Metro operations take place during non-revenue hours (approximately 1am-4am) or during non-peak hours to minimize impacts to service. The developer may be responsible for additional operating costs resulting from disruption to normal Metro service.
Construction during approved hours ensures
the steady progress of adjacent development
construction and minimizes impacts to Metro’s
transit service.
Metro Adjacent Development Handbook | 35
3.4 Excavation/Drilling Monitoring
Excavation is among the most hazardous construction activities and can pose threats to the structural integrity of Metro’s transit infrastructure.
RECOMMENDATION: Coordinate with Metro Engineering to review and approve excavation and shoring plans during design and development, and well in advance of construction (see Sections 2.1 and 2.2).
Geotechnical instrumentation and monitoring will be required for all excavations occurring within Metro’s geotechnical zone of influence, where there is potential for adversely affecting the safe and efficient operation of transit vehicles. Monitoring of Metro facilities due to adjacent construction may include the following as determined on a case-by-case basis:
• Pre- and post
-construction condition surveys
• Extensome
ters
• Inclinometer
s
• Settlement r
eference points
• Tilt-met
ers
• Groundwa
ter observation wells
• Movemen
t arrays
• Vibration monit
oring
Excavation and shoring plans must be reviewed
by Metro to ensure structural compatibility with
Metro infrastructure and safety during adjacent
development construction.
A soldier pile wall used for Regional Connector
station at 2nd/Hope.
36 | Metro Adjacent Development Handbook
Construction Safety & Management
3.5 Crane Operations
Construction activities adjacent to Metro ROW may require moving large, heavy loads of building materials and machinery using cranes.
Cranes referenced here include all power-operated equipment that can hoist, lower, and horizontally move a suspended load. To ensure safety for Metro riders, operators, and transit facilities, crane operations adjacent to Metro ROW must follow the safety regulations and precautions below and are subject to California Occupational Safety and Health Administration (Cal/OSHA) standards.
RECOMMENDATION:
Coordinate with Metro to discuss construction methods and confirm if a crane work plan is required. Generally, crane safety near Metro’s ROW and facilities largely depends on the following factors: 1) Metro’s operational hours and 2) swinging a load over or near Metro power lines and facilities. Note:
1. Clearance: A crane
boom may travel over energized Metro OCS only
if it maintains a vertical 20-foot clearance and the load maintain a horizontal 20-foot clearance.
2. Pow
er: Swinging a crane boom with a load over Metro facilities or passenger areas is strictly prohibited during revenue hours.
To swing a load in the “no fly zone” (see diagrams to right), the construction team must coordinate with Metro to de-energize the OCS.
3. Weather
vaning: When not in use, the crane boom may swing 360
degrees with the movement of the wind, including over energized Metro OCS, only if the trolley is fully retracted towards the crane tower and not carrying any loads.
4. Process: Dev
elopers and contractors must attend Metro Track
Allocation (detailed in Section 3.2) to determine if Metro staff support is necessary during crane erection and load movement.
5. Permit: Dev
elopers must apply for a Metro Right-of-Entry permit to swing over Metro facilities.
Project teams will bear all costs associated with impacts to Metro Rail operations and maintenance.
Plan View: While crane boom swings over “no
fly zone,” the trolley and load are retracted to
maintain clearance from OCS.
Cranes and construction equipment should be
staged to avoid conflicts with the rail OCS.
“No fly zone”
20’
20’
Load
Trolley
Tower
(Mast)
Boom
(Jib)
“No fly zone”20’ Setback from OCS
Construction Site
Metro ROW
Adjacent Building
OCS
Load
Tower
Plan View: Crane swing and load are restricted
near Metro ROW.
“No fly zone”20’ Setback from OCS
Construction Site
Metro ROW
Adjacent Building
Load
Tower
Metro Adjacent Development Handbook | 37
3.6 Construction Barriers & Overhead Protection
During construction, falling objects can damage Metro facilities and pose a safety concern to the riders accessing them.
RECOMMENDATION: Erect vertical construction barriers and overhead protection compliant with Metro and Cal/OSHA requirements to prevent objects from falling into Metro ROW or areas designed for public access to Metro facilities. A protection barrier shall be constructed to cover the full height of an adjacent project and overhead protection from falling objects shall be provided over Metro ROW as necessary. Erection of the construction barriers and overhead protection for these areas shall be done during Metro non-revenue hours.
Overhead protection is required when moving
heavy objects over Metro ROW or in areas
designated for public use.
Constructed above is a wooden box over the
entrance portal for overhead protection at the
4th/Hill Station.
38 | Metro Adjacent Development Handbook
Construction Safety & Management
3.7 Pedestrian & Emergency Access
Metro’s riders rely on the consistency and reliability of access and wayfinding to and from stations, stops, and facilities. Construction on adjacent property must not obstruct pedestrian access, fire department access, emergency egress, or otherwise present a safety hazard to Metro operations, its employees, riders, and the general public. Fire access and safe escape routes within all Metro stations, stops, and facilities must be maintained at all times.
RECOMMENDATION: Ensure pedestrian and emergency access
from Metro stations, stops, and transit facilities is compliant with the Americans with Disabilities Act (ADA) and maintained during construction:
• Temporar
y fences, barricades, and lighting should be installed
and watchmen provided for the protection of public travel, the construction site, adjacent public spaces, and existing Metro facilities.
• Temporar
y signage should be installed where necessary and in
compliance with the latest California Manual on Uniform Traffic Control Devices (MUTCD) and in coordination with Metro Art and Design Standards.
• Emergency e
xits shall be provided and be clear of obstructions at
all times.
• Access shall be maintained f
or utilities such as fire hydrants, stand
pipes/connections, and fire alarm boxes as well as Metro-specific infrastructure such as fan and vent shafts.
Sidewalk access is blocked for a construction
project, forcing pedestrians into the street or to use
less direct paths to the Metro facility.
Metro Adjacent Development Handbook | 39
3.8 Impacts to Bus Routes & Stops
During construction, bus stop zones and routes may need to be temporarily relocated. Metro needs to be informed of activities that require stop relocation or route adjustments in order to ensure uninterrupted service.
RECOMMENDATION: During construction, maintain or relocate existing bus stops consistent with the needs of Metro Bus Operations.
Design of temporary and permanent bus stops and surrounding sidewalk areas must be compliant with the ADA and allow passengers with disabilities a clear path of travel to the transit service. Existing bus stops must be maintained as part of the final project. Metro Bus Operations Control Special Events Department and Metro Stops & Zones Department should be contacted at least 30 days before initiating construction activities.
Temporary and permanent relocation of bus
stops and layover zones will require coordination
between developers, Metro, and other municipal
bus operators and local jurisdictions.
40 | Metro Adjacent Development Handbook
Construction Safety & Management
3.9 Utility Coordination
Construction has the potential to interrupt utilities that Metro relies on for safe operations and maintenance. Utilities of concern to Metro include, but are not limited to, condenser water piping, potable/fire water, storm and sanitary sewer lines, and electrical/ telecommunication services.
RECOMMENDATION: Coordinate with Metro Real Estate during project design to gauge temporary and permanent utility impacts and avoid conflicts during construction.
The contractor shall protect existing above-ground and underground Metro utilities during construction and coordinate with Metro to receive written approval for any utilities pertinent to Metro facilities that may be used, interrupted, or disturbed.
When electrical power outages or support functions are required, approval must be obtained through Metro Track Allocation in coordination with Metro Real Estate for a Right of Entry Permit.
To begin coordination with Metro Real Estate, visit www.metro.net/ devreview and select the drop-down “Utility Project Coordination.” Coordination of underground utilities is critical to
safely and efficiently operate Metro service.
Metro Adjacent Development Handbook | 41
3.10 Air Quality & Ventilation Protection
Hot or foul air, fumes, smoke, steam, and dust from adjacent construction activities can negatively impact Metro facilities, service, and users.
