2024-11-11 ATT No. 7 - 5700 Hannum Final and Draft EIR — City Council Meeting Agenda, November 11, 2024 (part 2 of 5)

projects at 5757 Uplander Way and 5730 Uplander Way were NOT included.

These 2 proposed projects, if built, will result in an additional 1396 units in close proximity to the 5700 Hannum Avenue development.

3. Message to City Council: Did you read the EIRs that you are asking us the public to comment? Do you know the change that you are deciding to impose in an entire neighborhood? The minimum that the city council can do is to provide a full well done EIR including all the concerns brought up by the residents. Item 1 above is extremely important to the community. A change of 1 or 2 degrees inside our units in the hot summer without AC, can become lethal for the most vulnerable population. Here is a portion of the EIR, please at least read this part:
"Significant and unavoidable impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the City would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the City considered in approving the project notwithstanding the potential for significant environmental impacts. “ City Council, if your intention is to override our CEQA guidelines (protection that is in place for the public), you must understand and demand all the consequences you are going to impose in Fox Hills.

4. From the EIR "the regional climate within the Air Basin is considered semi-arid and is characterized by warm summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity.”….. We can tell you, we live here, we have great air flow. The construction being higher and a massive structures west and south west of us means less air flow. From EIR "The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. “ This is one more reason to study the air flow (ocean breeze) affect. It can cause of air pollutants not moving away from the neighborhood. Remember, we need the ocean breeze that comes from the west to cool us down and move the air pollutants. We have the 405 and major boulevards and high traffic street all around us. This neighborhood is ok now because we have a well balanced nature help but your construction can upset the balance we have now.

5. We ask for Alternative 1 or Alternative 3 (Reduced project alternative)

6. Lower height for every building. Do not exceed existing building height.

Yumi Mandt-Rauch
Fox Hills Resident

Letter IND 7C

From: Eurana High <[email protected]>
Sent: Monday, May 20, 2024 3:37 PM
To: Culver City Advance Planning Division <[email protected]> Subject: Fox Hills

Dear City council and city staff,
For City Council and city staff:

Currently, not every resident in Fox Hills gets notice of the projects that affect us. This due to the 500 ft rule for notice. Depending on the location, NONE of the residents get notice about the projects. The only way people get to know is thru the advocacy groups that work for the neighborhood. Cemeteries, offices, park, are receiving notices and the residents are NOT. The spirit of the law is not met with 500 ft. We must have at least 2000 ft to make sure everyone affected by the change is notified. Also the notice’s is given for transparency. If the developer is asking for an exemption or exception of a law that protects the public, that should be in the notice. Not the law number, but in words that a common person can understand.

The city must protect the residents and always have the residents BEST interest first!
This is a response to the 5700 Hannum EIR. Here are our concerns:

1. 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 all projects that are happening in Fox Hills. I do not see 5757 Uplander in your study as part of the other projects. There is another one that was not in your list. We need to know what happens to our ocean breeze, i.e. our cooling if you’re building blocks or divert our air flow. The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here. This is the minimum the city can do for the current residents.

2. The EIR shows “Unavoidable Significant Impact”. Question: Why this study did not include the other projects in Fox Hills? One of them is 1106 units (577 Uplander) alone. If not, the city of Culver City MUST do a new study w/ all the current projects.

Not partial list. HOW DO WE KNOW OF THIS INCOMPLETE REPORT ANALYSIS?: Of the 12 related projects listed in the report link below on Page 82/Table 3.1, (See page 81 that states EIR requirement), the proposed projects at 5757 Uplander Way and 5730 Uplander Way were NOT included. These 2 proposed projects, if built, will result in

an additional 1396 units in close proximity to the 5700 Hannum Avenue development.

3. Message to City Council: Did you read the EIRs that you are asking us the public to comment? Do you know the change that you are deciding to impose in an entire neighborhood? The minimum that the city council can do is to provide a full well done EIR including all the concerns brought up by the residents. Item 1 above is extremely important to the community. A change of 1 or 2 degrees inside our units in the hot summer without AC, can become lethal for the most vulnerable population. Here is a portion of the EIR, please at least read this part: "Significant and unavoidable impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the City would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the City considered in approving the project notwithstanding the potential for significant environmental impacts. “ City Council, if your intention is to override our CEQA guidelines (protection that is in place for the public), you must understand and demand all the consequences you are going to impose in Fox Hills.

5. We ask for Alternative 1 or Alternative 3 (Reduced project alternative)

6. Lower height for every building. Do not exceed existing building height.

Eurana High
Fox Hills resident

Letter IND 7D

From: irene french <[email protected]>
Sent: Monday, May 20, 2024 3:16 PM
To: McMorrin, Yasmine <[email protected]>; [email protected] <[email protected]>; Puza, Freddy <[email protected]>; Vera, Albert <[email protected]>; [email protected] <[email protected]>; Culver City Advance Planning Division <[email protected]>; Jones, Stephen <[email protected]>
Subject: Fox hills project

Dear City council and city staff,
For City Council and city staff:

The city must protect the residents and always have the residents BEST interest first!
This is a response to the 5700 Hannum EIR. Here are our concerns:

1. 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 all projects that are happening in Fox Hills. I do not see 5757 Uplander in your study as part of the other projects. There is another one that was not in your list. We need to know what happens to our ocean breeze, i.e. our cooling if you’re building blocks or divert our air flow. The city of Culver City MUST do this study for the Fox Hills residents since the city is changing the density so excessively here. This is the minimum the city can do for the current residents.

2. The EIR shows “Unavoidable Significant Impact”. Question: Why this study did not include the other projects in Fox Hills? One of them is 1106 units (577 Uplander) alone.

If not, the city of Culver City MUST do a new study w/ all the current projects. Not

partial list. HOW DO WE KNOW OF THIS INCOMPLETE REPORT ANALYSIS?: Of the 12 related projects listed in the report link below on Page 82/Table 3.1, (See page 81 that states EIR requirement), the proposed projects at 5757 Uplander Way and 5730 Uplander Way were NOT included. These 2 proposed projects, if built, will result in an additional 1396 units in close proximity to the 5700 Hannum Avenuedevelopment.

3. Message to City Council: Did you read the EIRs that you are asking us the public to comment? Do you know the change that you are deciding to impose in an entire neighborhood? The minimum that the city council can do is to provide a full well done EIR including all the concerns brought up by the residents. Item 1 above is extremely important to the community. A change of 1 or 2 degrees inside our units in the hot summer without AC, can become lethal for the most vulnerable population. Here is a portion of the EIR, please at least read this part: "Significant and unavoidable impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the City would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the City considered in approving the project notwithstanding the potential for significant environmental impacts. “ City Council, if your intention is to override our CEQA guidelines (protection that is in place for the public), you must understand and demand all the consequences you are going to impose in Fox Hills.

5. We ask for Alternative 1 or Alternative 3 (Reduced project alternative)

6. Lower height for every building. Do not exceed existing building height.

Irene French
Fox Hills resident

Letter IND 7E

From: Gabriel Parhoti <[email protected]>
Sent: Monday, May 20, 2024 9:30 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]> Subject: Concern from Fox Hills (Gabriel Parhoti )

Dear City council and city staff,
For City Council and city staff:

The city must protect the residents and always have the residents BEST interest first!
This is a response to the 5700 Hannum EIR. Here are our concerns:

2. The EIR shows “Unavoidable Significant Impact”. Question: Why this study did not include the other projects in Fox Hills? One of them is 1106 units (577 Uplander) alone.

If not, the city of Culver City MUST do a new study w/ all the current projects. Not partial list. HOW DO WE KNOW OF THIS INCOMPLETE REPORT ANALYSIS?: Of the 12 related projects listed in the report link below on Page 82/Table 3.1, (See page 81 that states EIR requirement), the proposed projects at 5757 Uplander Way and 5730 Uplander Way were NOT included. These 2 proposed projects, if built, will result in an additional 1396 units in close proximity to the 5700 Hannum Avenue development.

3. Message to City Council: Did you read the EIRs that you are asking us the public to comment? Do you know the change that you are deciding to impose in an entire neighborhood? The minimum that the city council can do is to provide a full well done EIR including all the concerns brought up by the residents. Item 1 above is extremely important to the community. A change of 1 or 2 degrees inside our units in the hot summer without AC, can become lethal for the most vulnerable population. Here is a portion of the EIR, please at least read this part: "Significant and unavoidable impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the City would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the City considered in approving the project notwithstanding the potential for significant environmental impacts. “ City Council, if your intention is to override our CEQA guidelines (protection that is in place for the public), you must understand and demand all the consequences you are going to impose in Fox Hills.

5. We ask for Alternative 1 or Alternative 3 (Reduced project alternative)

6. Lower height for every building. Do not exceed existing building height.

Gabriel Parhoti
Fox Hills resident

Appendix B
Draft EIR Public Meeting
Materials

PUBLIC MEETING ON THE

DRAFT EIR
5700 Hannum Avenue Mixed-Use
Residential and Commerical Project
April 30, 2024
7:00 p.m. – 8:00 p.m.

PLANNING DIVISION
Draft EIR Meeting Objectives
• Provide information about the 5700 Hanum Avenue Mixed-Use Residential and Commercial Project
• Provide information on the CEQA process
• Identify the environmental topics evaluated in the Draft EIR • Summarize impact findings provided in the Draft EIR
• Provide instructions on how to submit comments on the Draft EIR A
ll written comments received on the Draft EIR will be responded to in writing in the Final EIR.

PLANNING DIVISION
Project Site and Vicinity
• Project Site:
5700 H
annum Avenue in Culver
City, California, 90230
• 2.23-ac res (97,264 square feet)
• Bounded:

H
annum Avenue (North)
Buckingham Parkway (East/SE)
Existing commercial uses (West)
• Primary regional access:

I-405 F
reeway 0.7 mile west

PLANNING DIVISION
Existing Conditions
• Fully Developed
• Existing 30,672 square foot, 2-s tory
office building.
• Surface Parking & On-S ite Landscaping.
• Adjoining sidewalks are landscaped with
s
treet trees.

PLANNING DIVISION
Project Description
• New 6-s tory, mixed -use building over two (2) semi-subterranean levels. • 309 residential units (including 27 Very Low-I ncome units) • 5,600 square feet of retail space.
• Building height
70 f
eet along north property line adjacent to Hannum Avenue 71 feet at the south property line along Buckingham Parkway. • 7,507 square foot publicly accessible open space area (Hannum Plaza). • Two primary driveways:

B
uckingham driveway for residential use
Hannum driveway for resident, retail, delivery uses.
• 428 on-s ite vehicle parking spaces & 92 bicycle parking spaces.

PLANNING DIVISION
Conceptual Site Plan

FIRE LANE/ACCESS ROAD
5700 HANNUM AVE
6 STORY RESIDENTIAL BUILDING WITH GROUND FLOOR COMMERCIAL

PROPERTY LINE
FU==L______J ffi z
rJ4'8' 16' 32'1CD

PLANNING DIVISION
North Elevation
View looking south from Hannum Avenue

NORTH ELEVATION

PLANNING DIVISION
East Elevation
View looking west from Buckingham Parkway

PLANNING DIVISION
California Environmental Quality Act (CEQA)
Purpose of CEQA Review:
• To inform decision-m akers and the public of a project’s potential environmental effects
• Increases public understanding of and participation in environmental review pr
ocess
• Discloses potential impacts on the environment
• Identifies ways to avoid or reduce potential environmental impacts through m
itigation measures or alternatives

PLANNING DIVISION
The EIR Process
Prepare Final EIR Including
Response to Comments
EIR Scoping Meeting
September 12, 2023
Prepare Draft EIR
Public & Agency Review of Draft EIR
(47-day review period ends May 20, 2024)
Public Hearings
Prepare Public Notice of Draft EIR Availability
= We are here in the process
Prepare/Distribute Notice of Preparation
(31-day review period ended September 28, 2023)
File Notice of Determination
= Opportunities for Public Input
e~~ CITY

DIVISION
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
■
•••
*
*
Topics Not Evaluated in the Draft EIR
•Agriculture and Forestry
R
esources
•Biological Resources
•Hazards & Hazardous Materials
•Hydrology and Water Quality
•Mineral Resources
•Utilities and Service Systems
(
Telecommunications,
Wastewater and Solid Waste)
•Wildfire
Topics Found to have no impacts or less than significant impacts in Initial Study

PLANNING DIVISION
Topics Analyzed in the Draft EIR
•Aesthetics
•Air Quality
•Cultural Resources
•Energy
•Geology and Soils ( Paleontological
Resources only)
•Greenhouse Gas Emissions
•Land Use and Planning
•Noise
•Population and Housing
•Public Services
(Fire a
nd Police Protection,
Schools, and Parks/Recreation)
•Transportation
•Tribal Cultural Resources
•Utilities and Service Systems
(W
ater Supply, Electricity and
Natural Gas Facilities)

PLANNING DIVISION
Draft EIR Topics with Less than Significant Impacts
• Aesthetics
• Air Quality (Operation)
• Energy
• Greenhouse Gas Emissions
• Land Use and Planning
• Noise and Vibration
– Operational Noise
– Construction/Operation Vibration
• Population and Housing
• Public Services
(
Fire and Police Protection,
Schools and Parks/Recreation)
• Transportation
• Utilities and Service Systems –
W
ater Supply, Wastewater, Solid
Waste, Electricity and Natural
Gas Facilities

PLANNING DIVISION
Draft EIR Topics with Significant Impacts Requiring Mitigation Measures •Air Quality – Con struction Related Emissions
•Cultural Resources – A rchaeological Resources
•Geology and Soils – P aleontological Resources
•Tribal Cultural Resources
After implementation of Mitigation Measures, impacts for these topics were reduced to less than significant levels:

PLANNING DIVISION
Draft EIR Topics with Significant and Unavoidable Impacts – Construction Related Only
•Noise – On- Site Construction Noise
•Significant and unavoidable impact would occur during the earthwork s
horing/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction only if these construction activities occurred outside of the City’s allowable construction hours and an extended hours construction permit was not obtained.
•However, the construction noise impact would be less than significant i
f an extended hours construction permit is obtained.

After implementation of Mitigation Measures, impacts for these topics were still significant and unavoidable:

PLANNING DIVISION
Draft EIR Availability
The Draft EIR is currently available at the following locations:
• Online at: https://www.culvercity.org/Active-Projects/5700-Hannum-Ave-Proposed-Project • In-per son at: Culver City Current Planning Division counter Current Planning Division Office, City Hall, Second Floor 9770 Culver Boulevard
Culver City, CA 90232-0507
Business hours are 7:30 A.M. – 5:30 P.M., Monday through Friday, except alternate Fridays Telephone in advance to assure staff availability at (310) 253-5710 • In-per
son at: Culver City Julian Dixon Library (see library website for address and hours of operation)

PLANNING DIVISION
Submittal of Public Comments on the Draft EIR
Due date for public comments on
the Draft EIR:
5:30 p.m. on Monday, May 20, 2024
Please direct public comments on
the Draft EIR to:

Jose Mendivil, Associate Planner
City of Culver City Planning Division
9770 Culver Boulevard
Culver City, California 90230
Email: [email protected]
Reference:
5700 Hannum Avenue Mixed-Use
Residential and Commercial Project Draft
EIR
0 PLANNING DIVISION
Public Comment Period
Oral Comments:

Zoom
• Mouse over the bottom of the Zoom
window
• Click “Raise Hand” button
• Wait until moderator calls your name and
unmut
es you
By Phone
• Dial *9 t o raise your hand and *6 to unmute
NOTE: There will be a one minute time limit for oral
comments. After you have had your turn to speak, your hand will be lowered and you will be placed back on mute.
0 ~
'
Chat Raise Hand

PLANNING DIVISION
Submittal of Public Comments on the Draft EIR
Due date for public comments on
the Draft EIR:
5:30 p.m. on Monday, May 20, 2024
Please direct public comments on
the Draft EIR to:

5700 HANNUM MIXED-USE RESIDENTIAL AND

COMMERCIAL PROJECT
Draft Environmental Impact Report
State Clearinghouse No. 2023080709

Prepared for April 2024
City of Culver City
9770 Culver Blvd.

Culver City, CA 90232

Culver City Case Nos:

P2023-0218-CP; -DOBI; -ZCMA; -GPMA; -EIR

r ESA
~

5700 HANNUM MIXED-USE RESIDENTIAL AND

COMMERCIAL PROJECT
Draft Environmental Impact Report
State Clearinghouse No. 2023080709
Prepared for April 2024
City of Culver City
9770 Culver Blvd.