RECOMMENDATION: Ensure that hot or foul air, fumes, smoke, and steam from adjacent facilities are discharged beyond 40 feet from existing Metro facilities, including but not limited to ventilation system intake shafts and station entrances. Should fumes be discharged within 40 feet of Metro intake shafts, a protection panel around each shaft shall be required.
A worker breaks up concrete creating a cloud of
silica dust.
42 | Metro Adjacent Development Handbook
Glossary
Cone of Visibility
A conical space at the front of moving transit vehicles allowing for clear visibility of travel way and/or conflicts.
Construction Work Plan (CWP)
Project management document outlining the definition
of work tasks, choice of technology, estimation of
required resources and duration of individual tasks, and identification of interactions among the different work tasks.
Flagger/Flagman
Person who controls traffic on and through a construction project. Flaggers must be trained and certified by Metro Rail Operations prior to any work commencing in or
adjacent to Metro ROW.
Geotechnical Foul Zone
Area below a track-way as measured from a 45-degree
angle from the edge of the rail track ballast.
Guideway
A channel, track, or structure along which a transit
vehicle moves.
Heavy Rail Transit (HRT)
Metro HRT systems include exclusive ROW (mostly
subway) trains up to six (6) cars long (450’) and utilize a contact rail for traction power distribution (e.g. Metro Red Line).
Joint Development (JD)
JD is the asset management and real estate development
program through which Metro collaborates with
developers to build housing, retail, and other amenities on Metro properties near transit, typically through
ground lease. JD projects directly link transit riders with destinations and services throughout LA County.
Light Rail Transit (LRT)
Metro LRT systems include exclusive, semi-exclusive, or street ROW trains up to three (3) cars long (270’) and
utilize OCS for traction power distribution (e.g. Metro Blue Line).
Measure R
Half-cent sales tax for LA County approved in November
2008 to finance new transportation projects and
programs. The tax expires in 2039.
Measure M
Half-cent sales tax for LA County approved in November
2016 to fund transportation improvements, operations
and programs, and accelerate projects already in the
pipeline. The tax will increase to one percent in 2039
when Measure R expires.
Metrolink
A commuter rail system with seven lines throughout Los
Angeles, Orange, Riverside, San Bernardino, Ventura,
and North San Diego counties governed by the Southern
California Regional Rail Authority (SCRRA).
Metro Adjacent Construction Design Manual
Volume III of the Metro Design Criteria & Standards,
which outlines the Metro adjacent review procedure as
well as operational requirements when constructing over, under, or adjacent to Metro facilities, structures, and property.
Metro Bus
Metro “Local” and “Rapid” bus service runs within
the street, typically alongside vehicular traffic, though occasionally in “bus-only” lanes.
Metro Bus Rapid Transit (BRT)
High quality bus service that provides faster and
convenient service through the use of dedicated ROW,
branded vehicles and stations, high frequency and
intelligent transportation systems, all-door boarding, and intersection crossing priority. Metro BRT may run within dedicated ROW or in mixed flow traffic on streets.
Metro Adjacent Development Handbook | 43
Metro Design Criteria and Standards
A compilation of documents that govern how Metro
transit service and facilities are designed, constructed, operated, and maintained.
Metro Rail
Urban rail system serving LA County consisting of six lines, including two subway lines and four light rail lines.
Metro Rail Design Criteria (MRDC)
Volume IV of the Metro Design Criteria & Standards
which establishes design criteria for preliminary
engineering and final design of a Metro Rail Project.
Metro Transit Oriented Communities
Land use planning and community development program
that seeks to maximize access to transportation as a key organizing principle and promote equity and sustainable living by offering a mix of uses close to transit to support households at all income levels, as well as building
densities, parking policies, urban design elements, and first/last mile facilities that support ridership and reduce auto dependency.
Noise Easement Deed
Easement granted by property owners abutting Metro
ROW acknowledging noise due to transit operations and
maintenance.
Overhead Catenary System (OCS)
One or more electrified wires situated over a transit ROW that transmit power to light rail trains via pantograph, a current collector mounted on the roof of an electric
vehicle. Metro OCS is supported by hollow poles placed
between tracks or on the outer edge of parallel tracks.
Right of Entry Permit
Written approval granted by Metro Real Estate to enter
Metro ROW and property.
Right of Way (ROW)
Legal right over property reserved for transportation
purposes to construct, protect, maintain and operate
transit services.
Southern California Regional Rail Authority (SCRRA)
A joint powers authority made up of an 11-member
board representing the transportation commissions
of Los Angeles, Orange, Riverside, San Bernardino and
Ventura counties. SCRRA governs and operates Metrolink
service.
Threat Assessment and Blast/Explosion Study
Analysis performed when adjacent developments are
proposed within twenty (20) feet from an existing Metro tunnel or facility.
Track Allocation/Work Permit
Permit granted by Metro Rail Operations Control to
allocate a section of track and perform work on or
adjacent to Metro Rail ROW. This permit should be
submitted for any work that could potentially foul the
envelope of a train.
Wayfinding
Signs, maps, and other graphic or audible methods used
to convey location and directions to travelers.
44 Metro Adjacent Development Handbook
metro.net/projects/devreview/
General Plan EIR Comments
Jon Bridgeman <[email protected]>
Mon 5/13/2024 5:49 PM
To: O'Brien, Dan <Dan.O'[email protected]>; Puza, Freddy <[email protected]>; Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
To Advance Planning, City Council and Planning Chairperson, I am an environmental consultant who lives in Fox Hills and works across Los Angeles. I understand housing is an issue for all Culver City residents and with that in mind, I want to stress these responses to the General Plan EIR.
Here are my concerns:
Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need to account for the density bonus (doubles the allowed density) Fox Hills' current buildings are older and either have no capability of adding AC systems or are cost-prohibitive. The current cooling system for Fox Hills relies on natural ocean breeze. In my unit, our windows and sliding doors are open over 12 hours a day, sometimes 24 hours a day to make use of the ocean breeze. It is the most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze.
This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. There needs to be a study to assess the effect these new developments will have on the ocean breeze by a climate/weather expert. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation). Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 3 to 6 times from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,….), city services, schools, etc). In summary, our quality of life.
Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers? We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots to build on. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre. (their plan is 75-100 units affordable units of the 1105 they are planning) Jonathan Bridgeman
5/14/24, 8:01 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/2 4-1
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Fox Hills resident and proponent of more housing for all Culver City 5/14/24, 8:01 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 2/2 4-8
cont.
General Plan for Fox Hills
Anna Budevska <[email protected]>
Mon 5/13/2024 11:24 AM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important Dear City council and city staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems.
The
current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze ef
fect based on the new General
Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the 5/13/24, 11:27 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/2 5-1
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5-5
environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY
, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit.
They may add a few affordable housing but not enough.
Also, the city is losing all the
leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density.
Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Anna Budevska
Fox Hills resident
5/13/24, 11:27 AM Mail - Reyes, Oscar - Outlook
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cont.
5-6
5-7
5-8
5-9
Fox Hills General Plan
YK G <[email protected]>
Sun 5/12/2024 6:14 AM
To: Culver City Advance Planning Division <[email protected]>; Vera, Albert <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>; Puza, Freddy <[email protected]>; Eriksson, Goran <[email protected]>; Jones, Stephen <[email protected]>; McMorrin, Yasmine <Yasmine- [email protected]>
EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Some people who received this message don't often get email from [email protected]. Learn why this is important Dear City council and city staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems.
The
current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze ef
fect based on the new General
Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traf
fic, street parking, ocean breeze,
5/13/24, 7:40 AM Mail - Reyes, Oscar - Outlook
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basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY
, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit.
They may add a few affordable housing but not enough.
Also, the city is losing all the
leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density.
Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Yihui Gould
Fox Hills resident
5/13/24, 7:40 AM Mail - Reyes, Oscar - Outlook
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cont.
Hello
Gloria Ko <[email protected]>
Sun 5/12/2024 7:37 AM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Some people who received this message don't often get email from [email protected]. Learn why this is important Dear City council and city staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems.
The
current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. W
e need to know what happens to our ocean breeze if
the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all 5/13/24, 7:40 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/3 7-1
the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY
, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few af
fordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it.
They make profit w/ the 100
units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Gloria Moritz
Fox Hills resident
____________________________________________________________________________ _
Are we against housing in Fox Hills?
No, we understand that we need housing, but we want equitable distribution of housing. One single neighborhood can not be the answer for all Culver City housing.
What is the total number of housing Culver City is requested by the state to create? 3341 units.
How many current proposed projects in Fox Hills?
1705 units (3 projects) + Bristol Plaza, rumor of 1000 units. Total: 2705 units 5/13/24, 7:40 AM Mail - Reyes, Oscar - Outlook
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cont.
What is a General Plan?
A general plan is each local government's blueprint for meeting the community's long-term vision for the future. One of the important things that sets is the zoning parameters. The new Culver City General Plan is for the next 20-30 years.
What is the current density for mix use zoning in Fox Hills? Density Mix use zoning is 35 units/acre.
What is in the General Plan for Fox Hills?
Proposed mix use is 100 units/Acre. About 300% increase in our density.
Is this the maximum number of units they can develop?
No. Developers can obtain a density bonus doubling the number of units. We could have up to 200 units/Acre. 600% increase in our density.
5/13/24, 7:40 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 3/3 Fox Hills Planning
MELISSA KORC <[email protected]>
Mon 5/13/2024 2:35 PM
To: Culver City Advance Planning Division <[email protected]> Cc: O'Brien, Dan <Dan.O'[email protected]>; Puza, Freddy <[email protected]>; Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Jones, Stephen <[email protected]>; McMorrin, Yasmine <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important To Advance Planning, City Council and Planning Chairperson, This is a response to the General Plan EIR.
Here are my concerns:
Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need to account for the density bonus (doubles the allowed density)
The CA law for composting is very difficult to meet in our buildings. Our buildings were built so long ago that we don’t have enough space for trash, recycling and organic bins. This requires us to get the small cart which is not ideal in large buildings.
Our older buildings do not allow for EV charging. We tried adding it our building through a program with SCE. However, we were told it would require a transformer outside and the city denied the request. It makes us homeowners trying to keep our value of condo and help the environment be put in a tough spot. The new buildings would be built this with no consideration for us in older buildings.
Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. There needs to be a study to assess the effect these new developments will have on the ocean breeze by a climate/weather expert. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation). Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
5/13/24, 3:55 PM Mail - Reyes, Oscar - Outlook
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8-2
8-3
8-4
8-5
The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 3 to 6 times from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots to build on. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre. (their plan is 75-100 units affordable units of the 1105 they are planning)
FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Melissa Korc
Fox Hills resident
Melissa Korc
Sent from my iPhone
5/13/24, 3:55 PM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 2/2 8-5
cont.
8-6
8-7
8-8
8-9
8-10
Response for General Plan EIR
[email protected] <[email protected]>
Mon 5/13/2024 4:41 PM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important Dear City council and city staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems.
The
current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze ef
fect based on the new General
Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the 5/13/24, 4:45 PM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/2 9-1
environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY
, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit.
They may add a few affordable housing but not enough.
Also, the city is losing all the
leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density.
Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
Yumi Mandt-Rauch
Fox Hills resident
5/13/24, 4:45 PM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 2/2 9-1
cont.
Throwing ALL housing to Fox Hills
Karyn Marks <[email protected]>
Sun 5/12/2024 9:27 AM
To: Culver City Advance Planning Division <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important To Whom It May Concern,
I know it’s easier to just throw all housing to Fox Hills. Fox Hills has ALWAYS been the “Redheaded Stepchild” of Culver City.
When you throw ALL of the housing to our area. You Clearly destroy our quality of life.
There is NO WAY the traffic will be acceptable. It is already impossible.
The architects told us to "fight all you want but this is a done deal.” They said (and I quote) “The City Council plans to pack Fox Hills with housing.”
This is a blatant disregard for all who live here, for all who supported you! This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit.
All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. W
e need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5/13/24, 7:41 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/2 10-1
10-2
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer
, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little af
fect to current residents. South of Slauson should be
no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit.
They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more af fordable housing. It makes no
sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density.
Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Karyn Marks
310-892-3977
Fox Hills resident
5/13/24, 7:41 AM Mail - Reyes, Oscar - Outlook
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cont.
Comments on GENERAL PLAN - Culver City
Gildardo Ramirez Jr. <[email protected]>
Fri 5/24/2024 2:29 PM
To: Culver City Advance Planning Division <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important Dear Members of the City Council and Planning Chairperson, I am writing in response to the concerns raised about the General Plan EIR regarding the proposed zoning density changes in Fox Hills. It's my understanding that I missed the May 13th deadline to submit such comments, but I thought it best to submit them nonetheless. While I understand and appreciate the apprehensions of my fellow residents, I believe there are significant benefits to the proposed plan that warrant consideration. Below, I address the specific concerns highlighted.
1. Zoning Density: The proposed density increase to 100 units/acre with the potential for a density bonus may seem excessive at first glance. However, it is essential to recognize the pressing need for housing in Culver City and the broader region. Higher density zoning can help address the housing shortage, reduce housing costs, and provide more affordable housing options. Moreover, modern urban planning techniques can mitigate the potential negative impacts on infrastructure and quality of life.
2. Cooling Systems and Ocean Breeze: The concern about blocking ocean breezes and increasing temperatures is valid, but it is important to note that new developments can be designed to minimize these effects. Architects and planners can incorporate designs that allow for airflow and utilize advanced cooling technologies that are energy-efficient and environmentally friendly. Additionally, a study by climate and weather experts can be conducted to ensure that new developments do not significantly impact the natural cooling benefits currently enjoyed by residents.
3. Environmental Impact: The Environmental Impact Report (EIR) acknowledges “Unavoidable Significant Impact” in areas such as air quality, noise, and transportation. It is crucial to ensure that the EIR fully accounts for maximum development scenarios, including potential density bonuses. This transparency allows for better planning and the implementation of mitigation strategies to minimize these impacts. However, increased density can also lead to more efficient land use, reducing sprawl and preserving open spaces elsewhere.
4. Quality of Life and Community Charact
er: While concerns about losing Fox Hills's unique
character are valid, it is important to recognize that neighborhoods' character naturally evolves over time. Fox Hills has undergone numerous changes over the years, adapting to 5/24/24, 3:00 PM Mail - Reyes, Oscar - Outlook
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its residents' needs and the broader societal trends. This evolution is a testament to our community's resilience and dynamism.
Historically, Fox Hills has seen various phases of development, from its early days with single-family homes to the introduction of multifamily units and commercial spaces. Each phase brought new amenities, infrastructure improvements, and a broader mix of residents, enhancing the area's vibrancy and economic diversity. This continuous evolution has enriched the community, making it more inclusive and dynamic.
Cities are living entities that must evolve to meet the changing needs of their inhabitants.
With the current housing crisis and increasing urban populations, higher-density developments are essential to provide affordable housing, reduce urban sprawl, and promote sustainable living. Thoughtful urban planning can ensure that these developments are integrated seamlessly with the existing environment, preserving the unique character of Fox Hills while accommodating new growth.
Additionally, higher-density housing can bring numerous benefits to the community, such as:
Increased Economic Activity: More residents can support local businesses, leading to a more vibrant local economy.
Enhanced Public Amenities: Higher density can justify the development of better public amenities, including parks, community centers, and public transportation, improving the quality of life for all residents.