Culver City, CA 90232

Culver City Case Nos:

P2023-0218-CP; -DOBI; -ZCMA; -GPMA; -EIR

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City of Culver City i 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

TABLE OF CONTENTS
5700 Hannum Avenue Mixed-Use Residential
and Commercial Project
Page
Executive Summary ........................................................................................................ ES-1 ES.1 Project Description ....................................................................................... ES-1 ES.2 Issues Raised during Notice of Preparation Process and Areas of Controversy ................................................................................................. ES-2 ES.3 Significant and Unavoidable Environmental Impacts ................................... ES-3 ES.4 Alternatives that Would Reduce or Avoid Significant Impacts ..................... ES-3 ES.4.1 Alternative 1: No Project ............................................................... ES-3 ES.4.2 Alternative 2: Existing Zoning Alternative ..................................... ES-4 ES.4.3 Alternative 3: Reduced Project Alternative ................................... ES-4 ES.4.4 Environmentally Superior Alternative ........................................... ES-5 ES.5 Summary of Environmental Impacts ............................................................ ES-6 ES.5.1 Project Design Features ............................................................. ES-11 ES.5.2 Mitigation Measures ................................................................... ES-17 Chapter 1, Introduction ...................................................................................................... 1-1

1.1 Purpose of the Draft EIR ................................................................................. 1-1

1.2 EIR Scoping Process ...................................................................................... 1-2

1.2.1 Initial Study ...................................................................................... 1-2

1.2.2 Notice of Preparation ....................................................................... 1-3

1.2.3 EIR Scoping Meeting/Community Meeting ...................................... 1-4

1.2.4 Comments Received ....................................................................... 1-4

1.3 Format of the Draft EIR ................................................................................... 1-4

1.4 Public Review of the Draft EIR ........................................................................ 1-6 Chapter 2, Project Description .......................................................................................... 2-1

2.1 Introduction ..................................................................................................... 2-1

2.2 Project Location and Surrounding Uses ......................................................... 2-1

2.3 Existing Conditions ......................................................................................... 2-4

2.4 General Plan Land Use and Zoning ................................................................ 2-5

2.5 Statement of Project Objectives ...................................................................... 2-5

2.6 Description of Proposed Project ..................................................................... 2-6

2.6.1 Project Overview ............................................................................. 2-6

2.6.2 Architectural Design ........................................................................ 2-9

2.6.3 Building Floor Plans and Project Uses .......................................... 2-15

2.6.4 Building Elevations and Sections .................................................. 2-21

2.6.5 Open Space and Landscaping ...................................................... 2-21

2.6.6 Vehicular and Bicycle Access, Circulation, and Parking ................ 2-27

2.6.7 Lighting and Signage ..................................................................... 2-29

2.6.8 Site Security .................................................................................. 2-29 Table of Contents

Page
City of Culver City ii 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

2.6.9 Sustainability Features .................................................................. 2-30

2.6.10 Anticipated Construction Schedule/Activities ................................ 2-30

2.7 Project Design Features ............................................................................... 2-31

2.8 Anticipated Project Approvals ....................................................................... 2-36 Chapter 3, Environmental Setting ..................................................................................... 3-1

3.1 Overview of Environmental Setting ................................................................. 3-1

3.1.1 On-Site Conditions .......................................................................... 3-1

3.1.2 Surrounding Uses ............................................................................ 3-2

3.2 Related Projects ............................................................................................. 3-2 Chapter 4, Environmental Impacts Analysis ................................................................... 4-1

4.0 Environmental Impacts Analysis ..................................................................... 4-1

4.0.1 Introduction...................................................................................... 4-1

4.0.2 Environmental Impact ...................................................................... 4-2

4.0.3 Terminology Used in This EIR ......................................................... 4-3

4.1 Aesthetics .................................................................................................... 4.1-1

4.1.1 Introduction................................................................................... 4.1-1

4.1.2 Environmental Setting .................................................................. 4.1-1

4.1.3 Project Impacts ............................................................................. 4.1-9

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 Project Impacts ........................................................................... 4.2-25

4.3 Cultural Resources – Archaeological Resources ......................................... 4.3-1

4.3.1 Introduction................................................................................... 4.3-1

4.3.2 Environmental Setting .................................................................. 4.3-1

4.3.3 Environmental Impacts ............................................................... 4.3-14

4.4 Energy ......................................................................................................... 4.4-1

4.4.1 Introduction................................................................................... 4.4-1

4.4.2 Environmental Setting .................................................................. 4.4-1

4.4.3 Environmental Impacts ............................................................... 4.4-15

4.5 Geology and Soils – Paleontological Resources ......................................... 4.5-1

4.5.1 Introduction................................................................................... 4.5-1

4.5.2 Environmental Setting .................................................................. 4.5-1

4.5.3 Environmental Impacts ................................................................. 4.5-7

4.6 Greenhouse Gas Emissions ........................................................................ 4.6-1

4.6.1 Introduction................................................................................... 4.6-1

4.6.2 Environmental Setting .................................................................. 4.6-1

4.6.3 Project Impacts ........................................................................... 4.6-37

4.7 Land Use and Planning ............................................................................... 4.7-1

4.7.1 Introduction................................................................................... 4.7-1

4.7.2 Environmental Setting .................................................................. 4.7-1

4.7.3 Environmental Impacts ............................................................... 4.7-10

4.8 Noise ........................................................................................................... 4.8-1

4.8.1 Introduction................................................................................... 4.8-1

4.8.2 Noise and Vibration Basics .......................................................... 4.8-1

4.8.3 Environmental Setting .................................................................. 4.8-7

4.8.4 Existing Conditions ..................................................................... 4.8-13

4.8.5 Environmental Impacts ............................................................... 4.8-20 Table of Contents

Page
City of Culver City iii 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.9 Population and Housing ............................................................................... 4.9-1

4.9.1 Introduction................................................................................... 4.9-1

4.9.2 Environmental Setting .................................................................. 4.9-1

4.9.3 Environmental Impacts ................................................................. 4.9-9

4.10.1 Public Services – Fire Protection ............................................................ 4.10.1-1

4.10.1.1 Introduction.............................................................................. 4.10.1-1

4.10.1.2 Environmental Setting ............................................................. 4.10.1-1

4.10.1.3 Environmental Impacts .......................................................... 4.10.1-12

4.10.2 Public Services – Police Protection ........................................................ 4.10.2-1

4.10.2.1 Introduction.............................................................................. 4.10.2-1

4.10.2.2 Environmental Setting ............................................................. 4.10.2-1

4.10.2.3 Environmental Impacts ............................................................ 4.10.2-5

4.10.3 Public Services – Schools....................................................................... 4.10.3-1

4.10.3.1 Introduction.............................................................................. 4.10.3-1

4.10.3.2 Environmental Setting ............................................................. 4.10.3-1

4.10.3.3 Environmental Impacts ............................................................ 4.10.3-3

4.10.4 Public Services – Parks and Recreation ................................................. 4.10.4-1

4.10.4.1 Introduction.............................................................................. 4.10.4-1

4.10.4.2 Environmental Setting ............................................................. 4.10.4-1

4.10.4.3 Environmental Impacts ............................................................ 4.10.4-7

4.11 Transportation ............................................................................................ 4.11-1

4.11.1 Introduction................................................................................. 4.11-1

4.11.2 Environmental Setting ................................................................ 4.11-1

4.11.3 Environmental Impacts ............................................................. 4.11-13

4.12 Tribal Cultural Resources .......................................................................... 4.12-1

4.12.1 Introduction................................................................................. 4.12-1

4.12.2 Environmental Setting ................................................................ 4.12-1

4.12.3 Project Impacts ........................................................................... 4.12-7

4.13.1 Utilities and Service Systems – Water Supply ........................................ 4.13.1-1

4.13.1.1 Introduction.............................................................................. 4.13.1-1

4.13.1.2 Environmental Setting ............................................................. 4.13.1-1

4.13.1.3 Project Impacts ...................................................................... 4.13.1-14

4.13.2 Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities ................................................................ 4.13.2-1

4.13.2.1 Introduction.............................................................................. 4.13.2-1

4.13.2.2 Environmental Setting ............................................................. 4.13.2-1

4.13.2.3 Environmental Impacts ............................................................ 4.13.2-6 Chapter 5, Alternatives ...................................................................................................... 5-1

5.1 Introduction ..................................................................................................... 5-1

5.2 Objectives of the Project ................................................................................. 5-2

5.3 Overview of Alternatives Selected for Analysis ............................................... 5-3

5.4 Alternatives Considered and Rejected ............................................................ 5-3

5.4.1 Alternative Off-Site Location ............................................................ 5-4

5.4.2 Alternatives to Further Reduce or Avoid Significant Noise Impacts during Construction ............................................................ 5-5

5.5 Analysis Format .............................................................................................. 5-6

5.5.1 Alternative 1: No Project/No Build Alternative ................................. 5-7

5.5.2 Alternative 2: Existing Zoning Alternative ...................................... 5-15

5.5.3 Alternative 3: Reduced Project Alternative .................................... 5-34

5.6 Environmentally Superior Alternative ............................................................ 5-52 Table of Contents

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City of Culver City iv 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Chapter 6, Other CEQA Considerations ........................................................................... 6-1

6.1 Significant Unavoidable Impacts ..................................................................... 6-1

6.2 Reasons Why the Project Is Being Proposed, Notwithstanding Significant Unavoidable Impacts ..................................................................... 6-1

6.3 Irreversible Environmental Changes ............................................................... 6-4

6.4 Growth-Inducing Impacts ................................................................................ 6-6

6.5 Potential Secondary Effects Related to Project Mitigation Measures ............. 6-7

6.5.1 Air Quality ........................................................................................ 6-7

6.5.2 Cultural Resources – Archaeological Resources ............................ 6-8

6.5.3 Geology and Soils – Paleontological Resources ............................. 6-8

6.5.4 Noise ............................................................................................... 6-8

6.5.5 Tribal Cultural Resources ................................................................ 6-8

6.6 Impacts Found Not to Be Significant ............................................................... 6-9 Chapter 7, References ....................................................................................................... 7-1 Chapter 8, List of EIR Preparers and Organizations and Persons Contacted .............. 8-1

8.1 Lead Agency ................................................................................................... 8-1

8.2 Project Applicant ............................................................................................. 8-1

8.3 Environmental Impact Report Preparation ...................................................... 8-1

8.4 Agencies Consulted ........................................................................................ 8-3 Chapter 9, Standard Terms, Acronyms, and Abbreviations ........................................... 9-1

Figures
Figure 2-1 Regional and Project Vicinity Location ....................................................... 2-2 Figure 2-2 Project Location – Aerial Photograph ......................................................... 2-3 Figure 2-3 Conceptual Site Plan .................................................................................. 2-7 Figure 2-4 Conceptual Project Rendering – Hannum Plaza Looking West ............... 2-10 Figure 2-5 Conceptual Project Rendering – Hannum Plaza Looking East ................ 2-11 Figure 2-6 Conceptual Project Rendering – Northeast Corner of Hannum Avenue and Buckingham Parkway ........................................................... 2-12 Figure 2-7 Conceptual Project Rendering – Looking West from Fox Hills Parkette .................................................................................................... 2-13 Figure 2-8 Conceptual Project Rendering – Looking North Along Buckingham Parkway ............................................................................... 2-14 Figure 2-9 Level P1 Plan ........................................................................................... 2-16 Figure 2-10 Level P2 Plan ........................................................................................... 2-17 Figure 2-11 First Floor Plan ......................................................................................... 2-18 Figure 2-12 Second Floor Plan .................................................................................... 2-19 Figure 2-13 Sixth Floor Plan ........................................................................................ 2-20 Figure 2-14 North and West Elevations ....................................................................... 2-22 Figure 2-15 East Elevation .......................................................................................... 2-23 Figure 2-16 South Elevation ........................................................................................ 2-24 Figure 2-17 Building Sections ...................................................................................... 2-25 Figure 3-1 Related Projects Map ................................................................................. 3-5 Figure 4.2-1 SCAQMD General Forecast Areas and Air Monitoring Areas ............... 4.2-20 Figure 4.2-2 MATES Cancer Risk ............................................................................. 4.2-21 Figure 4.2-3 Air Quality Sensitive Receptors ............................................................. 4.2-24 Figure 4.7-1 Project Site and Surrounding Land Use Designations ............................. 4.7-8 Figure 4.7-2 Zoning on the Project Site and in the Surrounding Area ......................... 4.7-9 Table of Contents

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City of Culver City v 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Figure 4.8-1 Decibel Scale and Common Noise Sources ............................................ 4.8-3 Figure 4.8-2 Guidelines for Noise Compatible Land Use ........................................... 4.8-10 Figure 4.8-3 Surrounding Land Uses and Noise Measurement Locations ................ 4.8-16 Figure 4.10.1-1 Culver City Fire Department Stations ................................................. 4.10.1-8 Figure 4.10.4-1 Culver City Parks and Recreational Facilities Located in the Vicinity of the Project Site ................................................................... 4.10.4-6 Figure 4.11-1 Existing Transit Service ....................................................................... 4.11-12 Figure 4.11-2 Existing Bicycle Facilities .................................................................... 4.11-14

Tables
Table ES-1 Summary of Project Impacts, Project Design Features, and Mitigation Measures ................................................................................ ES-7 Table 2-1 Development Program Summary ............................................................... 2-8 Table 2-2 Summary of Project Design Features ....................................................... 2-31 Table 3-1 Related Projects List .................................................................................. 3-4 Table 4.2-1 Ambient Air Quality Standards ................................................................ 4.2-8 Table 4.2-2 South Coast Air Basin Attainment Status (Los Angeles County) ........... 4.2-17 Table 4.2-3 Ambient Air Quality Data ....................................................................... 4.2-19 Table 4.2-4 Estimated Existing Emissions (pounds per day) .................................... 4.2-22 Table 4.2-5 SCAQMD Regional Emissions Thresholds (pounds per day) ............... 4.2-26 Table 4.2-6 Estimated Maximum Unmitigated Regional Construction Emissions (pounds per day) .................................................................. 4.2-44

Table 4.2-7 Estimated Maximum Unmitigated Regional Operational Emissions (pounds per day) .................................................................. 4.2-45

Table 4.2-8 Estimated Maximum Unmitigated Localized Construction Emissions (pounds per day) ................................................................. 4.2-47

Table 4.2-9 Estimated Maximum Localized Operational Emissions – Project (pounds per day) ................................................................................... 4.2-47 Table 4.2-10 Maximum Unmitigated Health Risk Impacts for Off-Site Sensitive and Commercial Receptors ................................................................... 4.2-49 Table 4.2-11 Maximum Mitigated Health Risk Impacts for Off-Site Sensitive Receptors .............................................................................................. 4.2-51 Table 4.2-12 Related Projects within 1,000 Feet of the Project Site ........................... 4.2-52 Table 4.3-1 Previously Recorded Cultural Resources .............................................. 4.3-12 Table 4.4-1 Existing Annual Regional Energy Use ................................................... 4.4-12 Table 4.4-2 Electric Power Mix Delivered to Retail Customers in 2021 .................... 4.4-13 Table 4.4-3 Existing Site Annual Energy Use ........................................................... 4.4-15 Table 4.4-4 Summary of Energy Use During Project Construction ........................... 4.4-20 Table 4.4-5 Summary of Annual Net New Energy Use During Project Operation .............................................................................................. 4.4-22

Table 4.6-1 Estimated Statewide Greenhouse Gas Emissions Reductions in the 2022 Scoping Plan ............................................................................ 4.6-9

Table 4.6-2 Major Climate Legislation and Executive Orders Enacted Since the 2017 Scoping Plan .......................................................................... 4.6-10

Table 4.6-3 Description of Identified GHGs .............................................................. 4.6-29 Table 4.6-4 Atmospheric Lifetimes and GWPs ......................................................... 4.6-30 Table 4.6-5 State of California GHG Emissions ....................................................... 4.6-36 Table 4.6-6 Estimated Existing Project Site GHG Emissions ................................... 4.6-37 Table of Contents

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City of Culver City vi 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Table 4.6-7 Consistency with Applicable SCAG Connect SoCal Actions and Strategies .............................................................................................. 4.6-62 Table 4.6-8 Project Construction GHG Emissions .................................................... 4.6-65 Table 4.6-9 Estimated Annualized Unmitigated Project GHG Emissions ................. 4.6-67 Table 4.7-1 Consistency of the Project with Applicable Goals of Connect SoCal .................................................................................................... 4.7-12

Table 4.7-2 Comparison of the Project to Applicable Policies of the Culver City General Plan .................................................................................. 4.7-17 Table 4.7-3 Comparison of the Project to Applicable Policies of the Culver City Bicycle & Pedestrian Action Plan ................................................... 4.7-25

Table 4.8-1 Construction Vibration Damage Criteria .................................................. 4.8-8 Table 4.8-2 Groundborne Vibration and Groundborne Noise Impact Criteria for General Assessment ......................................................................... 4.8-9

Table 4.8-3 City of Culver City Noise Standards ...................................................... 4.8-12 Table 4.8-4 Summary of Ambient Noise Measurements .......................................... 4.8-17 Table 4.8-5 Predicted Existing Vehicular Traffic Noise Levels ................................. 4.8-19 Table 4.8-6 Construction Equipment Noise Levels ................................................... 4.8-26 Table 4.8-7 Estimated Construction Noise Levels at Existing Off-Site Sensitive Receptors .............................................................................. 4.8-28 Table 4.8-8 Estimated Construction Noise Levels at Commercial Land Uses .......... 4.8-28 Table 4.8-9 Estimate of Off-Site Construction Traffic Noise Levels .......................... 4.8-29 Table 4.8-10 Mechanical Equipment Noise Levels at Noise Sensitive Receptors .............................................................................................. 4.8-31 Table 4.8-11 On-Site Parking Noise Levels at Noise Sensitive Receptors ................. 4.8-32 Table 4.8-12 Loading Areas and Refuse Collection Noise Levels .............................. 4.8-33 Table 4.8-13 Offsite Traffic Noise Impacts – Existing Plus Project Conditions ........... 4.8-33 Table 4.8-14 Offsite Traffic Noise Impacts – Future Plus Project Conditions ............. 4.8-35 Table 4.8-15 Estimated Daytime Outdoor Open Space Noise Levels (Leq) ............... 4.8-37 Table 4.8-16 On-Site Composite Noise Impacts ........................................................ 4.8-39 Table 4.8-17 Operational Noise Levels at Commercial Land Uses ............................ 4.8-39 Table 4.8-18 Estimated Mitigated Construction Noise Levels at Existing Off- Site Sensitive Receptors ....................................................................... 4.8-40 Table 4.8-19 Vibration Source Levels for Construction Equipment ............................ 4.8-41 Table 4.8-20 Related Projects within 1,000 Feet of the Project Site ........................... 4.8-44 Table 4.9-1 Projected Population, Housing, and Employment Estimates ................... 4.9-9 Table 4.9-2 Projected Increases in Population, Housing, and Employment ............. 4.9-11 Table 4.9-3 Projected Population, Housing, and Employment Increases for the City .................................................................................................. 4.9-12 Table 4.9-4 Related Projects Housing, Population and Employment ....................... 4.9-15 Table 4.9-5 Cumulative Population, Housing and Employment Growth For City ........................................................................................................ 4.9-16 Table 4.10.1-1 CCFD Fire Stations Located in the Vicinity of the Project Site ........... 4.10.1-9 Table 4.10.1-2 CCFD Response Times ................................................................... 4.10.1-11 Table 4.10.2-1 Culver City 2022 Crime Statistics ....................................................... 4.10.2-5 Table 4.10.3-1 Enrollment of CCUSD Schools Serving the Project Site .................... 4.10.3-3 Table 4.10.3-2 Estimated Number of Students Generated by the Project .................. 4.10.3-5 Table 4.10.3-3 Cumulative Student Generation ......................................................... 4.10.3-8 Table 4.10.4-1 Culver City Parks and Recreation Master Plan - Park and Open Space Classifications ......................................................................... 4.10.4-3 Table 4.10.4-2 Culver City Parks In a Two-Mile Radius of the Project Site ................ 4.10.4-5 Table of Contents