Sustainability: Concentrating development within existing urban areas helps preserve open spaces and reduces the environmental impact of suburban sprawl. Modern construction techniques and green building standards can further mitigate environmental concerns.
It is also worth noting that other cities that have embraced higher-density development have successfully maintained their unique character while providing much-needed housing and amenities. Examples from cities like Portland, OR, and Vancouver, BC, demonstrate that with careful planning and community involvement, it is possible to balance growth with preservation.
5. Development Location and Density Allocation: The proposal to concentrate higher density north of Slauson and limit density south of Slauson is a reasonable compromise. However, it is essential to balance this with the need for equitable development across the city.
Ensuring that new developments include a mix of market-rate and affordable housing is crucial. Incentivizing developers to provide affordable units through density bonuses can be an effective strategy if properly managed.
6. State Compliance and Developer Incentives: It is true that state regulations require cities to plan for adequate housing across all income levels. Reducing density too much could jeopardize compliance with these requirements. However, the city has leverage in 5/24/24, 3:00 PM Mail - Reyes, Oscar - Outlook
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cont
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negotiating with developers to ensure that new projects meet community needs while still providing sufficient housing units.
In conclusion, while the concerns raised about the proposed density increases in Fox Hills are valid, they can be addressed through careful planning and community engagement. Increased density, if managed well, can bring numerous benefits, including more affordable housing, better land use, and a more vibrant community. It is crucial for the city to conduct thorough studies, engage with residents, and implement measures to mitigate any adverse impacts, ensuring that the development benefits all members of the community.
Thank you for considering these points.
Sincerely,
Gil Ramirez
6435 Green Valley Circle, Unit 308
Culver City, CA 90230
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cont.
Fox Hills General Plan
Pouran <[email protected]>
Sun 5/12/2024 8:16 PM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
You don't often get email from [email protected]. Learn why this is important Dear City council and city staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit. All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. We need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation). Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City. That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little affect to current residents. South of Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit. They may add a 5/13/24, 7:41 AM Mail - Reyes, Oscar - Outlook
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few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Pouran Saeedi
Fox Hills resident
Sent from my iPhone
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cont.
COMMENT
S TO BE ADDRESSED RE: THE EIR FOR THE CULVER CITY DRAFT GENERAL PLAN:
Per the Advance Planning Division, the 100 units/acre density designation was not put on the north side of Slauson , which presently has no housing and far less traffic than the south side of Slauson, because of developer preference for larger parcels, thus the south side of Slauson is presently designated for 100 units/acre under the city’s Draft GP. This decision resulted in thus far, 3 developers, proposing a total of 1706 units with most likely more proposals to be submitted to include a probable large development in the former site of CVS on Bristol Parkway, adding most likely another proposed 700 to 1000 units. All these proposals are concentrated on the south side of Hannum, which is even a smaller area of concentration than just the south side of Slauson. Presently all of the 2800 units in 26 complexes in Fox Hills, located south of Hannum, make it the densest housing area in Culver City.
According to the results of the EIR, there will be a potential for Unavoidable Significant Impact on several areas to include air quality, noise and transportation. Based on the above results of the EIR, please clarify, if the same significant impact on air quality would occur with development of 100 units per acre as with 50 units per acre? Or, let's say, that a bulk of the units would be on the north side of Slauson. Would that also produce the same unavoidable impact on air quality for the south side of Slauson, where all the building is being proposed now? Please be specific with documented proof.
As verified by the Advance Planning manager, the reason that the 100 unit/acre designation was not placed on the north side of Slauson in Fox Hills is developer preference for larger parcels and that he said that was the only reason he could think of. The Community Development Director stated: “An EIR requires the study of a reduced density alternative. As there is already a designation of 65 units/acre, 80 units/acre was selected as there needs to be a significant difference between existing densities (in this case, between 65 and 100). ESA, in conjunction with City staff, developed that option.” This response was emailed to me when I wrote: “We know about the housing element and that if the land use element is changed to decrease density designation in certain areas it would have to be done by City Council. The "option"of 80 units/acre, as you know, would not significantly decrease the density south of Slauson and is not a serious option at all.” You must give a logical explanation (not developer preference) as to why the 100 units/acre designation will not be changed to the north side of Slauson in Fox Hills. Then, the lower density could go on the south side of Slauson. If the city was really concerned about air quality and its impact on citizens, tell us why it is not being done. 50 units/acre would be most desirable, as we know now that the developers can get their density doubled anyway.
Presen
tly, the residents in Fox Hills have natural breeze to cool their units and the present infrastructure have either no capacity for air conditioning or only for portable air conditioning. Given the air blockage that will occur with these new developments, reaching 7 stories high, this will affect residents tremendously. When I asked how the city is addressing this issue, I received the following comment from Advance Planning: ““CEQA Guidelines do not provide a threshold pertinent to ocean breezes. 13-1
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The City anticipates that given the topography as well as the setbacks and articulation required in the Zoning Code Update standards, that breezes would not be obstructed.” Documented scientific proof from a weather/climate expert is needed and not a general statement. Please address responsibly.
Thank you.
Judi Sherman
On the board of the Fox Hills Neighborhood Association
Resident of Fox Hills
Per the Advance Planning Division:
As stated in the draft EIR, Since “CEQA Guidelines do not provide a threshold pertinent to ocean breezes” The City anticipates that given the topography as well as the setbacks and articulation required in the Zoning Code Update standards, that breezes would not be obstructed.” 13-5
cont.
FW: EIR for General Plan
Evangelho, Troy <[email protected]>
Tue 4/23/2024 4:40 PM
To: Reyes, Oscar <[email protected]>
Hi Oscar,
Please include this in the EIR comments.
Thank you,
Troy Evangelho, AICP
Advance Planning Manager
Culver City, Planning and Development
9770 Culver Boulevard, Culver City, CA 90232
(310) 253-5744 /
[email protected]
From: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org> Sent: Thursday, April 18, 2024 7:02 PM
To: Evangelho, Troy <[email protected]>
Subject: Re: EIR for General Plan
EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Good evening Troy,
Thanks, as always for your responses.
I was under the impression that ESA did the report and they identified the significant impact problems and not the city. Is that correct?
To clarify, for example, the same significant impact on air quality would occur with development of 100 units per acre as with 50 units per acre? FYI: South of Hannum , the tally is up to 1709 units of mixed-use development with more than likely, another 1000 units to be proposed at the Fox Hills Plaza site, which would total 2700 units. Or, let's say, that a bulk of the units would be on the north side of Slauson. Would that also produce the same unavoidable impact on air quality for the south side of Slauson, where all the building is being proposed now? Also, who in "The City" determined the conclusions regarding the ocean breeze? Were they climate scientists or someone with expertise in the field of weather/climate? Please let us know who actually showed documented proof that ocean breezes would not be obstructed by the magnitude of development proposed in Fox Hills on the south side of Slauson.
Thanks once again for your clarifications and look forward to your responses.
Judi
From: Evangelho, Troy <[email protected]>
Sent: Wednesday, April 17, 2024 10:47 AM
4/23/24, 4:47 PM Mail - Reyes, Oscar - Outlook
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To: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org > Subject: RE: EIR for General Plan
Hi Judi,
You are correct that the City has iden fied a number of topics that will poten ally create a significant unavoidable impact. For next steps there are several op ons. The City could choose to make a “statement of overriding considera on” where it acknowledges the impacts, but chooses to con nue with the project as proposed regardless. Another op on would be to choose a less impac ul or scaled down op on. However, I believe even the less impac ul op ons create poten al significant unavoidable impacts.
Regarding ocean breezes, the City does not an cipate making any changes. As stated in the dra EIR, “CEQA Guidelines do not provide a threshold per nent to ocean breezes. The City an cipates that given the topography as well as the setbacks and ar cula on required in the Zoning Code Update standards, that breezes would not be obstructed.”
Regards,
Troy Evangelho, AICP
Advance Planning Manager
Culver City, Planning and Development
9770 Culver Boulevard, Culver City, CA 90232
(310) 253-5744 /
[email protected]
From: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org > Sent: Wednesday, April 10, 2024 7:16 PM
To: Evangelho, Troy <[email protected]>
Subject: Re: EIR for General Plan
EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Thank you again Troy.
So, at this point with air quality, noise, and the other items that have been analyzed by ESA as having significant impact that is unavoidable, what is the city obligated to do regarding these problem areas.
I realize that ESA listed the ocean breeze issue as a concern, so how is the city planning to address this issue? Actually that is the question I meant to ask.
Thanks
Judi
From: Evangelho, Troy <[email protected]>
Sent: Wednesday, April 10, 2024 5:09 PM
To: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org > Subject: RE: EIR for General Plan
Hi Judi,
4/23/24, 4:47 PM Mail - Reyes, Oscar - Outlook
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Yes there is references and discussion of ocean breezes.
Pg. 14 - Issues raised during no ce of prepara on process and areas of controversy Pg. 100 – Aesthe cs, listed under the “other” category
Regards,
Troy Evangelho, AICP
Advance Planning Manager
Culver City, Planning and Development
9770 Culver Boulevard, Culver City, CA 90232
(310) 253-5744 /
[email protected]
From: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org > Sent: Tuesday, April 9, 2024 11:35 AM
To: Evangelho, Troy <[email protected]>
Subject: Re: EIR for General Plan
EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Good morning, Troy,
As always, thanks so much for your responses.
The blockage of ocean breeze due to the proposed housing projects and its effect on climate control in Fox Hills was included in the comments as a problem ( Appendix 3). Is that issue addressed anywhere by the ESA in the EIR? I believe that was not covered in the EIR although maybe I missed it.
Again, thanks for all your responses.
Judi
From: Evangelho, Troy <[email protected]>
Sent: Tuesday, April 9, 2024 8:43 AM
To: Fox Hills Neighborhood Associa on <yourfoxhills@ nacc.org > Subject: RE: EIR for General Plan
Hi Judi,
See my responses to your questions below in red.
Troy Evangelho, AICP
Advance Planning Manager
4/23/24, 4:47 PM Mail - Reyes, Oscar - Outlook
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Culver City, Planning and Development
9770 Culver Boulevard, Culver City, CA 90232
(310) 253-5744 /
[email protected]
From: Fox Hills Neighborhood Association <[email protected]> Sent: Monday, April 8, 2024 12:48 PM
To: Evangelho, Troy <[email protected]>
Subject: EIR for General Plan
Importance: Low
EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Good afternoon, Troy,
I hope you had a good weekend and got a chance to see the eclipse today.
Can you please verify that I am interpreting the analysis correctly re: Air Quality and Noise sections of the EIR as follows?
When the report is explaining that there is unavoidable significant impact regarding the air quality and noise , I assume they mean to be addressing the General Plan as it is presently. Is that correct? Yes, the analysis is for the “project”, which is the General Plan as proposed.
Then, when they go on to say that any mitigating strategies would not reduce the significant impact on air quality and noise, I am again assuming they mean that as the GP is now, nothing would really result in any improvement in air quality or noise abatement. Is that correct? Correct, as proposed the project would have potentially significant unavoidable impacts to air quality, noise, transportation, and cultural resources.
Lastly, the section in the Executive Summary regarding "Issues raised during the preparation process and areas of controversy" there is a statement that these issues would be addressed later on. When will that be, if you have any idea of that timeline? I couldn’t find any references to issues 4/23/24, 4:47 PM Mail - Reyes, Oscar - Outlook
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that will be addressed later. This EIR covers a wide range of all environmental factors, including all those required by CEQA.
As always, your feedback is greatly appreciated.
Sincerely,
Judi
Fox Hills Neighborhood Association
Judi Sherman, President
Paula Keating, Treasurer
www.fhnacc.org
[email protected]
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The City of Culver City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act. 4/23/24, 4:47 PM Mail - Reyes, Oscar - Outlook
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The City of Culver City keeps a copy of all E-mails sent and received for a minimum of 2 years. All retained E-mails will be treated as a Public Record per the California Public Records Act, and may be subject to disclosure pursuant to the terms, and subject to the exemptions, of that Act.
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Sequoia Tully <[email protected]>
Sun 5/12/2024 1:03 AM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Some people who received this message don't often get email from [email protected]. Learn why this is important Dear City Council,
I have concerns regarding the General Plan EIR.
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need to account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco- friendly way to cool a unit.
All of the new development is in the west or south west of existing buildings and has a potential of blocking or diverting our current ocean breeze.
This could translate to several degrees of increase of heat for the current residents.
Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. W
e need to know what happens to our ocean
breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”(air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR 5/13/24, 7:39 AM Mail - Reyes, Oscar - Outlook
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should use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will have little af
fect to current residents. South of
Slauson should be no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because of profit. They may add a few affordable housing but not enough.
Also, the city is losing all the leverage to
incentivise the developers to give us more affordable housing. It makes no sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson (65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density. Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Sequoia Tully
Fox Hills resident
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cont.
Concern
Louise Wechsler <[email protected]>
Tue 5/7/2024 10:56 AM
To: Culver City Advance Planning Division <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
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To whom it may concern:
I am a 16 year resident of Fox Hills and condo owner who is opposed to the proposed housing developments planned for our neighborhood. We already have one of the densest housing areas in Culver City. The proposed new housing will only add to our traffic and noise issues. Please reconsider, and move the proposed new housing ( which certainly is needed) to the northern side of Slauson, which lacks residential buildings.
Thank you,
Louise Wechsler
6150 Buckingham Pkwy#301
Culver City 90230
Sent from my iPad
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General Plan EIR
Jeff Willis <[email protected]>
Sun 5/12/2024 9:04 PM
To: McMorrin, Yasmine <[email protected]>; O'Brien, Dan <Dan.O'[email protected]>;Puza, Freddy <[email protected]>;Vera, Albert <[email protected]>; Eriksson, Goran <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]> EXTERNAL: This email originated from outside of the organization. Do not click links or open attachments unless you confirm the content is safe.
Some people who received this message don't often get email from [email protected]. Learn why this is important Dear City Council and City Staff,
This is a response to the General Plan EIR. Here are our concerns:
1. Fox Hills new zoning density is too high. We are already the most dense area in Culver City. The General Plan should cut the density to 50 units/acre, because we need account for the density bonus (doubles the allowed density)
2. Fox Hills current buildings are older and have no capability of adding AC systems. The current cooling system for Fox Hills relies on natural ocean breeze. The most eco-friendly way to cool a unit.
All the new development is west or south west of existing buildings and it has a potential of blocking or diverting our current ocean breeze. This could translate to several degrees of increase of heat for the current residents. Related to this issue is the excess height of the new development which will cause further blocking or diversion. Fox Hills asks to add to the EIR study the ocean breeze effect based on the new General Plan. W
e need to know what happens to our ocean breeze if the entire new mix use zoning is fully developed at 100 unit/acre and another one with 200 units/acre (since this is a possibility w/ the max density bonus). The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here.
3. The EIR shows “Unavoidable Significant Impact”( air quality, noise, transportation).
Question: Is this study accounting for a fully developed new density Fox Hills? Is this study accounting for max density bonus? If not, the city of Culver City MUST do a new study w/ 100 units/acre and 200 units/acre fully developed Fox Hills.
4. The reason we are demanding the 200 units/acre scenario is because the density bonus can not be denied by the city. Is that correct? If this is correct, the worst case scenario is 200 units/acre.
5. Looking at the new density map proposed by the new General Plan, the Fox Hills area is the neighborhood with the largest density proposal than any other area in Culver City.