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City of Culver City vii 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Table 4.11-1 Consistency of the Project with Applicable Policies of the Circulation Element ............................................................................. 4.11-22 Table 4.11-2 Consistency of the Project with Applicable Action of the Culver City Bicycle & Pedestrian Action Plan ................................................. 4.11-24 Table 4.11-3 Consistency of the Project with Applicable Policies of the Complete Streets Policy ...................................................................... 4.11-25 Table 4.13.1-1 Existing Estimated Water Consumption ........................................... 4.13.1-11 Table 4.13.1-2 Project’s Estimated Water Consumption .......................................... 4.13.1-18 Table 4.13.1-3 Projected Normal Year Water Supply and Demand for Culver City Service Area .............................................................................. 4.13.1-18 Table 4.13.1-4 Single Dry Year Water Supply and Demand for Culver City Service Area ..................................................................................... 4.13.1-18

Table 4.13.1-5 Multiple (Five) Consecutive Dry Years Water Supply and Demand through 2045 for Culver City Service Area ......................... 4.13.1-19

Table 4.13.1-6 Estimated Cumulative Water Generation by Related Projects ......... 4.13.1-22 Table 5-1 Overview of the Project Alternatives ........................................................... 5-4 Table 5-2 Alternative 2 Student Generation ............................................................. 5-28 Table 5-3 Alternative 2 Estimated Water Consumption ............................................ 5-32 Table 5-4 Alternative 3 Estimated Water Consumption ............................................ 5-50 Table 5-5 Comparison of Impacts Associated with the Alternatives and the Project ...................................................................................................... 5-53

Table 5-6 Ability of Alternatives to Meet Project Objectives ..................................... 5-57

Appendices
Appendix A Notice of Preparation (NOP), Initial Study, Scoping Meeting Materials, and Comments on the NOP
A-1 Notice of Preparation
A-2 Initial Study
A-3 Scoping Meeting Materials
A-4 Comments on the NOP
Appendix B Shadow Figures
Appendix C Air Quality and Greenhouse Gas Emissions Calculations Appendix D Archeological Resources Report
Appendix E Energy Calculations
Appendix F Paleontological Resources Report
Appendix G Noise Calculations
Appendix H Public Services Correspondence
H-1 Culver City Fire Department Correspondence
H-2 Culver City Police Department Correspondence
H-3 Culver City Unified School District Correspondence
H-4 Culver City Parks, Recreation and Community Services Department Correspondence
Appendix I Transportation Impact Study
Appendix J Water Civil Technical Memorandum
Appendix K Alternatives Documentation

Table of Contents

City of Culver City viii 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

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City of Culver City ES-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

EXECUTIVE SUMMARY

This Draft Environmental Impact Report (Draft EIR) has been prepared pursuant to the requirements of the California Environmental Quality Act (CEQA, Public Resources Code Sections 21000 et. seq.) in accordance with CEQA Guidelines Section 15123. Accordingly, this chapter of the Draft EIR includes (1) a brief description of the Project; (2) issues raised during the Notice of Preparation (NOP) process, including areas of controversy known to the lead agency; (3) identification of potentially significant impacts and proposed mitigation measures or alternatives that would reduce or avoid those impacts; and (4) issues to be resolved, including the choice among alternatives and whether and how to mitigate the potential significant impacts.

ES.1 Project Description
This Draft Environmental Impact Report (EIR) has been prepared for the 5700 Hannum Project (Project). 5700 Hannum Owner, LLC c/o Lincoln Property Company, the Applicant, proposes to develop a mixed-use residential and commercial project on an approximately 2.23 -acre (97,264 square feet [sf]) site (Project Site) located at 5700 Hannum Avenue within the Fox Hills neighborhood of the City of Culver City (City). The Project Site is currently developed with an existing two-story office building in the northern portion of the Project Site and associated surface parking. The Project would develop a new 6-story (up to a height 78-feet) mixed-use building with two (2) semi -subterranean levels, consisting of 309 residential units (including 27 Very Low Income units) and 5,600 square feet of retail space. The Project would provide a total of 7,507 square feet of publicly accessible open space, 19,526 square feet of private open space and 27,123 square feet of common open space (for residents) for a total of 54,156 squar e feet of open space.

The building would be constructed atop two levels of semi -subterranean vehicular parking, with parking also provided on the first floor of the building. The Project would include a total of 428 vehicular parking spaces (399 residential, 6 guest and 23 commercial) within three parking levels.

Two points of vehicular access would be provided to the Project Site, including a residential only driveway along Buckingham Parkway and a commercial and residential driveway along Hannum Avenue. The Project would also provide a total of 92 bicycle spaces, consisting of 11 short -term and 81 long-term bicycle parking spaces in compliance with Culver City Municipal Code (CCMC) requirements. The Project would also include private and publicly accessibl e open space. The Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza fronting Hannum Avenue. Common open space available to residents only would include a centrally located courtyard, a community room on the second floor; a gym, an amenity deck, and a community room on the sixth floor.

The Project is proposing to change the Project Site’s zoning designation from Commercial Regional Business Park to Planned Development (PD) with adoption of a Comprehensive Plan that would serve as the overarching entitlement mechanism for the Project Site. To achieve the Project’s Executive Summary
City of Culver City ES-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
proposed density and mix of uses, a General Plan Amendment Map would be needed to designate the Project Site from Regional Center to General Corridor. The Project is also requesting Density and Other Bonus Incentives (DOBI) to allow for Increased Density with affordable units incorporated into the Project; and approval for Extended Hours of Construction (CCMC Section

9.07.035.C.1). In addition, the Project would require ministerial permits including but not limited to demolition, grading, building, haul route and engineering permits.

ES.2 Issues Raised during Notice of Preparation
Process and Areas of Controversy
The following lists potential environmental issues or concerns raised in response to the NOP circulation, the comment period for which extended from August 29, 2023 through September 28, 2023, and during the virtual Community Meeting and EIR Scoping Meeting held on September 12, 2023. The NOP comments are contained in Appendix A-3 of this Draft EIR. • Concerns regarding the population and allowable housing density on the Project Site (Refer to Chapter 2, Project Description , Section 4.7, Land Use and Planning, and Section 4.9, Population and Housing, of this Draft EIR.)
• Concerns regarding consistency with the Project’s zoning and General Plan land use designations (Refer to Chapter 2, Project Description, and Section 4.7, Land Use and Planning, of this Draft EIR.)
• Concerns regarding aesthetics impacts of the Project, including those related to massing and scale and shading (Refer to Appendix A, Initial Study , which addresses aesthetic impacts and Section 4.1, Aesthetics, of this Draft EIR.)
• Concerns regarding lighting impacts (Refer to Appendix A, Initial Study , of this Draft EIR, which addresses aesthetic impacts associated with lighting.) • Concerns regarding impacts related to air quality and greenhouse gas emissions, including impacts related to human health and carbon emissions (Refer to Section 4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions, of this Draft EIR.) • Concerns regarding energy and capacity of energy related infrastructure to accommodate the Project (Refer to Section 4.4, Energy, and 4.13.2, Utilities and Service Systems - Electric Power, Natural Gas, and Telecommunications Facilities, of this Draft EIR.) • Concerns regarding noise impacts (Refer to Section 4.8, Noise, of this Draft EIR.) • Concerns regarding impacts to public services, such as police, fire schools and parks (Refer to Sections 4.10.1 to 4.10.4, Public Services, of this Draft EIR.) • Concerns regarding transportation, parking and traffic impacts (Refer to Section 4.11, Transportation, of this Draft EIR.)
• Concerns regarding impacts to tribal cultural resources (Refer to Section 4.12, Tribal Cultural Resources, of this Draft EIR.)
• Concerns regarding ability of existing utilities to accommodate the Project, such as water, sewer electric, gas, cable, etc. (Refer to Appendix A, Initial Study , of this Draft EIR, which addresses impacts to utilities, as well as Section 13.1 , Utilities and Service Systems - Water Supply, and 4.13.2, Utilities and Service Systems - Electric Power, Natural Gas, and Telecommunications Facilities, of this Draft EIR.)
Executive Summary
City of Culver City ES-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• Concerns regarding cumulative impacts (Refer to Sections 4.1 to 4.13 of this Draft EIR, all of which address cumulative impacts for each their respective issue areas.) • Identification of alternatives that reduce the Project’s environmental impacts (Refer to Chapter 5, Alternatives, of this Draft EIR)
• Concerns related to biological resources, including impacts to endangered species (Refer to Appendix A, Initial Study, of this Draft EIR, which addresses impact to biological resources.) • Concerns regarding impacts to historical resources (Refer to Appendix A, Initial Study, of this Draft EIR, which addresses cultural resources impacts, including impacts to historic resources.) ES.3 Significant and Unavoidable Environmental
Impacts
CEQA Guidelines Section 15126.2(a) requires that an EIR describe significant environmental impacts of a project on the environment. Direct and indirect significant effects shall be clearly identified and described, giving due consideration to short-term and long-term effects. As evaluated in Section 4. 8, Noise, of this Draft EIR, and summarized below, implementation of the Project would result in significant impacts that cannot be mitigated with respect to Project-level on-site construction noise impacts.

Implementation of Mitigation Measures MM-NOI-1 (Sound Walls) and MM-NOI-2 (Construction Practices) would reduce the Project’s on-site construction noise impacts at the off-site ground-level noise sensitive receptors, to the extent technically feasible. 1 With implementation of Mitigation
Measures MM-NOI-1 and MM-NOI-2, the construction noise levels at all receptor locations would be reduced below the 5-dBA significance threshold. Therefore, with implementation of mitigation measures MM-NOI-1 and MM-NOI-2, impacts from on-site construction noise would be less than significant with approval of an extended hours construction permit. However, construction during off-hours (between 7:00 a.m. and 8:00 a.m. Monday to Friday and 7:00 a.m. to 9:00 a.m. on Saturdays ) during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction would remain significant and unavoidable if an extended hours permit was not obtained by the Project because they would occur outside of the City’s allowable construction hours.

ES.4 Alternatives that Would Reduce or Avoid
Significant Impacts
ES.4.1 Alternative 1: No Project
In accordance with the CEQA Guidelines, the No Project/No Build Alternative (Alternative 1) for a development project on an identifiable property consists of the circumstance under which the project does not proceed. CEQA Guidelines Section 15126.6(e)(3)(B) states that, “in certain instances, Alternative 1 means ‘no build’ wherein the existing environmental setting is

1 Technical infeasibility shall mean that said noise limitations cannot be complied with despite the use of mufflers, shields, sound barriers, and/or other noise reduction devices or techniques during the operation of the equipment.

LAMC Chapter XI, Art. 1, Section 112.05.

Executive Summary
City of Culver City ES-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
maintained.” Accordingly, for purposes of this analysis, Alternative 1 assumes that no new development would occur within the Project Site. As mentioned in Chapter 2, Project Description, of this Draft EIR, the Project Site is currently improved with an approximately 30,672 square foot, two-story office building built in the late 1970s. Under this alternative, the Project Site would continue to operate as an office building under existing conditions.

ES.4.2 Alternative 2: Existing Zoning Alternative
With development under the Existing Zoning Alternative (Alternative 2), the Project Site would be developed in accordance with the existing General Plan Land Use designation of Regional Center and existing zoning designation of Commercial Regional Business Park (CRB) for the Project Site.

It is acknowledged that the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update includes a draft Land Use Map and Land Use designations with appropriate draft densities. The Project Site’s draft land use designation and density is Mixed-Use High and 100 dwelling units per acre, consistent with the City’s adopted 2021-2029 Housing Element preferred designation and density.

Under this Alternative, the existing 30,672 square foot two-story office building built in the 1970s would be replaced with a modern 190,000 square foot, 4-story (56 feet) office building. There would be 380 parking spaces for the office employees and guest parking. The amount and extent of excavation [approximately 51,400 cubic yards and 27 feet below ground surface (bgs)] required for subterranean parking would be generally similar to the Project. This Alternative would provide no retail uses or public open space as compared to the Project.

As with the Project, Alternative 2 would require the demolition of the existing office building and associated paved surface parking areas on the Project Site. Although demolition and excavation would be largely similar to the Project, with an approximate 47 percent reduction in overall building square footage (362,596 sf vs 190,000 sf) proposed under Alternative 2, the overall duration of the building construction phase would be reduced by approximately 50 percent from 17 months to 9 months. Thus, overall construction under Alternative 2 would be approximately 22 months, as opposed to 30 months under the Project.

ES.4.3 Alternative 3: Reduced Project Alternative
Under the Reduced Project Alternative ( Alternative 3) and similar to the Project, the Project Site would be redeveloped under the PD zone with an aesthetically succinct and unified development .

Alternative 3 contemplates a 28 percent reduction in residential units (density) by reducing the Project’s 309 units to 223 units. With this reduction, Alternative 3 would include a total of 222,000 sf of residential square footage, compared to the Project’s 356,996 square feet of residential space. Under Alternative 3, there would be no affordable units provided and as such, the Project’s Density Bonus incentives related to additional units and building height would not be applicable to Alternative 3.

Alternative 3 would include the same 5,600 square feet of retail floor space as the Project. The building height would be 5-stories (over 1-level of subterranean parking) or 56 feet. There would be 312 parking spaces between the 1st floor and P1 level compared to the Project’s 428 spaces. The Executive Summary
City of Culver City ES-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
reduced parking would eliminate one of the Project’s two subterranean parking levels, which would in turn reduce the amount of required soil excavation. Proposed vehicle circulation and loading area locations would be similar under the Project and Alternative 3. Publicly accessible open space on the ground level along Hannum would be reduced from 7,507 square feet under the Project to 2,500 square feet under Alternative 3. The retail space would be provided at the Project’s northeastern corner adjacent to the Hannum Boulevard/Buckingham Parkway intersection. Under Alternative 3, unlike the Project, no residential units would be provided at the Buckingham Parkway street level.

Instead there would be two levels of parking garage exposed along Buckingham Parkway.

As with the Project, Alternative 3 would require the demolition of the existing office building and associated paved surface parking areas on the Project Site. The amount and extent of excavation required for subterranean parking would be less than the Project. Under the Project there would be approximately 51,400 cubic yards of soil excavation reaching approximately 27 feet bgs. Although demolition and excavation would be largely similar to the Project, with an approximate 37 percent reduction in overall building square footage ( 362,593 sf vs 227,600 sf) and removal of one of the subterranean parking levels proposed under Alternative 3, the duration of the Project’s excavation phase would be reduced from 4 months to 2.5 months and the building construction phase would be reduced by approximately 1.5 months from 17 months to 15.5 months. Thus, overall construction under Alternative 3 would be approximately 27 months, as opposed to 30 months under the Project.

ES.4.4 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 Table 5-5, Comparison of the Impacts of the Project and Alternatives, in Chapter 5, Alternatives, of th e Draft EIR. . In addition, Table 5-6, Ability of Alternatives to Meet Project Objectives, is also provided in Chapter 5, Alternatives, of the Draft EIR to show a comparison of the ability of the analyzed alternatives t o meet Project Objectives .

Of the alternatives analyzed in this Draft EIR, Alternative 1, the No Project/No Build Alternative, would be considered the environmentally superior because it would not involve new development and assumes the on -site office use would continue to operate similar to existing conditions.

Alternative 1 would not meet any of the Project Objectives and would avoid all of the Project’s potentially significant impacts and would have less impacts compared to the Project. However, because Alternative 1 has been identified as the environmentally superior alternative, identification of another environmentally superior alternative is required.

Alternative 2, the Existing Zoning Alternative, and Alternative 3, the Reduced Project Alternative, would both involve less development compared to the Project, and both alternatives would reduce, but not eliminate, the Project’s significant unavoidable impacts related to Project-level on-site Executive Summary
City of Culver City ES-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
construction noise. As shown in Table 5-5, Alternative 2 would result in four (4) “greater” impacts [Operational regional emissions, Consumption of Energy Resources, GHG, and Transportation- Vehicle Miles Travelled (VMT)] for the issue areas analyzed compared to the Project, and 16 “less” impacts compared to the Project. Alternative 3 would result in two (2) “greater” impacts (Land Use and Transportation-VMT) for the issue areas analyzed compared to the Project, and 21 “less” impacts compared to the Project. Alternative 3 is considered the environmentally superior alternative, as it would reduce the magnitude of overall impacts compared to the Project to a greater extent than Alternative 2 since it would require less building construction and result in reduced residential occupancy at the Project Site.

However, because Alternative 3 would develop a smaller mixed-use development, the number housing units would be reduced and no affordable units would be provided. As such, Alternative 3 would not meet or meet to a lesser extent than the Project most of the Project Objectives related to:
providing housing, including affordable housing, in accordance with the City’s Regional Housing Needs goals; provision of publicly available open space; and promoting an active, landscaped pedestrian environment.

ES.5 Summary of Environmental Impacts
This section provides a summary of impacts, mitigation measures, and impacts after implementation of the mitigation measures associated with implementation of the Project. The summary is provided by environmental issue area below in Table ES -1, Summary of Project Impacts, Project Design Features and Mitigation Measures. Table ES-1 provides the impact statement for each issue area evaluated in Chapter 4, Environmental Impact Analysis. The summary also includes any Project Design Features (PDFs) and mitigation measures, as applicable.

Executive Summary
City of Culver City ES-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE ES-1

SUMMARY OF PROJECT IMPACTS, PROJECT DESIGN FEATURES, AND MITIGATION MEASURES Environmental Impact Project Design Features (PDF) Mitigation Measures (MM) Project Impact Determination

4.1 Aesthetics
REGULATIONS GOVERNING SCENIC QUALITY See Project Design Feature AES-PDF-1 (Screening of Utilities), below.

None required Less Than Significant

4.2 Air Quality

CONSISTENCY WITH APPLICABLE AIR QUALITY
PLAN
See Project Design Features GHG-PDF-1
(Green Building Features) and TRAF-
PDF-2 (TDM Program), below.