That gives the Fox Hills resident the right to know what is the consequence of the city’s decision to up our density 300% to 600% from our current density. The entire EIR should 5/13/24, 7:43 AM Mail - Reyes, Oscar - Outlook
https://outlook.office365.com/mail/none/id/AAMkAGQxMzNkOGQ4LWM2YWYtNGI3My1iYmQxLTY0NWRkM2E2N2FlYQBGAAAAAAB5hUOFEsnqQ… 1/2 16-1
use the fully developed Fox Hills with 100 units/acre and 200 units/acre for all the environmental impact, such as air quality, noise, traffic, street parking, ocean breeze, basic infrastructure (sewer, water, electricity,....), city services, schools, etc). In summary, our quality of life.
6. Fox Hills has 2 areas: north of Slauson and south of Slauson. South of Slauson is where the current residents are. We propose that the high density of 100 units/acre be North of Slauson ONLY, where it will be little af
fect to current residents. South of Slauson should be
no more than 50 units/acre, so with the density bonus it could be up to 100 units/acre.
7. Why change the South of Slauson density to 50 units/acre? 100 units/acre gives no incentive for the developers to add affordable housing because they make enough profit.
They may add a few affordable housing but not enough. Also, the city is losing all the leverage to incentivise the developers to give us more af fordable housing. It makes no
sense to make a general plan that caters to what the developer wants. Is the General Plan made for the Culver City residents or for the developers?
8. We asked the top city planning person the reason why we could not switch the high density (100 units/acre) to North of Slauson(65 units/acre proposal) and make south of Slauson 65 units/acre? His answer: because the developers like big lots with high density.
Look at the current 5757 Uplander project. The developers are not using much of the density bonus because they do not need it. They make profit w/ the 100 units/acre.
9. FYI: Keep in mind developers may say that the city will be out of compliance with the state if the density designations are lowered on the south side of Slauson, which is inaccurate, as clarified by the Advance Planning Division when the Fox Hills Neighborhood Association asked about it.
Jeff Willis
Fox Hills Property Owner
Culver City Resident
5/13/24, 7:43 AM Mail - Reyes, Oscar - Outlook
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cont.
General Plan 2045 and Zoning Code Update Project
Draft Environmental Impact Report
State Clearinghouse No. 2022030144
March 2024
PREPARED FOR:
City of Culver City
9770 Culver Boulevard
Culver City, CA 90232
PREPARED BY:
Environmental Science Associates
626 Wilshire Boulevard, Suite 1100
Los Angeles, CA 90017
March 2024
General Plan 2045 and Zoning Code Update Project
Draft Environmental Impact Report
State Clearinghouse No. 2022030144
General Plan 2045 and Zoning Code Update Project i SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
CONTENTS
Draft Program Environmental Impact Report
Page
Executive Summary ................................................................................................................... ES-1 ES.1 Project Location ............................................................................................................. ES-1 ES.2 Proposed Project ........................................................................................................... ES-1 ES.3 Areas of Controversy and Issues to Be Resolved ........................................................... ES-2 ES.4 Significant and Unavoidable Environmental Impacts .................................................... ES-2 ES.5 Summary of Project Alternatives ................................................................................... ES-4 ES.6 Summary of Environmental Impacts ............................................................................. ES-7 Chapter 1, Introduction ............................................................................................................... 1-1
1.1 Purpose of the Draft EIR .................................................................................................. 1-1
1.2 Type of EIR ....................................................................................................................... 1-2
1.3 Intended Uses of the PEIR ............................................................................................... 1-3
1.4 EIR Scoping Process ......................................................................................................... 1-4
1.4.1 Background .......................................................................................................... 1-4
1.4.2 Notice of Preparation .......................................................................................... 1-5
1.4.3 Public Scoping Meeting ....................................................................................... 1-6
1.4.4 Comments Received ............................................................................................ 1-6
1.5 Scope of the PEIR ............................................................................................................. 1-6
1.5.1 Baseline and Planning Horizon ............................................................................ 1-6
1.5.2 Environmental Issue Areas .................................................................................. 1-7
1.6 Format of the Draft PEIR ................................................................................................. 1-8
1.7 Public Review of the Draft PEIR ....................................................................................... 1-9 Chapter 2, Project Description ..................................................................................................... 2-1
2.1 Introduction ..................................................................................................................... 2-1
2.2 Regional Location and Existing Setting ............................................................................ 2-2
2.2.1 Regional Location ................................................................................................ 2-2
2.2.2 Planning Area ....................................................................................................... 2-2
2.2.3 Existing Setting and Land Uses ............................................................................ 2-5
2.3 Purpose and Objectives of the Project ............................................................................ 2-8
2.4 Project Characteristics ................................................................................................... 2-10
2.4.1 General Plan 2045 ............................................................................................. 2-10
2.4.2 Zoning Code Update .......................................................................................... 2-31
2.5 Project Implementation................................................................................................. 2-36
2.5.1 Required Permits and Approvals ....................................................................... 2-36
2.5.2 Decision-Making Agencies ................................................................................. 2-36
2.5.3 Implementation Tools ....................................................................................... 2-36 Contents
General Plan 2045 and Zoning Code Update Project ii SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Chapter 3, Environmental Setting ................................................................................................ 3-1
3.1 Overview of the Environmental Setting .......................................................................... 3-1
3.1.1 Existing Conditions............................................................................................... 3-1
3.1.2 Surrounding Uses ................................................................................................. 3-2
3.2 Adopted General Plan and Zoning ................................................................................... 3-2
3.2.1 Adopted General Plan Land Use Designations .................................................... 3-2
3.2.2 Current Zoning ..................................................................................................... 3-3
3.3 Cumulative Projects ......................................................................................................... 3-3 Chapter 4, Environmental Impact Analysis ................................................................................... 4-1
4.0 Introduction to the Analysis ............................................................................................ 4-1
4.0.1 Introduction ......................................................................................................... 4-1
4.0.2 Format of the Environmental Impact Analysis .................................................... 4-2
4.0.3 Terminology Used in this PEIR ............................................................................. 4-2
4.1 Aesthetics ..................................................................................................................... 4.1-1
4.1.1 Introduction ...................................................................................................... 4.1-1
4.1.2 Environmental Setting ...................................................................................... 4.1-1
4.1.3 Regulatory Framework ..................................................................................... 4.1-4
4.1.4 Project Impact Analysis ..................................................................................... 4.1-9
4.1.5 Cumulative Impact Analysis ............................................................................ 4.1-17
4.2 Air Quality ..................................................................................................................... 4.2-1
4.2.1 Introduction ...................................................................................................... 4.2-1
4.2.2 Environmental Setting ...................................................................................... 4.2-1
4.2.3 Regulatory Framework ................................................................................... 4.2-14
4.2.4 Project Impact Analysis ................................................................................... 4.2-26
4.2.5 Cumulative Impacts Analysis .......................................................................... 4.2-52
4.3 Biological Resources ..................................................................................................... 4.3-1
4.3.1 Introduction ...................................................................................................... 4.3-1
4.3.2 Environmental Setting ...................................................................................... 4.3-1
4.3.3 Regulatory Framework ................................................................................... 4.3-11
4.3.4 Project Impact Analysis ................................................................................... 4.3-16
4.3.5 Cumulative Impacts Analysis .......................................................................... 4.3-29
4.4 Cultural Resources ........................................................................................................ 4.4-1
4.4.1 Introduction ...................................................................................................... 4 .4 -1
4.4.2 Environmental Setting ...................................................................................... 4.4-1
4.4.3 Regulatory Framework ................................................................................... 4.4-11
4.4.4 Project Impact Analysis ................................................................................... 4.4-22
4.4.5 Cumulative Impacts Analysis .......................................................................... 4.4-31
4.5 Energy ........................................................................................................................... 4.5-1
4.5.1 Introduction ...................................................................................................... 4.5-1
4.5.2 Environmental Setting ...................................................................................... 4.5-1
4.5.3 Regulatory Framework ..................................................................................... 4.5-5
4.5.4 Project Impact Analysis ................................................................................... 4.5-17
4.5.5 Cumulative Impacts Analysis .......................................................................... 4.5-36
4.6 Geology and Soils.......................................................................................................... 4.6-1
4.6.1 Introduction ...................................................................................................... 4.6-1
4.6.2 Environmental Setting ...................................................................................... 4.6-1
4.6.3 Regulatory Framework ................................................................................... 4.6-14
4.6.4 Project Impact Analysis ................................................................................... 4.6-24
4.6.5 Cumulative Impacts Analysis .......................................................................... 4.6-42 Contents
General Plan 2045 and Zoning Code Update Project iii SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
4.7 Greenhouse Gas Emissions ........................................................................................... 4.7-1
4.7.1 Introduction ...................................................................................................... 4.7-1
4.7.2 Environmental Setting ...................................................................................... 4.7-1
4.7.3 Regulatory Framework ................................................................................... 4.7-12
4.7.4 Project Impact Analysis ................................................................................... 4.7-37
4.7.5 Cumulative Impacts Analysis .......................................................................... 4.7-73
4.8 Hazards and Hazardous Materials ................................................................................ 4.8-1
4.8.1 Introduction ...................................................................................................... 4.8-1
4.8.2 Environmental Setting ...................................................................................... 4.8-1
4.8.3 Regulatory Framework ................................................................................... 4.8-11
4.8.4 Project Impact Analysis ................................................................................... 4.8-24
4.8.5 Cumulative Impacts Analysis .......................................................................... 4.8-39
4.9 Hydrology and Water Quality ....................................................................................... 4.9-1
4.9.1 Introduction ...................................................................................................... 4.9-1
4.9.2 Environmental Setting ...................................................................................... 4.9-1
4.9.3 Regulatory Framework ................................................................................... 4.9-13
4.9.4 Project Impact Analysis ................................................................................... 4.9-24
4.9.5 Cumulative Impacts Analysis .......................................................................... 4.9-37
4.10 Land Use and Planning ............................................................................................... 4.10-1
4.10.1 Introduction .................................................................................................... 4.10-1
4.10.2 Environmental Setting .................................................................................... 4.10-1
4.10.3 Regulatory Framework ................................................................................... 4.10-8
4.10.4 Project Impact Analysis ................................................................................. 4.10-13
4.10.5 Cumulative Impacts Analysis ........................................................................ 4.10-25
4.11 Mineral Resources ...................................................................................................... 4.11-1
4.11.1 Introduction .................................................................................................... 4.11-1
4.11.2 Environmental Setting .................................................................................... 4.11-1
4.11.3 Regulatory Framework ................................................................................... 4.11-6
4.11.4 Project Impact Analysis ................................................................................... 4.11-8
4.11.5 Cumulative Impacts Analysis ........................................................................ 4.11-11
4.12 Noise ........................................................................................................................... 4.12-1
4.12.1 Introduction .................................................................................................... 4.12-1
4.12.2 Environmental Setting .................................................................................... 4. 12-1
4.12.3 Regulatory Framework ................................................................................... 4.12-7
4.12.4 Existing Noise Environment .......................................................................... 4.12-13
4.12.5 Project Impact Analysis ................................................................................. 4.12-22
4.12.6 Cumulative Impacts Analysis ........................................................................ 4.12-39
4.13 Population and Housing ............................................................................................. 4.13-1
4.13.1 Introduction .................................................................................................... 4.13-1
4.13.2 Environmental Setting .................................................................................... 4.13-1
4.13.3 Regulatory Framework ................................................................................... 4.13-4
4.13.4 Project Impact Analysis ................................................................................... 4.13-9
4.13.5 Cumulative Impacts Analysis ........................................................................ 4.13-17
4.14 Public Services ............................................................................................................ 4.14-1
4.14.1 Introduction .................................................................................................... 4.14-1
4.14.2 Environmental Setting .................................................................................... 4.14-1
4.14.3 Regulatory Framework ................................................................................. 4.14-16
4.14.4 Project Impact Analysis ................................................................................. 4.14-25
4.14.5 Cumulative Impacts Analysis ........................................................................ 4.14-37 Contents
General Plan 2045 and Zoning Code Update Project iv SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
4.15 Recreation .................................................................................................................. 4.15-1
4.15.1 Introduction .................................................................................................... 4.15-1
4.15.2 Environmental Setting .................................................................................... 4.15-1
4.15.3 Regulatory Framework ................................................................................... 4.15-9
4.15.4 Project Impact Analysis ................................................................................. 4.15-11
4.15.5 Cumulative Impacts Analysis ........................................................................ 4.15-18
4.16 Transportation ............................................................................................................ 4.16-1
4.16.1 Introduction .................................................................................................... 4.16-1
4.16.2 Environmental Setting .................................................................................... 4.16-1
4.16.3 Regulatory Framework ................................................................................. 4.16-10
4.16.4 Project Impact Analysis ................................................................................. 4.16-17
4.16.5 Cumulative Impacts Analysis ........................................................................ 4.16-28
4.17 Tribal Cultural Resources ............................................................................................ 4.17-1
4.17.1 Introduction .................................................................................................... 4.17-1
4.17.2 Environmental Setting .................................................................................... 4.17-1
4.17.3 Regulatory Framework ................................................................................... 4.17-3
4.17.4 Project Impact Analysis ................................................................................... 4.17-5
4.17.5 Cumulative Impacts Analysis .......................................................................... 4.17-8
4.18 Utilities and Service Systems ...................................................................................... 4.18-1
4.18.1 Introduction .................................................................................................... 4.18-1
4.18.2 Environmental Setting .................................................................................... 4.18-1
4.18.3 Regulatory Framework ................................................................................. 4.18-15
4.18.4 Project Impact Analysis ................................................................................. 4.18-35
4.18.5 Cumulative Impacts Analysis ........................................................................ 4.18-51
4.19 Wildfire ....................................................................................................................... 4.19-1
4.19.1 Introduction .................................................................................................... 4.19-1
4.19.2 Environmental Setting .................................................................................... 4.19-1
4.19.3 Regulatory Framework ................................................................................... 4.19-6
4.19.4 Project Impact Analysis ................................................................................. 4.19-11
4.19.5 Cumulative Impacts Analysis ........................................................................ 4.19-24 Chapter 5, Alternatives ................................................................................................................ 5-1
5.1 Introduction ..................................................................................................................... 5-1
5.2 Project Objectives ............................................................................................................ 5-2
5.3 Alternatives Considered and Rejected ............................................................................ 5-3
5.3.1 Dispersed Densification Alternative .................................................................... 5-4
5.3.2 Reduced Buildout Alternative .............................................................................. 5-6
5.4 Alternatives Selected for Analysis ................................................................................... 5-7
5.5 Impact Analysis of the Alternatives ................................................................................. 5-8
5.5.1 Alternative 1 – No Project ................................................................................... 5-8
5.5.2 Alternative 2 – Concentrated Growth Alternative ............................................ 5-36