None required Less Than Significant

CUMULATIVELY CONSIDERABLE INCREASE OF CRITERIA POLLUTANTS IN NONATTAINMENT AREA Construction Not applicable None required Less Than Significant Operation Not applicable None required Less Than Significant

SENSITIVE RECEPTOR EXPOSURE TO POLLUTANT CONCENTRATIONS Construction Not applicable See Mitigation Measure AQ-1, below Less Than Significant with Mitigation (Project-level and
Cumulative)
Operation Not applicable None required Less Than Significant

4.3 Cultural Resources
ARCHAEOLOGICAL RESOURCES Not applicable See Mitigation Measures ARCH-1 through ARCH-3, below.

Less Than Significant with
Mitigation (Project-level and
Cumulative)

4.4 Energy

WASTEFUL, INEFFICIENT, AND UNNECESSARY

CONSUMPTION OF ENERGY RESOURCES
See Project Design Features GHG-PDF-1
(Green Building Features) and TRAF-
PDF-2 (TDM Program), below.

None required Less Than Significant

CONFLICT OR OBSTRUCT A STATE OR LOCAL

PLAN FOR RENEWABLE ENERGY OR ENERGY

EFFICIENCY
See Project Design Feature GHG-PDF-1
(Green Building Features), below.

None required Less Than Significant

4.5 Geology and Soils
PALEONTOLOGICAL RESOURCES Not applicable

See Mitigation Measures GEO-1 through
GEO-4, below.

Less Than Significant with
Mitigation (Project-level and
Cumulative)
Executive Summary
City of Culver City ES-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE ES-1

SUMMARY OF PROJECT IMPACTS, PROJECT DESIGN FEATURES, AND MITIGATION MEASURES Environmental Impact Project Design Features (PDF) Mitigation Measures (MM) Project Impact Determination

4.6 Greenhouse Gas Emissions

GHG EMISSIONS/ CONFLICT WITH ANY

APPLICABLE PLAN, POLICY OR REGULATION

ADOPTED FOR THE PURPOSE OF REDUCING THE

EMISSIONS OF GHGS
See Project Design Features GHG-PDF-1
(Green Building Features), and TRAF-
PDF-2 (TDM Program), below.

None required Less Than Significant

4.7 Land Use and Planning

CONFLICT WITH ANY APPLICABLE LAND USE

PLAN, POLICY, OR REGULATION ADOPTED FOR

THE PURPOSE OF AVOIDING OR MITIGATING AN

ENVIRONMENTAL EFFECT
See Project Design Features GHG-PDF-1
(Green Building Features and TRAF-PDF-
2 (TDM Program), below.

None required Less Than Significant

4.8 Noise

SUBSTANTIAL TEMPORARY OR PERMANENT INCREASE IN AMBIENT NOISE LEVELS Construction – On-Site See Project Design Features NOI-PDF-1 (Project Construction Schedule), NOI-
PDF-2 (Use of Impact Pile Driver), and
NOI-PDF-3 (Construction Rules Sign),
below.

See Mitigation Measures NOI-MM-1
(Sound Walls) and NOI-MM-2
9Construction Practices), below.

Significant and Unavoidable
Construction – Off-Site (Mobile Source) NOI-PDF-4 (Neighborhoods Streets), below.

None required Less Than Significant
Operation – On-Site See Project Design Features NOI-PDF-5 (Mechanical Equipment Noise), and NOI-
PDF-6 (Noise Control –Amplified Sound
Systems), below.

None required Less Than Significant
Operation – Off-Site Note Applicable. None required Less Than Significant

VIBRATION
Construction Not applicable None required Less Than Significant Operation Not applicable None required Less Than Significant

4.9 Population and Housing

INDUCE SUBSTANTIAL UNPLANNED POPULATION
GROWTH
Not applicable None required Less Than Significant
Executive Summary
City of Culver City ES-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE ES-1

SUMMARY OF PROJECT IMPACTS, PROJECT DESIGN FEATURES, AND MITIGATION MEASURES Environmental Impact Project Design Features (PDF) Mitigation Measures (MM) Project Impact Determination

4.10.1 Public Services – Fire Protection

FIRE PROTECTION
Construction See Project Design Feature TRAF-PDF-1
(Construction Management Plan), below.

None required Less Than Significant
Operation Not Applicable None required Less Than Significant

4.10.2 Public Services – Police Protection

POLICE PROTECTION
Construction See Project Design Features POL-PDF-1
(Project Site Security and Access During
Construction) and TRAF-PDF-1
(Construction Management Plan), below.

None required Less Than Significant
Operation See Project Design Feature POL-PDF-2
(Project Site Security and Access During
Operation), below.

None required Less Than Significant

4.10.3 Public Services – Schools
SCHOOLS Not applicable None required Less Than Significant

4.10.4 Public Services – Parks and Recreation

PARKS AND RECREATION
Construction Not applicable None required Less Than Significant Operation Not applicable None required Less Than Significant

4.11 Transportation

CONFLICT WITH A PROGRAM, PLAN, ORDINANCE

OR POLICY ADDRESSING THE CIRCULATION

SYSTEM, INCLUDING TRANSIT, ROADWAY,

BICYCLE AND PEDESTRIAN FACILITIES
See Project Design Feature TRAF-PDF-1
(Construction Management Plan), below.

None required Less Than Significant

CONFLICT OR BE INCONSISTENT WITH CEQA
GUIDELINES SECTION 15064.3, SUBDIVISION (B) -

VEHICLE MILES TRAVELED (VMT)
See Project Design Feature TRAF-PDF-2
(TDM Program), below.

None required Less Than Significant
GEOMETRIC HAZARDS Not applicable None required Less Than Significant EMERGENCY ACCESS See Project Design Feature TRAF-PDF-1
(Construction Management Plan), below.

None required Less Than Significant
Executive Summary
City of Culver City ES-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE ES-1

SUMMARY OF PROJECT IMPACTS, PROJECT DESIGN FEATURES, AND MITIGATION MEASURES Environmental Impact Project Design Features (PDF) Mitigation Measures (MM) Project Impact Determination

4.13 Tribal Cultural Resources
TRIBAL CULTURAL RESOURCES Not applicable See Mitigation Measures CUL-MM-2 and TCR-MM-1 through TCR-MM-3, below.

Less Than Significant with
Mitigation

4.13.1 Utilities and Service Systems – Water Supply
WATER INFRASTRUCTURE See Project Design Feature TRAF-PDF-1 (Construction Management Plan), below.

None required Less Than Significant
WATER SUPPLY See Project Design Feature WATER-
PDF-1 (Water Conservation), below.

None required Less Than Significant

4.13.2 Utilities and Service Systems – Electric Power, Natural Gas, and Telecommunications Facilities

ELECTRIC POWER, NATURAL GAS, AND

TELECOMMUNICATIONS INFRASTRUCTURE
Not applicable. None required Less Than Significant
SOURCE: ESA, 2024

Executive Summary
City of Culver City ES-11 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
ES.5.1 Project Design Features
Aesthetics
AES-PDF-1: Screening of Utilities. Mechanical, electrical, and roof top equipment (including Heating, Ventilation, and Air Conditioning [HVAC] systems), as well as building appurtenances (such as rooftop elevator stops), will be integrated into the Project’s architectural design (e.g., placed behind parapet walls) and will be screened from view from public rights-of-way.

Greenhouse Gas Emissions
GHG-PDF-1: Green Building Features. The Project will include the following green building features:
• The Project buildings will be designed to meet the United States Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) Certified performance level or higher and will be designed and operated to meet or exceed the applicable requirements of the State of California Green Building Standards Code and Culver City’s Green Building Program Requirements.
• The Project will include installation of a solar photovoltaic system with 1 kW solar photovoltaic panels per 10,000 sf consistent with CCMC Chapter 15.02.1005 in order to achieve compliance with the City of Culver City’s solar photovoltaic requirement, per the City’s Green Building Ordinance and CALGreen standards.
• The Project will provide EV parking and charging for residential and commercial use. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable.

Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready. Forty -four (44) total spaces (41 residential + 3 commercial) would have EV charging stations. • The Project will include LED lighting throughout the Project Site and would install ENERGY STAR-rated appliances.
• The Project will incorporate efficient water management through low flow faucets and water - efficient landscape design with weather-based controllers and drip irrigation systems. • The Project will utilize only electricity and no natural gas in all land uses except for the retail space.

Noise
NOI-PDF-1: Project Construction Schedule. Prior to issuance of a building permit, notice of the Project construction schedule will be provided to adjacent property owners and occupants.

Evidence of such notification will be provided to the City of Culver City Public Works Department.

The notice will identify the commencement date and proposed timing for all construction phases (demolition, grading, excavation/shoring, foundation, rough frame, plumbing, roofing, mechanical and electrical, and exterior finish).

NOI-PDF-2: Use of Impact Pile Driver. The Project will not require or allow the use of impact pile drivers. Lower noise- and vibration-generating shoring piles to be drilled will be used.

Executive Summary
City of Culver City ES-12 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
NOI-PDF-3: Construction Rules Sign. During all phases of construction, a “Construction Rules Sign” that includes contact names and telephone numbers, with 24-hour availability, of the Applicant, Property Owner, construction contractor(s) will be posted on the Property in a location that is visible to the public. In addition, appropriate staff person at the City of Culver City will be notified for such incidences. These names and telephone numbers will also be made available to adjacent property owners and occupants to the satisfaction of the appropriate department (Planning Manager and/or Building Official) of Culver City.

NOI-PDF-4: Neighborhood Streets. No construction haul trucks, including concrete trucks, will be allowed to travel through neighborhood streets that are primarily residential uses.

NOI-PDF-5: Mechanical Equipment Noise . All building mechanical equipment and/or ventilation systems not fully enclosed will be designed to not exceed sound level limits of the noise level requirements of the City of Culver City General Plan Noise Element Regulation of Stationary Noise Sources through the use of quiet fans, duct silencers, parapets, or similar noise attenuation methods.

NOI-PDF-6: Noise Control – Amplified Sound Systems . If the Project installs permanent outdoor amplified sound systems, the systems will be located in discrete areas of the outdoor common opens space areas courtyard such that the sound would be mostly blocked by the proposed on-site building or walls from of f-site residential receivers. Section 9.07.055(B) of the CCMC prohibits the operation of a loud speaker or sound amplifying equipment for the purposes of transmitting messages, giving instructions or providing entertainment which is audible at a distance of fifty (50) feet or beyond the subject's property line without first filing an application and obtaining a permit as set forth in Chapter 9.07, Noise Regulations, of the CCMC. The systems will at a minimum be designed so as not to result in a perceivable increase at the nearest noise sensitive residential receptor. Specifically, daytime outdoor amplified sound systems will not result in an increase of 5 dBA L
eq over existing ambient noise conditions at the nearest noise sensitive residential receptor. Nighttime speaker noise, if it occurs, will comply with the exterior noise standards identified in the Regulation of Stationary Noise Sources (City of Culver City General Plan Noise Element, approved by City Council July 22, 1996) . A qualified noise consultant will provide written documentation and submitted to appropriate department of City of Culver City that the design of the system(s) complies with the maximum noise levels at the property line of the nearest off-site sensitive receivers.

Police Services
POL-PDF-1 (Project Site Security and Access During Construction): During construction of the Project, the Project Site will be fenced and gated with surveillance cameras to monitor the site during off hours.

POL-PDF-2 (Project Site Security and Access During Operation): During operation of the Project, access to the parking structure will be controlled through gated entries, and the entry areas will be well illuminated. Project Site security would include controlled keycard access to office spaces, security lighting within common areas and entryways, and closed-circuit TV monitoring (CCTV).

Executive Summary
City of Culver City ES-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Transportation
TRAF-PDF-1: Construction Management Plan. A Final Construction Management Plan (FCMP) will be prepared by the Project contractor in consultation with the Project's traffic and/or civil engineer. The FCMP will define the scope and scheduling of construction activities covering the entire Project Site as well as the Applicant's proposed construction site management responsibilities in order to ensure that disturbance of nearby land uses or interruption of pedestrian, vehicle, bicycle and public transit are minimized to the extent feasible. The FCMP will be subject to review and approval by appropriate building officials, city traffic engineers, civil engineers, and planning manager for the City of Culver City, as required, prior to issuance of any Project demolition, grading or excavation permit. The FCMP will also be reviewed and approved by the respective fire and police departments.

Prior to commencement of construction, the contractor will advise the City’s public works inspector and building inspector (inspectors) of the construction schedule. As -needed construction management meetings shall be convened with appropriate Culver City staff and representatives of surrounding developments that may have overlapping construction schedules with the Project, to ensure that concurrent construction projects are managed in collaboration with one another. The FCMP will consider potential project construction disruptions to transportation facilities near the Project Site and provide effective strategies to limit the Project’s use of the public right-of -way (streets and sidewalks) during peak traffic periods and will be subject to adjustment by City staff as deemed necessary and appropriate to preserve the general public safety and welfare.

Prior to approval of the FCMP and grading permits, the Applicant will conduct one (1) community meeting pursuant to the notification requirements of the City of Culver City community meeting guidelines, to discuss and provide the following information to the surrounding community:

1. Construction schedule and hours.

2. Framework for construction phases.

3. Identify traffic diversion plan by phase and activity.

4. Potential location of construction parking and office trailers.

5. Truck hauling routes and material deliveries (i.e., identify the potential routes and restrictions.

Discuss the types and number of trucks anticipated and for what construction activity).

6. Emergency access plan.

7. Demolition plan.

8. Staging plan for the concrete pours, material loading and removal.

9. Crane location(s).

10. Accessible Applicant and contractor contacts during construction activity and during off hours (relevant email address and phone numbers).

11. Community notification procedures.

Executive Summary
City of Culver City ES-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
The FCMP will at a minimum include the following:

1. The name and telephone number of a contact person who can be reached 24 hours a day via telephone regarding construction or construction traffic complaints or emergency situations.

2. An up-to-date list of local police, fire, and emergency response organizations and procedures for the coordination of construction activity, potential delays, and any alerts related to unanticipated road conditions or delays, with local police, fire, and emergency response agencies. Maps showing access to and within the site and to adjacent properties will be provided.

3. Construction plans and procedures to address community concerns the City of Culver City personnel notification of key construction activities; temporary construction fencing and maintenance of construction areas within public view; noise and vibration controls; dust management and control; and worker education on required mitigation measures included in the Project’s Mitigation Monitoring Program and best practices to reduce disturbances to adjacent and nearby land uses.

4. Procedures for the training and certification of flag persons.

5. To the extent known, identification of the location, times, and estimated duration of any roadway closures; procedures for traffic detours, pedestrian protection, reducing effects on public transit and alternate transportation modes; and plans for use of protective devices, warning signs, and staging or queuing areas.

6. The location of temporary power, portable toilet and trash and materials storage locations.

7. The timing and duration of any street, sidewalk and/or lane closures will be approved in advance by ethe City of Culver City. As traffic lane, parking lane, and/or sidewalk closures are anticipated, worksite traffic control plan(s), approved by the City of Culver City, will be developed and implemented to route vehicular traffic, bicyclists, and pedestrians around any such closures. As applicable at the time of construction, such notices will be made available in digital format for posting on each City w ebsite and distribution via email alerts on electronic platforms such as the County of Los Angeles’ "Gov Delivery" system. The FCMP will be updated weekly during the duration of project construction, as determined necessary by the City. The FCMP will require that review and approval of any proposed lane closures include coordination with the Culver City Fire and Police Departments to minimize potential effects on traffic flow and emergency response.

8. Provisions that staging of construction equipment and materials will be accommodated within the Project Site and that construction worker parking will be accommodated on the Project Site and/or at off-site locations to be determined and disclosed, potentially with shuttles to and from the Project Site.

TRAF-PDF-2: Transportation Demand Management (TDM) Program. The Project will implement TDM measures that include, but are not limited to, those listed below subject to Culver City Transportation Department review and approval prior to issuance of the first Temporary Certificate of Occupancy (TCO) for the Project in order to reduce drive-alone vehicle trips to/from the Project Site by residents, visitors and employees, as well peak hour traffic. The TDM strategies necessary comply with the TDM and trip reduction requirements of City Municipal Code Section

07.05.015, as well as City’s design requirements for the Project:

Executive Summary
City of Culver City ES-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
On-Site Enhancements - The Project design will incorporate mobility features to encourage alternative transportation modes. The features will be designed in accordance with the City Municipal Code requirements and standards.
• Pedestrian Connections. The Project will p rovide exclusive pedestrian access separate from vehicular driveways. The Project will provide internal walkways that connect the pedestrian access points to off-site pedestrian facilities, rideshare, and transit. • Bicycle Parking and Amenities. The Project wil l provide both short-term and long-term bicycle parking spaces on-site in accordance with the City Municipal Code requirements. Short -term bicycle parking, which will include bicycle racks, will be located near the pedestrian entrance.

Long-term bicycle parking, which will include bicycle lockers or secure bicycle enclosures, will be placed in an accessible weather protected location.

Electric Vehicle (EV) Parking. In
accordance with City Municipal Code Section 17.320.035.O.3, at least 40% of the onsite parking supply wi ll have EV capability, including EV Capable spaces (20%), EV Ready spaces (10%), and Full EV Charger/Charging Stations (10%).

Off-Site Enhancements - T he Project will improve and contribute toward improvements to off - site mobility facilities to encourage alternative transportation modes. • Mobility Fees. I n accordance with City Municipal Code Section 05.06.015, the Project will be subject to contributing its fair share toward funding the City's mobility infrastructure and improvement projects intended to reduce VMT and support housing and job growth. Pursuant to Resolution No. 2021-R055, the total mobility fee for the Project will be based on a rate of $3,394 per multi-family unit and $14.92 per sf of commercial space.

Other TDM Strategies - T
he Project will implement TDM strategies to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The following details the minimum TDM strategies necessary to comply with the TDM and trip reduction requirements of City Mun icipal Code Section 07.05.015, as well as City’s design requirements for the Project:
• Transportation Information Center (TIC). The Project will provide a TIC, a commuter information center where residents, employees, and visitors can obtain information regarding commute programs and individuals can obtain real -time information for planning travel without using an automobile. A TIC provides information about transit schedules, commute planning, rideshare, telecommuting, bicycle routes and facilities, and facilities and resources for carpoolers, vanpoolers, bicyclists, transit riders, and pedestrians. The TIC can be provided via a bulletin board, display case, or kiosk, as well as virtually, providing every resident, employee, and visitor access to commuter information through a website portal. • Bicycle Parking and Amenities. The Project will support bicycling to work through the provision of bike storage facilities throughout the Project site. Bicycle parking will be provided in accordance with the City Municipal Code requirements for the Project and will include short- term facilities (e.g., bicycle racks) and secure long-term bicycle parking (e.g., fully enclosed rooms or bicycle lockers that protect the bicycle from inclement weather and accessible only to the owner).

• Pedestrian-Friendly Environment . The Project is designed to be pedestrian -friendly and accessible to the local neighborhood. The Project’s pedestrian access points will be located separate from vehicular access points. To promote walkability within and around the Project Executive Summary
City of Culver City ES-16 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
site, internal pedestrian pathways will provide a safe and direct connection to external public pedestrian facilities. Safety measures will also be implemented at the Project driveway to ensure safe crossings to limit potential vehicular-pedestrian conflicts. • E mployee Parking. At least 10% of employee parking will be reserved, as signed on the spaces, for use by potential carpool or vanpool vehicles and located as close as practical to employee entrances. This preferential parking will be identified on the site plan accompanyi ng the application for a building permit. Vanpool spaces will have a minimum parking space dimension of nine feet wide by 18 feet in length and provide a minimum interior vertical clearance of eight feet two inches. A safe and convenient zo ne in which vanpool and carpool vehicles may deliver or board their passengers will also be provided. • Bus Stop Improvements. If deemed necessary by the City, bus stop improvements will be provided to the satisfaction of the City Director of Transportation.

Plan/Program Management - T he Project will take appropriate measures to help future residents and employees manage each TM Plan element and maximize program participation through consolidation of information and proactive engagement. The following will be provided as part of the TDM Plan:
• Project Transportation Coordinator. A Transportation Coordinator will be designated for the site and will be responsible for implementing, coordinating, and maintaining the elements of the TDM Plan. The identity and contact information for the Transportation Coordinator will be supplied to the City and kept current.
• Transportation Information Packet for New Residents and Employees .

Each new resident and
employee will receive an information packet summarizing the transit and transportation alternatives available to Project tenants. The packet will emphasize the location of the TIC and include the contact information of the Transportation Coordinator.

Mobility Hub Support and Alternative Transportation - Th e Project will incorporate measures
and design elements to support first -mile/last-mile service connection for transit users and reduce reliance on personal automobiles. The following will be provided as part of the TDM Plan:
• Bike Repair Station. The Project will provide an on-si te bike parking station for use by Project residents and employees that has a space and basic tool set for bike repairs. • Subsidized Shared- Ride/Uber/Lift Service. Employees who arrive to work via a means other than a single -passenger vehicle or utilize the carpool matching service will automatically be registered in a Subsidized Shared -Ride/Uber/Lift Service by which, upon request to the Transportation Coordinator, the employee will be given a voucher to travel home or Uber/Lyft (or similar shared ride service) in case of illness or emergency. The Project will provide up to $750 in total for this program every year. The subsidy will be for two years after Certificate of Occupancy over a two-year period.
• Transit Passes. The Project will provide up to $500 per pass per year of subsidies for up to five Transit Access Passes (TAP) cards for a period of three years for employees who opt to take Metro instead of personal vehicles and will not be provided on-site parking acco mmodations and not receive a car share subsidy.

Executive Summary
City of Culver City ES-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Utilities and Service Systems – Water Supply
WATER-PDF-1: Water Conservation. The Project will implement water conservation measures that include, but are not limited to, the following:
• Landscape and Irrigation
– California Friendly® plants or native plants
– Drip/ Subsurface Irrigation (Micro-Irrigation)
– Proper Hydro-zoning/Zoned Irrigation (groups plants with similar water requirements together) ES.5.2 Mitigation Measures
Air Quality
AQ-1: Construction Equipment. The Applicant shall implement the following requirements for construction equipment operating at each Project site. These requirements shall be included in applicable bid documents and contractor(s) must demonstrate the ability to supply such equipment.

Construction equipment shall include the following:
• The Project shall utilize off-road diesel-powered construction equipment that meets or exceeds the California Air Resources Board (CARB) and United States Environmental Protection Agency (USEPA) Tier 4 Final off-road emissions standards or equivalent for equipment rated at 25 horsepower (hp) or greater during Project construction where available within the Air Basin. Such equipment shall be outfitted with Best Available Control Technology (BACT) which means a CARB certified Level 3 Diesel Particulate Filter or equivalent. A copy of each unit’s certified tier specification, BACT documentation, and CARB or Southern California Air Quality Management District (SCAQMD) operating permit at the time of mobilization of each applicable unit of equipment shall be provided.
• Use electrified tower cranes in place of diesel-fueled equipment.

Cultural Resources
ARCH-1: Prior to the issuance of a demolition permit, the Applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archaeology (Qualified Archaeologist) to oversee an archaeological monitor who shall be present during initial Project construction work such as site demolition (e.g., building footings/foundations, subsurface utilities, surface parking lots, sidewalks, etc.), clearing/grubbing, grading, trenching, or related moving of soils wit hin the Project Site (collectively, ground disturbing activities); provided, however, that ground disturbing activities shall not include any moving of soils after they have been initially disturbed or displaced by Project -related construction. The Qualified Archaeologist shall determine the frequency of monitoring based on the rate of excavation and grading activities, proximity to known archaeological resources, the materials being excavated (younger alluvium vs. older alluvium), and the depth of excavation, and if found, the abundance and type of archaeological resources encountered. The frequency of monitoring can be reduced to part -time inspections or ceased entirely if determined appropriate by the Qualified Archaeologist.

Prior to commencement of excavation activities, an Archaeological and Cultural Resources Sensitivity Training shall be given for construction personnel. The training session shall be carried Executive Summary
City of Culver City ES-18 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
out by the Qualified Archaeologist and shall focus on how to identify archaeological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event.

ARCH-2: In the event that historic or prehistoric archaeological resources (e.g., bottles, foundations, refuse dumps, etc.) are unearthed, ground-disturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluated. After consulting with the Applicant, the Qualified Archeologist shall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety considerations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where construction activities shall not be allowed to continue. Work within the buffer area shall only be allowed to continue after the evaluation and recovery efforts are completed. Work shall be allowed to continue outside of the buffer area.

All archaeological resources unearthed by Project construction activities shall be evaluated by the Qualified Archaeologist. If the Qualified Archaeologist determines the find to constitute a “historical resource” pursuant to CEQA Guidelines Section 15064.5(a) or a “unique archaeological resource” pursuant to Public Resources Code Section 21083.2(g), the Qualified Archaeologist shall coordinate with the Applicant and the City of Culver City (City) to develop a formal treatment plan that would serve to reduce impacts to the resources and that provides for or the adequate recovery of the scientifically consequential information contained in the resources along with subsequent laboratory processing, analysis, evaluation, and reporting. The treatment plan establ ished for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and Public Resources Code Sections 21083.2(b) for unique archaeological resources. The treatment plan shall include measures regarding the curation of the recovered resources that may include curation at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the resources, they may be donated to a local school or historical society in the area (such as the Culver City Historical Society) for educational purposes.

ARCH-3: The Qualified Archaeologist shall prepare a final report and appropriate California Department of Parks and Recreation Site Forms at the conclusion of archaeological monitoring.

The report shall include a description of resources unearthed, if any, treatment of the resources, results of the artifact processing, analysis, and research, and evaluation of the resources with respect to the California Register of Historical Resources and CEQA. The report and the Site Forms shall be submitted by the Applicant to the City, the South Central Coastal Information Center, and representatives of other appropriate or concerned agencies to signify the satisfactory completion of the Project and required mitigation measures.

Geology and Soils
GEO-1: Prior to the issuance of grading permits, the Applicant shall retain a Qualified Paleontologist meeting the Society of Vertebrate Paleontology (SVP) Standards. The Qualified Paleontologist shall provide technical and compliance oversight of all work as i t relates to paleontological resources, shall attend the Project kick-off meeting, and shall be responsible for Executive Summary
City of Culver City ES-19 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
monitoring and overseeing paleontological monitors (meeting SVP standards) that will observe grading and excavation activities.

GEO-2: Paleontological monitoring shall be conducted during construction excavations into undisturbed older alluvial sediments and undisturbed Baldwin Hills Paleosol. Monitoring shall consist of visually inspecting fresh exposures of rock for larger fossil rema ins and, where appropriate, collecting and wet screening sediment samples of promising horizons for smaller fossil remains. If significant vertebrate fossils are found by screening, it will be necessary to collect a 6,000-pound sample for screening from each producing geologic unit, per SVP Guidelines (2010).

The sample(s) can be collected by construction machinery and stockpiled and processed in a safe location on site, or transported to another site for processing. The frequency of monitoring inspections shall be determined by the Qualified Paleontologist and shall be based on the rate of excavation and grading activities, the materials being excavated, and the depth of excavation, and if found, the abundance and type of fossils encountered. Full -time monitoring can be reduced to part-time inspections, or ceased entirely, if determined adequate by the Qualified Paleontologist. If a potential fossil is found, the Qualified Paleontologist and the monitor shall have authority to temporarily stop excavatio n activity or to temporarily divert or redirect grading and excavation activities in the area of the exposed fossil to facilitate evaluation of the discovery. An appropriate buffer area shall be established by the Qualified Paleontologist around the find where construction activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area. At the Qualified Paleontologist’s discretion, and to reduce any construction delay, the grading and excavation contractor shall assist in removing rock/sediment samples for initial processing and evaluation. If preservation in place is not feasible, the Qualified Paleontologist shall implement a paleontological salvage program to remove the resources from their location.

GEO-3: If the older Quaternary alluvium produces any mollusk fossils, a specimen shall be submitted for radiocarbon dating. If the Fox Hills Paleosol produces any pedogenic calcium carbonate, a sample shall be submitted for radiocarbon dating.

GEO-4: Any significant fossils recovered during Project -related excavations shall be prepared to the point of identification. The residue form sediment samples shall be dried and sorted with a binocular dissecting microscope. Both macrofossils and vertebrate microfossils shall be prepared to the point of identification, identified, and curated into an accredited repository. The Qualified Paleontologist shall prepare a final report summarizing the results of the monitoring and salvaging efforts, the methodology used in these efforts, as well as a description of the fossils collected and their significance. The report shall accompany the specimens to the accredited repository. The report shall also be submitted by the Applicant to the City of Culver City to signify the satisfactory completion of the Project and required mitigation measures.

Noise
MM-NOI-1: Temporary noise barriers shall be installed along the southern and eastern Project boundary to shield the sensitive receptors from construction noise. The barrier shall have a minimum height of 6 to 15 feet (from south to north, with the top of the barrier at least 15 feet above the ground surface of the residences to the east along Buckingham Parkway) that is made of Executive Summary
City of Culver City ES-20 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
sound blanket, plywood or other solid material capable of reducing on-site construction noise levels by 17 to 19 dBA.

MM-NOI-2: Since construction equipment operates intermittently, and the types of equipment change with the stage of construction, noise emitted during construction would be mobile and highly variable. The following features shall be implemented during Project construction to reduce noise levels:
• Maintain all construction tools and equipment in good operating order according to manufacturers’ specifications.
• To the extent practicable, schedule construction activity during normal working hours between 8 a.m. and 5 p.m. on weekdays when higher sound levels are typically present and are found acceptable.
• Equip internal combustion engines with properly operating mufflers that are free from rust, holes, and leaks.
• For construction equipment that utilize internal combustion engines, ensure the engine’s housing doors are kept closed, and install noise -insulating material mounted on the engine housing consistent with manufacturers’ guidelines, if possible.

Tribal Cultural Resources
TCR-MM-1: Prior to the issuance of a demolition permit for the Project, the Applicant shall retain a Native American Monitor from the Gabrieliño Band of Mission Indians – Kizh Nation (Kizh Nation or Tribe). The Native American Monitor shall be present during the following construction activities that have the potential for encountering tribal cultural resources: demolition, pavement removal, clearing/grubbing, drilling/augering, potholing, grading, trenching, excavation, tree removal or other ground disturbing activity associated with the Project, whether on the Project Site or in connection with Project off -site improvements (collectively “ground disturbing activities”).

Notwithstanding the foregoing, Native American monitoring shall not be required for any moving of soils that have been monitored or observed prior to their disturbance and subsequently disturbed or displaced by Project-related construction. The Applicant shall prepare a monitoring agreement with the Kizh Nation that outlines the roles and responsibilities of the Native American Monitor and shall submit this agreement to the City of Culver City (City) prior to the issuance of demolition permit for the Project.

Prior to commencement ground disturbing activities, a Tribal Cultural Resources Sensitivity Training session shall be held for those construction personnel who will be directly involved in the ground disturbing activities. The training session shall be car ried out by the Native American Monitor and shall focus on how to identify tribal cultural resources that may be encountered during ground disturbing activities and the procedures to be followed in such an event. If the Native American Monitor is not present at the Project Site on any given workday, the ground disturbing activities may continue if the workers involved in such activities attended the training session.

Full-time monitoring may be reduced to part -time inspections, or ceased entirely, if determined appropriate by the Native American Monitor in the event there appears to be little to no potential Executive Summary
City of Culver City ES-21 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
for impacting tribal cultural resources. Native American monitoring shall conclude no later than conclusion of ground disturbing activities.

TCR-MM-2: The Native American Monitor shall complete daily monitoring logs that provide descriptions of the relevant ground-disturbing activities, the type of construction activities performed, locations of ground-disturbing activities, soil types, cultural-related materials, and any other facts, conditions, materials, or discoveries of significance to the Tribe. Monitor logs shall identify and describe any discovered tribal cultural resources, including but not limited to, Native American cultural and historical artifacts, remains, places of significance, etc., as well as any discovered Native American (ancestral) human remains and burial goods. Copies of monitor logs shall be provided to the Applicant and the City upon written request to the Tribe. The Applicant shall not be deemed to be out of compliance with this measure if the Native American Monitor fails to complete or submit any such monitoring logs.

TCR-MM-3: In the event of a discovery of potential tribal cultural resources at the Project Site, the Qualified Archaeologist identified in Mitigation Measure CUL-MM-1 (after consultation with the Native American Monitor) shall have the authority to temporarily divert, redirect, or halt ground-disturbance activities to allow identification, evaluation, and potential recovery of such potential resources. After consulting with the Native American Monitor and the Applicant, the Qualified Archaeologist shall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safety considerations for those making an evaluation and potential recovery of the disc overy.

This buffer area shall be established around the find where ground-disturbing activities shall not be allowed to continue. Work shall be allowed to continue outside of the buffer area.

Within three (3) business days of such discovery, a meeting shall take place between the Applicant, the Qualified Archaeologist, the Tribe, and the City to discuss the significance of the find and whether it qualifies as a tribal cultural resource pursuant to Public Resources Code Section 21074(a). If, as a result of the meeting and after consultation with the Tribe, the Applicant, and the Qualified Archaeologist, the City determines, based on substantial evidence, that the resource is in fact a tribal cultural resource, the Qualified Archaeologist shall develop a reasonable and feasible treatment plan, with input from the Tribe as necessary, and with the concurrence of the City’s Planning Director. The treatment measures in the treatment plan shall be in compliance with any applicable federal, State, or local laws, rules or regulations. The treatment plan shall also include measures regarding the curation of the recovered resources.

If the Applicant does not accept a particular recommendation determined to be reasonable and feasible by the Qualified Archaeologist (including, but not limited to, the size of the buffer set forth above), the Applicant, or its successor, may request mediation by a mediator agreed to by the Applicant and the City. The mediator must have the requisite professional qualifications and experience to mediate such a dispute. The City shall make the determination as to whether the mediator is at least minimally qualified to mediate the dispute. After making a reasonable effort to mediate this particular dispute, the City may: (1) require the recommendation be implemented as originally proposed by the Archaeologist; (2) require the recommendation, as modified by the City, be implemented as it is at least as equally effective to mitigate a potentially significant impact; (3) Executive Summary
City of Culver City ES-22 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
require a substitute recommendation be implemented that is at least as equally effective to mitigate a potentially significant impact to a tribal cultural resource; or (4) not require the recommendation be implemented because it is not necessary to mitigat e any significant impacts to tribal cultural resources. The Applicant shall pay all costs and fees associated with the mediator.

The Applicant may recommence ground disturbance activities inside of the specified radius of the discovery site only after it has complied with all of the recommendations developed and approved pursuant to the process set forth in the above paragraphs.

The recovered Native American resources may be placed in the custody of the Tribe, who may choose to use them for their educational purposes or they may be curated at a public, non- profit institution with a research interest in the materials. If neither the Tribe nor an institution accepts the resources, they may be donated to a local school or historical society in the area for educational purposes.

Notwithstanding the above paragraph, any information determined to be confidential in nature by the City Attorney’s office, shall be excluded from submission to the SCCIC or the general public under the applicable provisions of the California Public Records Act, California Public Resources Code Section 6254(r).

City of Culver City 1-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 1
Introduction
This Draft Environmental Impact Report (EIR) has been prepared for t he 5700 Hannum Project (Project). 5700 Hannum Owner, LLC c/o Lincoln Property Company, the Applicant, proposes to develop a mixed-use residential and commercial project on an approximately 2.23-acre ( 97,264 square feet [sf]) s ite (Project Site) located at 5700 Hannum Avenue within the Fox Hills neighborhood of the City of Culver City (City). The Project Site is currently developed with an existing two-story office building in the northern portion of the Project Site and associated surface parking. The Project would develop a mixed-use building consisting of a new 6-story (up to a height 78-feet) structure above two (2) semi subterranean levels; 309 residential units (including 27 Very Low-Income units) and 5,600 square feet of ground floor retail space. The Project would provide 7,507 square feet of publicly accessible open space, 19,526 square feet of private open space, and 27,123 square feet of common open space (for residents) for a total of 54,156 square feet of open space. The Project would include a total of 428 vehicular parking spaces (399 residential, six (6) guest and 23 commercial) within three parking levels. Two points of vehicular access would be provided to the Project Site, including a residential only driveway along Buckingham Parkway and a commercial and residential driveway along Hannum Avenue. The Project would also provide a total of 92 bicycle spaces, consisting of 11 short -term and 81 long-term bicycle parking spaces in compliance with Culver City Municipal Code (CCMC) requirements . The Project is proposing to change the Project Site’s zoning designation to Planned Development (PD) with adoption of a Comprehensive Plan that would serve as the overarching entitlement mechanism for the Project Site. To achieve the Project’s proposed density and mix of uses, a General Plan Amendment Map would be needed to designate the Project Site as General Corridor.