5.5.3 Alternative 3 – Modified Mixed Use High Designation ..................................... 5-64
5.6 Environmentally Superior Alternative ........................................................................... 5-93 Chapter 6, Other CEQA Considerations ........................................................................................ 6-1
6.1 Significant and Unavoidable Impacts .............................................................................. 6-1
6.1.1 Air Quality ............................................................................................................ 6-1
6.1.2 Cultural Resources ............................................................................................... 6-2
6.1.3 Noise .................................................................................................................... 6-2
6.1.4 Transportation ..................................................................................................... 6-2
6.1.5 Water Supply ....................................................................................................... 6-2 Contents
General Plan 2045 and Zoning Code Update Project v SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
6.2 Reasons the Project is Being Proposed Notwithstanding its Significant Unavoidable Impacts ....................................................................................................... 6-3
6.3 Growth-Inducing Impacts ................................................................................................ 6-4
6.3.1 Population and Housing Growth ......................................................................... 6-4
6.3.2 Removal of Obstacles to Population Growth ...................................................... 6-5
6.3.3 Employment Growth ........................................................................................... 6-5
6.3.4 Precedent-Setting Policies ................................................................................... 6-5
6.4 Significant Irreversible Environmental Changes .............................................................. 6-6
6.5 Potential Secondary Effects Related to Project Mitigation Measures ............................ 6-7
6.5.1 Air Quality ............................................................................................................ 6-7
6.5.2 Biological Resources ............................................................................................ 6-7
6.5.3 Cultural Resources ............................................................................................... 6-8
6.5.4 Geology and Soils – Paleontological Resources ................................................... 6-8
6.5.5 Noise .................................................................................................................... 6-9
6.6 Effects Found Not to Be Significant ................................................................................. 6-9
6.6.1 Aesthetics ............................................................................................................ 6-9
6.6.2 Agricultural and Forest Resources ..................................................................... 6-10
6.6.3 Air Quality .......................................................................................................... 6-11
6.6.4 Biological Resources .......................................................................................... 6-11
6.6.5 Cultural Resources ............................................................................................. 6-11
6.6.6 Geology and Soils ............................................................................................... 6-12
6.6.7 Hazards and Hazardous Materials ..................................................................... 6-12
6.6.8 Noise .................................................................................................................. 6-12 Chapter 7, References .................................................................................................................. 7-1 Chapter 8, List of Preparers .......................................................................................................... 8-1
Figures
Figure 2-1 Regional and Project Vicinity .................................................................................... 2-3 Figure 2-2 Planning Area ............................................................................................................ 2-4 Figure 2-3 Planning Area Neighborhoods .................................................................................. 2-6 Figure 2-4 Existing General Plan Land Use Map ........................................................................ 2-7 Figure 2-5 City Structure and Neighborhood Diagram ............................................................ 2-12 Figure 2-6 Draft General Plan Land Use Map .......................................................................... 2-14 Figure 2-7 Roadway Network & Classification Map ................................................................. 2-23 Figure 2-8 Truck Route Network .............................................................................................. 2-24 Figure 2-9 Pedestrian Network ................................................................................................ 2-25 Figure 2-10 Bicycle Network ...................................................................................................... 2-26 Figure 2-11 Transit Network ...................................................................................................... 2-27 Figure 2-12 Emerging Mobility Network .................................................................................... 2-28 Figure 2-13 Planned and Proposed Park and Recreational Facilities ......................................... 2-30 Figure 2-14 Existing Zoning Map ................................................................................................ 2-32 Figure 2-15 Proposed Zoning Map ............................................................................................. 2-34 Figure 4.2-1 SB 1000 Priority Neighborhoods .......................................................................... 4.2-20 Figure 4.3-1 Vegetation Communities and Habitat in Culver City ............................................. 4.3-2 Figure 4.3-2 California Natural Diversity Database Species Occurrences in Culver City ............ 4.3-6 Figure 4.6-1 Soil Types within the Planning Area ...................................................................... 4.6-3 Figure 4.6-2 Regional Earthquake Faults ................................................................................... 4.6-5 Contents
General Plan 2045 and Zoning Code Update Project vi SCH No. 2022030144 City of Culver City March 2024
Preliminary − Subject to Revision
Figure 4.6-3 Alquist-Priolo Fault Zones within the Planning Area ............................................. 4.6-8 Figure 4.6-4 Potential Landslide Zones Within the Planning Area ........................................... 4.6-10 Figure 4.6-5 Potential Liquefaction Zones in the Planning Area .............................................. 4.6-12 Figure 4.8-1 Hazard Sites within the Planning Area ................................................................... 4.8-5 Figure 4.8-2 Primary Evacuation Routes .................................................................................. 4.8-10 Figure 4.9-1 Existing Hydrologic Setting .................................................................................... 4.9-2 Figure 4.9-2 Existing Groundwater Subbasins within the Planning Area ................................... 4.9-7 Figure 4.9-3 Flood Zones in the Planning Area ........................................................................ 4.9-12 Figure 4.10-1 Planning Area ....................................................................................................... 4.10-2 Figure 4.10-2 Planning Area Neighborhoods ............................................................................. 4.10-3 Figure 4.10-3 Existing General Plan Land Use Map ................................................................... 4.10-6 Figure 4.11-1 Mineral Resources Zones (MRZs) within the Planning Area ................................ 4.11-3 Figure 4.11-2 Inglewood Oil Field Context Map ........................................................................ 4.11-5 Figure 4.12-1 Decibel Scale and Common Noise Sources .......................................................... 4.12-3 Figure 4.12-2 Noise Measurement Locations .......................................................................... 4.12-17 Figure 4.12-3 Existing Roadway Noise Contour Map ............................................................... 4.12-21 Figure 4.12-4 Future Roadway Noise Contour Map ................................................................ 4.12-29 Figure 4.14-1 Culver City Fire Department Fire Stations, Facilities, and Service Areas ............. 4.14-3 Figure 4.14-2 Police Stations within the Planning Area ............................................................. 4.14-9 Figure 4.14-3 CCUSD Attendance Areas .................................................................................. 4.14-13 Figure 4.14-4 Government and Civic/Cultural Facilities within the Planning Area .................. 4.14-15 Figure 4.15-1 Existing Parks and Recreational Facilities in the Planning Area ........................... 4.15-4 Figure 4.15-2 Public Access to Existing Parks ............................................................................. 4.15-7 Figure 4.15-3 Proposed Recreation Facilities ........................................................................... 4.15-14 Figure 4.16-1 Existing Roadway Network .................................................................................. 4.16-2 Figure 4.16-2 Existing and Proposed Bicycle Network ............................................................... 4.16-5 Figure 4.16-3 Existing and Proposed Transit Routes ................................................................. 4.16-8 Figure 4.19-1 Wildfire Hazard Severity Zones ............................................................................ 4.19-4 Figure 5-1 Land Use Alternatives Conceptual Comparison........................................................ 5-5
Tables
Table ES-1 Summary of Project Impacts and Mitigation Measures ......................................... ES-8 Table 2-1 Existing General Plan Land Use Designations ........................................................... 2-5 Table 2-2 Proposed General Plan Land Use Designations ...................................................... 2-15 Table 2-3 General Plan 2045 Population, Household, and Job Growth Projections .............. 2-19 Table 2-4 General Plan 2045 Projections by Land Use ........................................................... 2-19 Table 2-5 Special Roadway Classifications .............................................................................. 2-22 Table 2-6 Zoning Code – Uses and Development Standards .................................................. 2-33 Table 4.2-1 Ambient Air Quality Standards .............................................................................. 4.2-2 Table 4.2-2 Air Pollutant Standards and Ambient Air Quality Data – SRA 2 ............................. 4.2-9 Table 4.2-3 Pollutant Standards and Ambient Air Quality Data – SRA 3 ................................ 4.2-10 Table 4.2-4 Pollutant Standards and Ambient Air Quality Data – SRA 1 (for PM2.5) ............. 4.2-11 Table 4.2-5 Estimated Existing Regional Operational Emissions (pounds per day) ................ 4.2-13 Table 4.2-6 South Coast Air Basin Attainment Status (Los Angeles County) .......................... 4.2-15 Table 4.2-7 Estimated Culver City 2045 Regional Operational Emissions (pounds per day) .................................................................................................. 4.2-41 Table 4.3-1 Special-Status Plants in Culver City ........................................................................ 4.3-7 Table 4.3-2 Special-Status Wildlife in Culver City ..................................................................... 4.3-8 Contents