1.1 P urpose of the Draft EIR
The purpose of this Draft EIR is to inform decision-makers and the general public of the potential environmental impacts resulting from the Project. The City is the Lead Agency under the California Environmental Quality Act (CEQA) responsible for preparing this Draft EIR. This Draft EIR has been prepared in conformance with CEQA (California Public Resources Code [PRC] Section 21000 et seq.), and the CEQA Guidelines (California Code of Regulations [CCR], Title 14, Section 15000 et seq.). The principal CEQA G uidelines sections governing content of this document are Sections 15120 through 15132 (Contents of an EIR), and Section 15161 (Project EIR).

The City is responsible for processing and approving the Project pursuant to CEQA Statute Section 21067. The City will consider the information in this Draft EIR, along with other information that may be presented during the CEQA process, including but not limited to the Initial Study and a Final EIR. The EIR will be used in connection with other permits and approvals necessary for the

1. Introduction

City of Culver City 1-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
construction and operation of the Project. The EIR will be used by the City ’s Current Planning Division, Building Safety Division, Public Works Department, and any other responsible public agencies that must approve activities undertaken with respect to the Project.

In accordance with CEQA Guidelines Section 15121, this Draft EIR is an informational document that will inform public agency decision -makers and the public generally of the environmental effects associated with the Project, and ways to minimize significant environmental effects through mitigation measures or reasonable alternatives to the Project. For some effects, significant environmental impacts cannot be mitigated to a level considered less than significant; in such cases, impacts are considered significant and unavoidable. In accordance with CEQA Guidelines Section 15093(b), if a public agency approves a project that has significant impacts that are not substantially mitigated (i.e., significant unavoidable impacts where impacts 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 EIR and any other information in the public record for the project. This is known as a “statement of overriding considerations.”
This Draft EIR analyzes the environmental effects of the Project to the degree of specificity appropriate to the activities proposed by the Project, as required under CEQA Guidelines Section 15146. This analysis considers the activities associated with the Project, to determine the short - term and long-term effects associated with their implementation. This Draft EIR discusses both the direct and indirect impacts of this Project, as well as the cumulative impacts associated with other past, present, and reasonably foreseeable future projects in the vicinity . CEQA requires the preparation of an objective, full disclosure document to inform agency decision -makers and the general public of the direct and indirect environmental effects of the proposed Project, including mitigation measures and reasonable alternatives that can reduce or eliminate any identified significant adverse impacts.

1.2 EIR Scoping Process
In compliance with the State CEQA Guidelines, the City has taken steps to provide opportunities to participate in the environmental review process. In association with preparation of the Draft EIR, efforts were made to contact various State, regional, and local government agencies and other interested parties to solicit comments and inform the public of the Project. As further described below, this included the distribution of an Initial Study and Notice of Preparation (NOP) of an Environmental Impact Report and EIR Scoping Meeting.

1.2.1 Initial Study
In accordance with CEQA Guidelines Section 15063(a), the City prepared an Initial Study to identify potential environmental impacts. The Initial Study determined that the Project had the potential to result in significant impacts associated with a number of environmental issues. As a result, the Initial Study led to a determination that a Draft EIR should be prepared to address those issues where the Project could result in significant environmental impacts, and to consider feasible mitigation measures and alternatives to the Project.

1. Introduction

City of Culver City 1-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
The Draft EIR focuses primarily on changes in the environment that would result from the Project, individually and cumulatively with other development projects. The Draft EIR identifies potentially significant direct and indirect impacts resulting from construction and operation of the Project and provides mitigation measures to reduce or avoid such effects. Based on public input and the results of the Initial Study, this Draft EIR addresses environmental effects in the following areas:
• Aesthetics
• Air Quality
• Cultural Resources
– Archaeological Resources only
• Energy
• Geology and Soils
– Paleontological Resources only
• Greenhouse Gas Emissions
• Land Use and Planning
• Noise
• Population and Housing
• Public Services
– Fire Protection
– Police Protection
– Schools
– Parks
• Transportation
• Tribal Cultural Resources
• Utilities and Service Systems
Based on the Initial Study, issues for which no significant impacts are anticipated to occur are discussed briefly as a part of Chapter 6, Other CEQA Considerations, of this Draft EIR. The analyses supporting these determinations are provided in the Initial Study included as Appendix A-2 of this Draft EIR.

1.2.2 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 30-day review period commencing August 29, 2023 and ending September 29, 2023. The purpose of the NOP was to formally notice that the City was preparing a Draft EIR for the Project, and to solicit input regarding the scope and content of the environmental information to be included in the Draft EIR. See Appendix A-1 of this Draft EIR for a copy of the NOP.

1. Introduction

City of Culver City 1-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

1.2.3 EIR Scoping Meeting/Community Meeting
The NOP included notification that a virtual Community Meeting and an EIR Scoping Meeting would be held. Consistent with City policy, but independent of the CEQA process, the purpose of the Community Meeting was for the Applicant to present the Project, solicit community comments, and receive feedback in association with the entitlement applications submitted to the City. In accordance with the CEQA Guidelines, the purpose of the EIR Scoping Meeting was for the City to solicit input and written comments from agencies and the public on environmental issues or alternatives they believe should be addressed in the Draft EIR. The virtual Community Meeting and EIR Scoping Meeting was held on September 12, 2023, at 7:00 P.M. The EIR Scoping Meeting was held in an online format using zoom and provided interested individuals, groups, and public agencies the opportunity to view materials and ask questions regarding the scope and focus of the Draft EIR as described in the NOP and Initial Study. The presentation materials from the EIR Scoping Meeting are provided in Appendix A-3 of this Draft EIR.

1.2.4 Comments Received
During the public review period for the NOP, 10 commenters submitted responses to the NOP .

Correspondence was received from the California Air Resources Board’s (CARB), California Department of Transportation (Caltrans), County of Los Angeles Department of Public Works, the Native American Heritage Commission (NAHC), interested organizations, and interested parties.

All written comments are provided in Appendix A -4, of this Draft EIR and summarized in the Executive Summary.

1.3 Format of the Draft EIR
The Draft EIR includes an Executive Summary, nine chapters, and appendices, which are organized as follows:

Executive Summary. This chapter of the Draft EIR provides an overview of the entire document in a concise, summarized format. It briefly describes the Project (location and key Project features), the CEQA review process and focus, identifies effects found to be significant and unavoidable, identifies areas of controversy, provides a summary of the Project alternatives (descriptions and conclusions regarding comparative impacts), and provides a summary of Project impacts, Project Design Features and mitigation measures, and the level of impact significance following implementation of mitigation measures.

1. Introduction. This chapter provides a summary of the Project, describes the purpose of the EIR, including CEQA compliance requirements, steps undertaken to date regarding implementation of the CEQA process, and also summarizes the Draft EIR’s organization.

2. Project Description. This chapter describes the location, background and existing conditions, Project objectives, physical and operational characteristics of the Project , and requested entitlements.

1. Introduction

City of Culver City 1-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

3. Environmental Setting. This chapter presents an overview of the Project’s environmental setting, including on-site and surrounding land uses. This section also provides a list and the mapped locations of past, present, and probable future related projects considered in the analysis of potential Project contributions to cumulative impacts.

4. Environmental Impact Analysis. This chapter contains the environmental setting, regulatory framework, methodology, thresholds to determine level of significance, Project Characteristics and/or Project Design Features, Project-specific and cumulative impact analyses, mitigation measures, and conclusions regarding the level of significance after mitigation for each of the following environmental issues: 1) Aesthetics; 2 ) Air Quality; 3 ) Cultural Resources – Archaeological Resources; 4) Energy; 5) Geology and Soils – Paleontological Resources; 6) Greenhouse Gas Emissions; 7) Land Use and Planning; 8) Noise; 9) Population and Housing; 10) Public Services – Fire Protection, Polic e Protection , Schools, Recreation ; 11) Transportation; 12) Tribal Cultural Resources; and 13) Utilities and Service Systems.

5. Alternatives. This chapter describes a reasonable range of alternatives to the Project, including the (1) No Project/No Build Alternative, (2) Existing Zoning/Office Alternative; and (3) Reduced Density Alternative. This chapter also evaluates the environmental effects of the alternatives for each issue area analyzed in the Draft EIR, though not at the same level of detail as analyzed for the Project.

6. Other CEQA Considerations. This chapter includes a discussion of issues required by CEQA that are not covered in other chapters. This includes irreversible environmental changes, significant unavoidable impacts, reasons why the Project is being proposed notwithstanding significant unavoidable impacts, growth-inducing impacts, potential secondary effects related to Project mitigation measures , effects found not to be significant in the Initial Study, and effects found to be less than significant in the Draft EIR (before mitigation).

7. References. This chapter lists the references and sources used in the preparation of this Draft EIR.

8. List of EIR Preparers and Organizations and Persons Contacted. This chapter lists the persons, public agencies, and organizations that were consulted or who contributed to the preparation of this Draft EIR.

9. Standard Terms, Acronyms and Abbreviations. This chapter provides a reference listing of the common terms , acronyms and abbreviations that are used throughout this document, as well as definitions of key terms.

The Environmental Analyses in this Draft EIR are supported by the following appendices:
• Appendix A – Notice of Preparation (NOP), Initial Study, Scoping Meeting Materials, and Comments on the NOP
– A-1 Notice of Preparation
– A-2 Initial Study
– A-3 Scoping Meeting Materials
– A-4 Comments on the NOP

1. Introduction

City of Culver City 1-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• Appendix B – Shadow Figures
• Appendix C – Air Quality and Greenhouse Gas Emissions Calculations • Appendix D – Archeological Resources Report
• Appendix E – Energy Calculations
• Appendix F – Paleontological Resources Report
• Appendix G – Noise Calculations
• Appendix H – Public Services Correspondence
– H-1 Culver City Fire Department Correspondence
– H-2 Culver City Police Department Correspondence
– H-3 Culver City Unified School District Correspondence – H-4 Culver City Parks, Recreation and Community Services Department Correspondence • Appendix I – Transportation Impact Study
• Appendix J – Water Civil Technical Memorandum
• Appendix K – Alternatives Documentation

1.4 Public Review of the Draft EIR
The Draft EIR is subject to a 45- day review period in which the document is made available to responsible and trustee agencies and interested parties. In compliance with the provision of CEQA Guidelines Sections 15085(a) and 15087, 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 City’s Planning Division website: https://www.culvercity.org/Active-Projects/5700-Hannum-Ave-Proposed-Project; (5) sent a NOA to all property owners within 500 feet of the Project Site; (6) sent a 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 (7) filed the NOA with the County Clerk.

Proof of publication is available at the Culver City Current Planning Division. The public review period commenced on April 4, 2024 and will end on May 20, 2023 for a total of 47 days.

Any public agency or members of the public desiring to comment on the Draft EIR must submit their comments in writing or send them via email to the following address prior to the end of the public review period:

Mail: Jose Mendivil
Associate Planner
City of Culver City Current Planning Division
9770 Culver Boulevard
Culver City, California 90232
Email: [email protected]

1. Introduction

City of Culver City 1-7 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Upon the close of the public review period, the City will proceed to evaluate and prepare responses to all relevant oral and written comments received from public agencies and other interested parties during the public review period. A Final EIR will then be prepared. The Final EIR will consist of the Draft EIR, any necessary revisions to the Draft EIR, comments submitted by responsible agencies or reviewing parties during the public circulation period for the Draft EIR, and City responses to those comments. After the Final EIR is completed and at least 10 days prior to its certification by the City Planning Commission
1, responses to comments made by public agencies
on the Draft EIR will be provided to the commenting agencies.

1 Prior to approval of the Project, the City, as Lead Agency and decision-making entity, is required to certify that the Final EIR has been completed in compliance with CEQA, that the Project has been reviewed and the information in the Final EIR has been considered, and that the Final EIR reflects the independent judgement of the City.

1. Introduction

City of Culver City 1-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

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City of Culver City 2-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 2
Project Description

2.1 Introduction
5700 Hannum Owner, LLC c/o Lincoln Property Company, the Applicant, proposes to develop a mixed-use residential and commercial project on an approximately 2.23-acre (97,264 square feet [sf]) site (Project Site) located at 5700 Hannum Avenue within the Fox Hills neighborhood of the City of Culver City (City). The Project Site is currently developed with an existing two-story office building in the northern portion of the Project Site and associated surface parking. The Project would develop a new 6- story (up to a height 78-feet) mixed-use building with two ( 2) semi- subterranean levels, consisting of 309 residential units (including 27 Very Low Income units) and 5,600 square feet of retail space. The Project would provide a total of 7,507 square feet of publicly accessible open space, 19,526 square feet of private open space and 27,123 square feet of common open space (for residents) for a total of 54,156 square feet of open space. The building would be constructed atop two levels of semi-subterranean vehicular parking, with parking also provided on the first floor of the building. The Project would include a total of 428 vehicular par king spaces (399 residential, 6 guest and 23 commercial) within three parking levels. Two points of vehicular access would be provided to the Project Site, including a residential only driveway along Buckingham Parkway and a commercial and residential driveway along Hannum Avenue. The Project would also provide a total of 92 bicycle spaces, consisting of 11 short -term and 81 long- term bicycle parking spaces in compliance with Culver City Municipal Code (CCMC) requirements. The Project would also include private and publicly accessible open space . The Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza fronting Hannum Avenue. Common open space would be available to residents including a centrally located courtyard, a community room on the second floor; a gym, an amenity deck, and a community room on the sixth floor.

2.2 Project Location and Surrounding Uses
The Project Site is located at 5700 Hannum Avenue in the southeastern portion of the City with regional access provided by the San Diego Freeway (1 -405) located approximately 0.7 mile west of the Project Site. Local access to the Project Site is provided via Hannum Avenue, Buckingham Parkway, and Uplander Way. The Project Site is located 0.6 mile east of the Culver City Transit Center and is not in one of the City’s four key Transit Priority Areas (TPA) identified in the City’s July 13, 2020 Transportation Study Criteria and Guidelines. See Figure 2-1, Regional and Project Vicinity Location, for the location of the Project Site. See Figure 2-2 , Project Location – Aerial Photograph, for an aerial image of the Project Site and surrounding development.

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2. Project Description

City of Culver City 2-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
The area surrounding the Project Site is developed primarily with office, business park and residential uses. Land uses located adjacent to the Project Site include: a parking lot and an office building to the north (across Hannum Avenue), a business park building and a surface parking lot to the west, multi-family residential uses to the south/southeast (across Buckingham Parkway), and the Fox Hills Parkette to the east across Buckingham Parkway. The surrounding areas to the north of the Project Site acros s Hannum Avenue and west and south of the Project Site (east side of Buckingham Parkway) have a General Plan land use designation of Commercial - Regional Center.

The multi-family uses across Buckingham Parkway to the east of the Project Site are designated by the General Plan for Planned Residential Development use, while the Fox Hills Parkette has an Open Space land use designation.

2.3 Existing Conditions
The Project Site is currently occupied by an approximately 30,672 square foot two-story office building built in the late 1970s . The remainder of the Project Site includes surface parking and associated landscaping. The sidewalks adjoining the Project Site to the north, east, and south are landscaped with street trees and trees are scattered throughout the existing surface parking lot. The office building and surface parking uses are on relatively flat graded land, however, Buckingham Parkway slopes downward from north to south, with the northernmost elevation (at its intersection with Hannum Avenue) at approximately 128 feet and the southernmost elevation (near Windsor Way) at approximately 103 feet. Thus, the topographical street elevation decreases by approximately 25 feet from north to south. A landscaped slope at varying widths up to approximately 50-feet wide and heights up approximately 17 feet high traverses along the Project Site’s eastern edge along Buckingham Parkway.

Existing vehicle access to the Project Site is provided via two ingress and egress points, which are located along Hannum Avenue and Uplander Way. Hannum Avenue, an east -west roadway adjacent to the Project Site, abuts the northern boundary of the Project Site and includes bicycle lanes in both directions. Uplander Way to the east of the Project Site is separated from the Project Site by an intervening business park property but provides access to the Project Site via a driveway easement to the Project Site ’s surface parking area. Buckingham Parkway abuts the eastern and southeastern boundary of the Project Site (due to the curved nature of Buckingham Parkway) and contains limited curbside parking but does not currently provide direct access to the Project Site.

Existing on-site surface parking includes 109 regular parking spaces and two handicapped parking spaces for a total of 111 parking spaces.

In addition to the existing building and a ssoci
ated surface parking, there is a mix of ornamental
landscaping on the Project Site. There are 119 trees on the Project Site including carrotwood, Canary Island Pine, Brazilian pepper, olive, weeping bottlebrush, paperbark, and podocarpus. In addition, there are 14 carrotwood street trees along Buckingham Parkway adjacent to the Project Site.

2. Project Description

City of Culver City 2-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

2.4 General Plan Land Use and Zoning
The General Plan Land Use designation for the Project Site is Regional Center, which allows large- scale commercial uses and is intended to support existing and anticipated regional -serving commercial developments. The Regional Center land use designation does not support residential and/or residential mixed-use projects. Per the Culver City Zoning Code (Zoning Code), the Project Site is zoned Commercial Regional Business Park (CRB). The CRB Zoning District identifies areas appropriate for large-scale office and business park developments with shared parking, including specific light industrial uses and does not permit residential uses. The City adopted a 2021-2029 Housing Element on January 24, 2022. Pursuant to the adopted Housing Element, the Property’s preferred land use designation is Mixed-Use High, which would allow for high-density residential uses including mixed-use developments. The 2022 Housing Element’s preferred Mixed-Use High designation permits a residential density of 100 dwelling units per acre. In addition, the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update, includes the draft Land Use Map and Land Use designations with appropriate draft densities. The Project Site’s draft land use designation and density is Mixed -Use High and 100 dwelling units per acre, consistent with the Housing Element preferred designation and density.

The Project is proposing to change the Project Site’s zoning designation to Planned Development (PD) with adoption of a Comprehensive Plan that would create zoning and development standards for the Project Site. Per the Zoning Code, a Comprehensive Plan is appropriate for large-scale development as it allows flexibility in the application of zoning code standards to encourage innovation in site planning and design and to support more effective responses to the settings of such properties and other environmental considerations.
1 To permit this, a Comprehensive Plan regulates
permitted uses, development standards, and permit requirements for a Project Site. To achieve the Project’s proposed density and mix of uses, a General Plan Map Amendment would be needed to designate the Project Site as General Corridor. More units than permitted under the Housing Element preferred and draft Land Use density are propo sed. The Applicant proposes a Density and Other Bonus Incentives density increase in return for reservation of a certain number of units as affordable for very low to moderate income households for a period of 55 year s. The Project’s unit count is consistent with the recently-adopted October 2021-2029 Housing Element’s preferred Mixed-Use High Designation, the Draft General Plan 2045 update, and state density bonus law.

2.5 Statement of Project Objectives
Section 15124(b) of the CEQA Guidelines states that a project description shall contain “a statement of the objectives sought by the proposed project,” and further states that “the statement of objectives should include the underlying purpose of the project.” The underlying purpose of the Project is to redevelop the underutilized Project Site with a high - quality mixed-use development that includes new multi -family housing at varying income levels, and retail uses, as well as publicly accessible open spaces, to revitalize the Project Site, promote

1 City of Culver City Zoning Code, Title 17, Section 17.560, Comprehensive Plans, https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-56855#JD_CHAPTER17.560.

Accessed April 2023.

2. Project Description

City of Culver City 2-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
walkability, and enhance the City’s economic base. As further required by the CEQA Guidelines, the specific objectives of the Project are provided below:

1. Develop new, high -quality infill housing with a diverse mix of residential dwelling types, containing both market-rate and affordable units.

2. Fulfill the City’s housing goals by improving access to quality housing for all members of the community through the provision of affordable housing in proximity to open space and public transportation, while maintaining access to a wide range of services and goods.

3. Provide open space amenities that will enhance existing site conditions through publicly accessible open space (Hannum Plaza), as well as a unified landscape design with common open space areas for Project residents.

4. Provide for a mix of commercial and residential uses to promote pedestrian activity, reduce vehicle trips and vehicle miles traveled, and encourage active transportation while maintaining appropriate levels of vehicle parking.

5. Activate the Hannum Avenue and Buckingham Parkway frontages by providing street-oriented retail and residential uses , and a landscaping program that further enhances the pedestrian experience.

6. Utilize the state’s Density Bonus laws to increase the permitted density at the Project Site in order to provide housing at a variety of income levels that will assist the City in meeting its Regional Housing Needs goals.

7. Provide a development that complements and improves the visual character of the area by connecting with the surrounding urban environment through a high level of architectural design, including a building form with vertical and horizontal breaks, generous setbacks, light materiality, landscape features, and active ground floor uses with open space amenities.

8. Create a development with high quality design that supports environmental sustainability through energy efficiency, water conservation, and the reduction of greenhouse gas emissions through such features as electric vehicle charging stations, energy -efficient appliances, water efficient plumbing fixtures and fittings, and water-efficient landscaping.

2.6 Description of Proposed Project

2.6.1 Pro ject Overview
The Project would involve demolition of approximately 30,672 sf of existing surface parking and two-story office building on the Project Site to support the new mixed-use development. As shown in Figure 2-3, Conceptual Site Plan, the Project would consist of six stories of development over two semi-subterranean levels for vehicular parking and building infrastructure. The proposed six- story building would be a maximum of 78 feet in height due to the existing site topography. The Project’s 356,996 square feet of residential floor area plus the 5,600 square feet of commercial floor area, which equates to a floor area ratio (FAR) of 3.73:1.

As shown in Table 2-1, Development Program Summary, and as further detailed below, the Project includes 356,996 sf of residential uses (including the residential lobby and community rooms) with 309 residential apartment units (including 27 Very Low Income units); 5,600 sf of commercial uses; three levels of vehicular parking (428 spaces), including two semi -subterranean levels; and public and private open space areas.
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-3
Conceptual Site Plan
SOURCE: KFA, 2024D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\Project Description\Illustrator - PROPERTY LINE
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2. Project Description

City of Culver City 2-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-1

DEVELOPMENT PROGRAM SUMMARY
Use Size/Units
Site Area (sf/ac) 97,264 sf/2.23 ac
Existing
Office Use 30,672 sf
Proposed
Residential Component
Studios 39 units
1-Bedrooms 180 units
2-Bedrooms 90 units
Residential Lobby 5,169 sf
Subtotal Residential Units and Square Footage 309 units (356,996 sf) Commercial Component
Retail 5,600 sf
Subtotal Commercial Square Footage 5,600 sf
Total Residential and Commercial Square Footage 362,596 sf Parking Floor Area 165,843 sf
Parking
Residential Parking 405 spaces
Commercial Parking 23 spaces
Total Vehicle Parking Provided 428 spaces
Bicycle Parking Spaces (Long / Short-Term) 81 / 11 spaces Open Space
Publicly Accessible Open Space
Hannum Plaza 7,507 sf
Total Publicly Accessible Open Space 7,507 sf
Common Open Space (for Residents)
Courtyard 11,378 sf
Community Room (Second floor) 396 sf
Gym & Amenity Rooms (Sixth floor) 5,739 sf
Amenity Deck (Sixth Floor) 9,610 sf
Private Open Space (Balconies) 19,526 sf
Subtotal Open Space (for Residents) 46,649 sf
Total Open Space Provided 54,156 sf
Very Low Income Units (included in 309 total units)
Studios 3 units
1-Bedrooms 16 units
2-Bedrooms 8 units
Total Low Income Units 27 units
sf = square feet; ac = acres
SOURCE: KFA, 2024.

2. Project Description

City of Culver City 2-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

2.6.2 Architectural Design
The Project is proposing a contemporary architectural design defined by simple lines, along with a neutral and unified color palette. Figure 2 -4, Conceptual Project Rendering – Hannum Plaza Looking West, is a rendering of the Project’s entrance and a westerly view along Hannum Avenue and illustrates the Hannum Plaza which includes outdoor seating areas for the public. Figure 2-5, Conceptual Project Rendering – Hannum Plaza Looking East, illustrates the Hannum Plaza looking east along Hannum Avenue. Figure 2-6, Conceptual Project Rendering – Northeast Corner of Hannum Avenue and Buckingham Parkway, provides a rendering of the Project as viewed from the intersection of Hannum Avenue and Buckingham Parkway. Figure 2-7, Conceptual Project Rendering – Looking West from Fox Hills Parkette, provides a rendering of the Project as viewed from the Fox Hills Parkette along Hannum Avenue. Figure 2-8, Conceptual Project Rendering – Looking North along Buckingham Parkway, is a northern view along Buckingham.

The Project design includes a curved facade along Buckingham Parkway and a distinct architectural volume anchoring the corner of Hannum Avenue and Buckingham Parkway. At the ground level, the corner retail component would include storefront glazing and a covered outdoor patio. Floating above the double height space, the facade would include textured corrugated and flat panels with large windows for the units. On the sixth floor, the building would become more transparent with a broad canopy and vertical fins framing the amenity deck.

A tripartite scheme along Buckingham Parkway would punctuate the massing along the longer lengths of the site. T he middle portion of the building is defined as a solid frame with semi- recessed unit balconies and inset panels with windows. Along Buckingham Parkway, the top floor would be set back 30 to 40 feet with large unit patios and an expansive amenity deck with views out towards the hills, with a pool, lounge seating and smaller gathering spaces. A large opening into the second floor courtyard would di vide the Buckingham Parkway facing facade into two separate masses while also providing more light and air into the courtyard. Another large opening in the frame closer to Hannum Avenue would provide a view into the courtyard. Units with front stoops would line the ground level facade along Buckingham Parkway, providing direct access to the street and planted areas in between patios, similar to the residential uses across Buckingham Parkway. The Project would follow Project-specific development standards (i ncluding setbacks) as provided in the Comprehensive Plan. The Comprehensive Plan includes 0 foot setback standards at the ground level and five -feet above the ground level along both Hannum Avenue and Buckingham Parkway. However, the Project aims to activate the ground level with pedestrian oriented design to enhance the neighborhood, as the area currently has minimal streetscape improvements. The first floor along Hannum Avenue would be setback between 20 - to 35-feet to create a public plaza with landscaping and a variety of seating areas open to the community. Along Buckingham Parkway, as well as the southern and western boundaries, the building would be set back at least 10-feet from the property line.

5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-4
Conceptual Project Rendering – Hannum Plaza Looking West SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-5
Conceptual Project Rendering – Hannum Plaza Looking East SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-6
Conceptual Project Rendering - Northeast Corner of Hannum Avenue and Buckingham Parkway SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-7
Conceptual Project Rendering – Looking West from Fox Hills Parkette SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-8
Conceptual Project Rendering – Looking North along Buckingham Parkway SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
~

2. Project Description

City of Culver City 2-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

2.6.3 Building Floor Plans and Project Uses
As shown in Figure 2-9, Level P1 Plan, there would be 14 residential units along Buckingham Parkway. Due to the slope of Buckingham Parkway, the six (6) northernmost units shown on the figure would be at grade, while the eight (8) southernmost units would be on the 2nd level as viewed directly from Buckingham Parkway. The figure also illustrates the vehicular driveway/ramp from Buckingham Parkway to the P2 parking garage. Level P1 includes 166 subterranean parking spaces.

Figure 2-10, Level P2 Plan, illustrates the eight (8) at grade residential units located south of the vehicular driveway/ramp to the P2 parking garage along Buckingham Parkway. Level P2 includes 177 subterranean parking spaces. Figure 2-11, First Floor Plan, illustrates the layout of the first floor which residential units along the Buckingham Parkway frontage and within the southern portion of the building. As shown in Figure 2-11, a 5,169 square foot residential lobby area would be located along Hannum Avenue in the north portion of the building, and the Project’s 5,600 square feet of retail use would be located at the northwest corner of the building near the Hannum Avenue/Buckingham Parkway intersection. The first floor includes 85 parking spaces. Bicycle parking, commercial and residential trash rooms, a dog spa, and storage are also illustrated on the first floor plan. Figure 2-12, Second Floor Plan, illustrates a mix of residential units that surround an internal centrally located 11,378 square foot courtyard, which also opens to Buckingham Parkway in two locations. A 396 square foot community room would also be located on the second floor. Floor levels 3 to 5 would consist entirely of residential units. Figure 2-13, Sixth Floor Plan, provides an illustration of the 39 residential units on the sixth floor, as well as the pool, jacuzzi spa, gym and community rooms located in the northeastern portion of the building.

Residential Uses
The 309 residential units would be located on floors P2 through six of the proposed development.

Level P2 would provide 8 two-bedroom two-story units. The first floor of the two-story units would be located on Level P2 and the second story would be located on Level P1. Level P1 would provide 6 residential units comprised of 1 two-bedroom unit and 5 one-bedroom units. The first floor would provide 22 residential units comprised of 3 studio units, 14 one-bedroom units, and 5 two-bedroom units. The second floo r would provide 54 residential units comprised of 6 studio units, 34 one - bedroom units, and 14 two-bedroom units. The third floor would provide 59 residential units comprised of 8 studio units, 33 one -bedroom units, and 18 two-bedroom units. The fourth floor would provide 61 residential units comprised of 8 studio units, 35 one-bedroom units, and 18 two- bedroom units. The fifth floor would provide 60 residential units comprised of 8 studio units, 36 one-bedroom units, and 16 two-bedroom units. The sixth floor would provide 39 residential units comprised of 6 studio units, 23 one-bedroom units, and 10 two-bedroom units.

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SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR

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1 BR
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2 BR
2 BR
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2 BR
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2 BR
2 BR
1 BR
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202'
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-13
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SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR POOL
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2. Project Description

City of Culver City 2-21 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Per CCMC Section 17.400.065 Table 4-2, the maximum allowable height for the Project is 56 feet.

However, the Project is proposing to include 27 units (12 percent of base density) of its residential units as Very Low Income affordable units. By doing so, consistent with the CCMC, State Density Bonus Law (Gov’t Code §65915) and Assembly Bill (AB) 2345, the Project is entitled to receive development incentives including a height increase. The Project is requesting a height increase of 22 feet beyond the maximum allowable height as a development incentive for providing affordable units. With this incentive, the Project would have a height of up to 78 feet due to the existing site topography. In addition to a height incentive due to the Project’s inclusion of affordable units, the Project would be available to receive up to a 50 precent density bonus per AB 2345. Per the City’s 2021-2029 Housing Element, Mixed-Use High land uses are allowed to develop 100 units per acre.

Thus, with the Project Site being 2.23 acres, up to 223 units could be developed. The Project includes 27 units (12 percent of base density) as Very Low Income affordable units. Providing this amount permits a 38.75 percent density increase under AB 2345. At 309 units, the Project w ould be within the allowed number of units with the density bonus incentives included.

Commercial Uses
As previously stated, the commercial uses for the Project would be located on the first floor of the Project. The first floor level of the building would include 5,600 sf of retail space. As shown in Figure 2-11, the retail area would anchor the northeast corner of the Project Site.

2.6.4 Building Elevations and Sections
Figure 2-14, North and West Elevations , provides an illustration of the north elevation facing Hannum Avenue and the west elevation which faces adjacent business park uses. Figure 2-15, East Elevation, which provides an illustration of the east elevation that faces the adjacent residential uses along Buckingham Parkway and its sloping topography. Figure 2-16, South Elevation , provides an illustration of the south elevation adjacent to Buckingham Parkway. Figure 2-17, Building Sections, illustrates the Proje ct’s proposed uses and heights by floor/level. As described in Section 2.6.3, t he Project is requesting a height increase of 22 feet beyond the maximum allowable height as a development incentive for providing affordable units. Design of the project is described in Section 2. 6.2 and building facades along Hannum Avenue and Buckingham Parkway are illustrated in Figures 2-4 through 2-8.

2.6.5 Open Space and Landscaping
The Project would include a total of 54,156 square feet of open space. The Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza. The Hannum Plaza, located along Hannum Avenue, would feature drought tolerant landscaping and a variety of seating areas, open to the community.

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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-14
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+171.00
6TH FLOOR
+181.50
LEVEL P1
+116.00

TO PARAPET
+196.58
ROOF
+192.00
LEVEL P2
+106.00

TOP OF STAIRS
+202.00
10' - 0"10' - 0"13' - 6"10' - 6"10' - 6"10' - 6"10' - 6"10' - 6" 4' - 7"
5' - 5"
+$1180
+$1180$9(
8/9(5&,7<&$

(9$7,216

EAST ELEVATION 2
EAST ELEVATION 1
0' 10' 20' 50'
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-15
East Elevation
SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
~
1ST FLOOR
+126.00
2ND FLOOR
+139.50
3RD FLOOR
+150.00
4TH FLOOR
+160.50
5TH FLOOR
+171.00
6TH FLOOR
+181.50
LEVEL P1
+116.00

TO PARAPET
+196.58
ROOF
+192.00
LEVEL P2
+106.00
4' - 7" 10' - 6"10' - 6"10' - 6"10' - 6"10' - 6" 13' - 6" 10' - 0"10' - 0" 1ST FLOOR
+126.00
2ND FLOOR
+139.50
3RD FLOOR
+150.00
4TH FLOOR
+160.50
5TH FLOOR
+171.00
6TH FLOOR
+181.50

TO PARAPET
+196.58
ROOF
+192.00

TOP OF STAIRS
+202.00
5' - 5"
4' - 7"
10' - 6"10' - 6"10' - 6"10' - 6"10' - 6" 13' - 6"

SOUTH WEST ELEVATION SOUTH ELEVATION
0' 10' 20' 50'
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-16
South Elevation
SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR r ESA
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1ST FLOOR
+126.00
2ND FLOOR
+139.50
3RD FLOOR
+150.00
4TH FLOOR
+160.50
5TH FLOOR
+171.00
6TH FLOOR
+181.50
LEVEL P1
+116.00

TO PARAPET
+196.58
ROOF
+192.00
LEVEL P2
+106.00

TOP OF STAIRS
+202.00
TO PARAPET 2
+199.58

BUCKINGHAM
PKWY

COURTYARDADJACENT

BUSINESS

PARK RESIDENTIAL PARKING

RESIDENTIAL RESIDENTIAL
2' - 5"
3' - 0"
4' - 7" 10' - 6" 10' - 6" 10' - 6" 10' - 6" 10' - 6" 13' - 6" 10' - 0" 10' - 0"

AMENITY DECK

MAX HEIGHT PER CCMC
56' - 0"
MAX HEIGHT (AB2345)
78' - 0"
LINE OF EXISTING GRADE OFFSET 78'-0" ABOVE

LINE OF EXISTING GRADE

ELEVATOR PENTHOUSES

RESIDENTIAL PARKING

RESIDENTIAL PARKING
9' - 0"9' - 4"9' - 4"9' - 4"9' - 4"10' - 6"
12' - 6"

FUTURE MECHANICAL EQUIPMENT
8' - 0"
8' - 11"
8' - 0"

FUTURE MECHANICAL EQUIPMENT
10' - 0"11' - 4"

SECTION A
1ST FLOOR
+126.00
2ND FLOOR
+139.50
3RD FLOOR
+150.00
4TH FLOOR
+160.50
5TH FLOOR
+171.00
6TH FLOOR
+181.50
LEVEL P1
+116.00

TO PARAPET
+196.58
ROOF
+192.00
LEVEL P2
+106.00

TOP OF STAIRS
+202.00
TO PARAPET 2
+199.58

RESIDENTIAL PARKING

RESIDENTIAL UNITS
2' - 5"
3' - 0"
4' - 7"10' - 6"10' - 6"10' - 6"10' - 6"10' - 6" 13' - 6" 10' - 0"10' - 0" LINE OF EXISTING GRADE OFFSET 78'-0" ABOVE GRADE

LINE OF EXISTING GRADE

ELEVATOR PENTHOUSE

RESIDENTIAL PARKING

RESIDENTIAL PARKING
MAX HEIGHT (AB2345)
78' - 0"
8' - 0"
8' - 0"

FUTURE MECHANICAL EQUIPMENT

BUCKINGHAM
PKWY
9' - 0"
9' - 4"9' - 4"
9' - 4"9' - 4"10' - 6" 10' - 0"11' - 4"
0'
1ST FLOOR
+126.00
2ND FLOOR
+139.50
3RD FLOOR
+150.00
4TH FLOOR
+160.50
5TH FLOOR
+171.00
6TH FLOOR
+181.50
LEVEL P1
+116.00

TO PARAPET
+196.58
ROOF
+192.00
LEVEL P2
+106.00

TOP OF STAIRS
+202.00

HANNUM AVERETAIL PARKING
4' - 7"10' - 6"10' - 6"10' - 6"10' - 6"10' - 6" 13' - 6" 10' - 0"10' - 0" LINE OF EXISTING GRADE OFFSET 78'-0" ABOVE GRADE

LINE OF EXISTING GRADE

FUTURE MECHANICAL EQUIPMENT
8' - 0"
8' - 0"
9' - 0"
9' - 4"9' - 4"
+$1180
+$1180$9(
&8/9(5&,7<&$

6,7(6(&7,216

SECTION B2
SECTION B1
0' 10' 20' 50'
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 2-17
Building Sections
SOURCE: KFA, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR iiiiii rr;

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2. Project Description

City of Culver City 2-26 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Of the total amount of open space, 19,526 square feet would be provided as private open space within balconies or private yards distributed throughout the Project’s eight levels (including the P1 and P2 levels). The remaining square footage would be common open space for residents. The Project would provide approximately 27,123 square feet of resident only open space. A 11,378 square foot centrally located courtyard and a 396 square foot community room would be located on the second floor. The central courtyard on the second floor would have a variety of seating areas, BBQs, and drought tolerant landscape.

A 9,610 square foot amenity deck, and 5,739 square feet of community room area and gym space would be located on the sixth floor. The sixth floor/roof level pool deck would include a pool and spa enclosed by a 3.5 foot perimeter amenity deck glass enclosure. The pool deck would open to the community room amenity space that would include open seating areas, private meeting areas, and a warming kitchen. The community room would be used for infrequent special events for residents.

Outdoor common spaces for residents would include lounge seating, gathering spaces, and small speakers installed in discreet areas to be used for low volume ambient sound and music. Occasional events for residents only would be held throughout the year within the courtyard or roof deck as an amenity for the residents. These events might include outdoor yoga, intimate food and beverage events, and/or outdoor movies. The property management team would have on- site staff, courtesy patrol, or hired service present at all times during such events. Additionally, on-site functions would require applicable insurance and executed event waivers.

Open space and landscaping would be provided in accordance with CCMC Requirements. The Project would incorporate public -facing landscaping along Hannum Avenue and Buckingham Parkway. The landscape design would be tailored for each of the landscaped open space areas with a compatible plant palette used throughout the Project Site. Planted perimeters at the ground level would buffer the Project site from Hannum Avenue and unit entrances along Buckingham Way while leaving openings for community facing mixed use. Two (2) new street trees and fifty-six (56) on-site trees are proposed. On-site, twenty-one (21) trees are proposed on Level P1, P2, and the first floor; twenty-four (24) trees are proposed within the second -floor courtyard, and eleven (11) trees proposed on the sixth floor amenity deck.

The first floor/ground level would feature planting areas, walkways, trees, and seating areas. Hannum Plaza, the first level outdoor area with seating outside the retail area at the intersection of Buckingham Parkway/ Hannum Avenue, would be open to the public, with the site’s other first level areas available only to Project residents. Seating areas would be placed throughout Hannum Plaza to create spaces for rest, open to the community. Seating areas would range from smaller spaces for 2 -8 people to larger open spaces that can accommodate more people and remain flexible as seating areas, a planted refuge, and outdoor co-working spaces. Planters at a height of 3’ feet would be planted with dense low water use plants, including trees. Irrigation would be provided by high efficiency drip systems on weather- based smart controllers. Landscaping would emphasize native, Mediterranean, and drought tolerant plants (e.g., Agave, Aloe, ornamental grasses, leafy groundcovers, colorful shrubs, and soft textured vegetation). For the trees being removed from the Project Site, new replacement trees would be planted on the Project Site per Section 9.08.215 of the CCMC.

2. Project Description

City of Culver City 2-27 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

2.6.6 Vehicular and Bicycle Access, Circulation, and Parking Vehicular Access
There is currently one driveway to access the Project Site along Hannum Avenue. Access is also available via Uplander Way. Vehicular access to the Project Site would be provided via two driveways, the Hannum Driveway and the Buckingham Driveway. Both driveways would provide access to the parking structure, with the Hannum Driveway accessible to residents, employees, and visitors. The Buckingham Driveway would be restricted to residential vehicles only on levels P1 and P2.

The driveway on Hannum Avenue would serve the proposed retail uses and would also provide access for resident and resident guest parking. Access for trucks and deliveries would be off of Hannum Avenue where the loading area is located in the north end of the Project Site near Hannum Avenue. The trash enclosures would be accessed from the access road/driveway to the west of the Project Site. A loading zone would be located along Buckingham Parkway for trash pick -up, passenger pickup, and residential move-in.

Bicycle Access
Bicycle access to the Project Site would be provided separately from the vehicular driveways via entrances along Buckingham Parkway to reduce potential vehicle -pedestrian and vehicle -bicycle conflicts. Hallway access doors would be located on each parking level (P2, P1, 1) and bicyclists would share the residential corridors connecting to long term bike storage rooms. The driveways on Hannum Avenue and Buckingham Parkway would be designed to provide maximum visibility between all roadway users. Bicycle park ing amenities would also be provided for residents, employees, and visitors to the site. The Project will provide a total of 92 bicycle parking spaces, with 8 reserved for short term resident use, 78 for long term resident use, and 3 each for commercial short and long term use. Bicycle racks for residents and visitors would be available next to the retail lobby off of Buckingham Parkway, on Level P2, and on Level P1 next to the P1 lobby. Bicycle lockers would be provided for residents and employees. Long te rm spaces will be provided in enclosed rooms internal to the Project, accessed only by residents or employees. Short -term bike parking would be located on Buckingham Parkways near the corner of Hannum Avenue and within the Hannum Plaza, across from the residential lobby.

An existing Class II bike lane is provided on both sides of Hannum Avenue adjacent to the Project Site. Development of the Project would maintain the existing bike lane along Hannum Avenue; however, the Hannum Driveway would intersect with the eastbound bike lane on the south side of Hannum Avenue. To ensure maximum visibility, the Hannum Driveway would meet all applicable CCMC requirements to ensure adequate sight distance is provided for drivers of vehicles entering and leaving the Project Site as well as bicyclists and pedestrians wishing to cross the driveway.

While no existing bicycle lanes are provided on Buckingham Parkway, Culver City Bicycle & Pedestrian Action Plan calls for a Class IV bike lane to be installed. The design for this bicycle lane has not been finalized. However, the Buckingham Driveway would intersect the southbound bicycle lane on the west side of Buckingham Parkway. Similar to the Hannum Driveway, the Buckingham Driveway would ensure maximum visibility by meeting all of the City’s driveway

2. Project Description

City of Culver City 2-28 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site as well as bicyclists crossing the driveway. The Project would not preclude the installation of the bicycle lane on Buckingham Parkway.

Pedestrian Circulation
The Project Site is oriented such that residents would be able to walk through and around the Project Site with multiple access points and community connections to the development. The first floor retail use at the corner of Hannum Avenue and Buckingham Parkway would serve as a pedestrian point of interest on the Project Site . It will be accessible from the street level along Hannum Avenue. The Hannum Plaza, located along Hannum Avenue, would provide open space for people to gather and interact with the retail space. Pedestrians would also be able to easily access the retail area from Hannum Avenue or Buckingham Avenue.

Vehicle and Bicycle Parking
Structured parking containing 428 vehicular parking spaces on three levels would be provided on the Project Site with 405 spaces for residential uses (including 6 parking spaces for residential guests) and 23 spaces for commercial uses. The subterranean parking level one (P1) would include parking spaces for 166 spaces for residential use. The subterranean parking level two (P2) would include 177 parking spaces for residential use. The first floor parking level would include 62 vehicle parking spaces for residential uses and 23 parking spaces for retail uses. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty -four (44) total spaces (41 residential + 3 commercial) would be EV ready. The vehicle parking spaces for residential guests would be clearly identified either by specific ground painting or wall signage/decals and would be located within the residential garage in the subterranean parking levels only. All subterranean parking would be secured under an access control system. There would be 81 long-term and 11 short-term bicycle parking spaces provided in the subterranean parking levels P1 and P2, on the first floor, and along Buckingham Parkway.

Public Transit
The Project Site is served by a variety of public transit options along Hannum Avenue and Buckingham Parkway provided by the Culver City Department of Transportation. Most significantly, the Project Site is located 0.6 mile east of the Culver City Transit Center which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Other transit operations in the vicinity of the site include Culver City Bus Line 5C2 – Overland/Fox Hills, which includes Stop 306 Hannum Ave/Buckingham Parkway, approximately 210 feet west of the Project Site.

Transportation Demand Management Program
Transportation demand management (TDM) features would be implemented by the Project.

Examples of the TDM features the Project would include, but are not limited to bicycle parking and amenities; employee parking; bus stop improvements ; and a Transportation Information Center (TIC). A TIC is a centrally -located commuter information center where the Project residents and employees can obtain information regarding commute programs, and individuals can obtain real-time

2. Project Description

City of Culver City 2-29 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
information for planning travel without using an automobile. A TIC provides information about transit schedules, commute planning, rideshare, telecommuting, bicycle routes and facilities , and facilities and resources for carpoolers, vanpoolers, bicyclists, transit riders, and pedestrians. The TIC can be provided via a bulletin board, display case, or kiosk, as well as virtually, providing every resident, employee, and visitor access to commuter information through a website portal . In accordance with the California Green Building Standards Code (CALGreen Code), infrastructure for EV charging stations would be provided.

2.6.7 Lighting and Signage
Exterior lighting would incorporate low -level exterior lights on the buildings and along pathways for security and wayfinding purposes. In addition, low-level lighting to accent signage, architectural features, and landscaping elements would be incorporated throughout the Project Site. Lighting for the Project is intended to minimize light trespass and glare from buildings and the Project Site onto adjacent properties, to provide comfort, safety, and nighttime visibility through shielded, focused and directed illumination. New street and pedestrian lighting within the public right-of-way would comply with applicable city regulations and would require approval from the City to maintain appropriate and safe lighting levels on sidewalks and roadways while minimizing light and glare on adjacent properties.

All proposed lighting for the Project’s residential and retail uses would be provided in accordance with CCMC Section 17.300.040, which provides the general standards for outdoor lighting to regulate lighting fixtures and design, energy use, light shielding, light intensity, and lighting placement.

Additionally, the Project would comply with CCMC Section 15.02.110A.12, which requires that all new lighting installed in a garage or parking structure be motion-sensor controlled and that minimum base level ligh ting shall be permitted. Project materials would also be selected to avoid highly reflective surfaces that would result in adverse glare effects on motorists or adjacent uses.

Proposed signage would be designed to be aesthetically compatible with the existing and proposed architecture of the Project Site and would comply with the requirements of the CCMC. Proposed signage would include identity signage, building and tenant signage, residential address numbers and parking entry signage, and general ground level and wayfinding pedestrian signage. No off-site advertising signage is proposed. New signage would be architecturally integrated into the design of the proposed building and would establish appropriate identification for the proposed uses. Exterior lighting for signage would be directed onto signs to avoid creating off-site glare. Signage may also be back-lit. Illumination used for Project signage would comply with light intensities set forth in the CCMC as measured at the property line of the nearest residentially zoned property.

2.6.8 Site Security
The Project would incorporate a security program to ensure the safety of Project residents, employees, and visitors. During construction of the Project, the Project Site would be fenced and gated with surveillance cameras to monitor the site during off hours. Access to retail uses and publicly accessible open space areas would be unrestricted during business hours. Facility operations would include staff training and building access/design to assist in crime prevention efforts and to reduce the demand for police protection services. Site security would include the provision of 24-

2. Project Description

City of Culver City 2-30 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
hour video surveillance. Security cameras would be located to capture views at the perimeter of the proposed buildings; at main pedestrian and vehicular entries; and other outdoor locations as appropriate; and at stair/elevator lobbies. During operation of the Project, access to the parking structure would be controlled through gated entries, keycard access, and the entry areas , publicly accessible areas, parking areas, and common open space residential areas would be well illuminated.

2.6.9 Sustainability Features
Energy saving and sustainable design features would be incorporated into the Project as the proposed buildings would comply with the applicable Title 24 California Code of Regulations. The Project would include 1 kW solar photovoltaic panels, per CALGreen standards. Design features would include energy conservation, water conservation, TDM and mobility measures, and pedestrian- and bicycle -friendly site design. EV parking and charging would be available for residential and commercial use. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready. The Project would include 92 bicycle spaces, consisting of 11 short-term and 81 long- term bicycle parking spaces. As it relates to energy conservation, the Project would include LED lighting throughout the Project Site and would install ENERGY STAR -rated appliances. As it relates to water conservation, the Project would incorporate efficient water management through low flow faucets and water-efficient landscape design with weather -based controllers and drip irrigation systems.

2.6.10 Anticipated Construction Schedule/Activities
A Construction Management and Traffic Plan would be prepared which defines the scope and scheduling of planned construction activities as well as the Applicant’s proposed construction site management responsibilities, to ensure minimal impacts to neighboring residents and land uses and to avoid interruption of pedestrian, vehicle, and alternative transportation modes and public transit.

The Construction Management and Traffic Plan would facilitate communication and coordination with residents and others in the neighborhood. A final comprehensive Construction Traffic Management Plan would be subject to review and approval by the City prior to the start of any construction activity. The Plan would include but not necessarily be limited to: name and telephone number of a contact person regarding traffic complaints or emergency situations; community notification procedures; contact information for loc al police, fire, and emergency response organizations and procedures for the continuous coordination of construction activity; procedures for training the flag person(s) used in implementing the plan; the location, times, and estimated duration of any temporary lane closures; managing the approved haul route plan; timing of disruptive construction activities; and a construction parking management plan.

The CCMC prohibits construction between the hours of 8:00 P.M. and 8:00 A.M. Monday through Friday, 7:00 P.M. and 9:00 A.M. on Saturday, and 7:00 P.M. and 10:00 A.M. on Sunday. In order to ensure the highest level of quality for the concrete structure and to reduce the construction duration, the Project would request approval for extended construction hours to be considered in conjunction with the entitlement application for the Project. That is, the Project is requesting an approval for Extended Hours of Construction, as allowed by CCMC Section 9.07.035.C.1, to allow for a 7:00 AM daily start, Monday through Saturday during the excavation, hauling, and concrete

2. Project Description

City of Culver City 2-31 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
activities. The daily construction end times would remain consistent with those allowed by the CCMC. The extended construction hours are being requested over the course of approximately four (4) months during the earthwork shoring/excavation , concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction. The other construction phases would occur per the allowable standard CCMC permitted construction hours.

The Project would require excavation to accommodate subterranean parking, building foundations, utilities and other improvements. Up to approximately 51,400 cubic yards (cy) of earthwork would be excavated and exported from the Project Site. Construction staging would be entirely internal to the Project Site. The Project would excavate to a maximum depth of 27 feet below grade.

Project construction would occur in one phase and is anticipated to commence as early as the first quarter of 2025 and is expected to take approximately 30 months to complete. Full build-out is expected as early as the fourth quarter of 2027.

2.7 Project Design Features
The Project proposes to implement a number of Project Design Features (PDFs) that have been voluntarily incorporated into the Project that serve to minimize or avoid significant environmental effects. The Project Design Features will be included in the Mitigation Monitoring and Reporting Program required in association with certification of the Draft EIR. The Project Design Features are summarized in Table 2-2, Summary of Project Design Features, and are discussed in detail in the technical sections indicated in the table. The Project Design Features are taken into account in the analyses of potential Project impacts.

TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary AES-PDF-1: Screening of Utilities Mechanical, electrical, and roof top equipment (including Heating, Ventilation, and Air Conditioning [HVAC] systems), as well as building appurtenances (such as rooftop elevator stops), will be integrated into the Project’s architectural design (e.g., placed behind parapet walls) and will be screened from view from public rights-of-way.

GHG-PDF-1: Green Building
Features
The Project will include the following green building features:
• The Project buildings will be designed to meet the United States Green Building Council (USGBC) Leadership in Energy and Environmental Design (LEED) rating system at a "certified" performance level or higher and will be designed and operated to meet or exceed the applicable requirements of the State of California Green Building Standards Code and Culver City’s Green Building Program Requirements.
• The Project will incorporate renewable energy features in the form of 1 kW solar photovoltaic panels per 10,000 sf in order to achieve compliance with the City of Culver City’s solar photovoltaic requirement, per the City’s Green Building Ordinance and CALGreen standards.
• The Project will provide EV parking and charging for residential and commercial use. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready. Forty-four (44) total spaces (41 residential + 3 commercial) would have EV charging stations. • The Project will include LED lighting throughout the Project Site and would install ENERGY STAR-rated appliances.

2. Project Description

City of Culver City 2-32 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary • The Project will incorporate efficient water management through low flow faucets and water-efficient landscape design with weather-based controllers and drip irrigation systems.
• The Project will utilize only electricity and no natural gas in all land uses except for the retail space.

NOI-PDF-1: Project Construction
Schedule
Prior to issuance of a building permit, notice of the Project construction schedule will be provided to adjacent property owners and occupants. Evidence of such notification will be provided to the City of Culver City Public Works Department.

NOI-PDF-2: Use of Impact Pile
Driver
The Project will not require or allow the use of impact pile drivers. Lower noise- and vibration-generating shoring piles to be drilled will be used.

NOI-PDF-3: Construction Rules
Sign
During all phases of construction, a “Construction Rules Sign” that includes contact names and telephone numbers, with 24-hour availability, of the Applicant, Property Owner, construction contractor(s) will be posted on the Property in a location that is visible to the public. In addition, appropriate staff person at the City of Culver City will be notified for such incidences. These names and telephone numbers will also be made available to adjacent property owners and occupants to the satisfaction of the appropriate department (Planning Manager and/or Building Official) of Culver City.

NOI-PDF-4: Neighborhood Streets No construction haul trucks, including concrete trucks, will be allowed to travel through neighborhood streets that are primarily residential uses.

NOI-PDF-5: Mechanical Equipment
Noise
All building mechanical equipment and/or ventilation systems not fully enclosed will be designed to not exceed sound level limits of the noise level requirements of the City of Culver City General Plan Noise Element Regulation of Stationary Noise Sources through the use of quiet fans, duct silencers, parapets, or similar noise attenuation methods.

NOI-PDF-6: Noise Control –
Amplified Sound Systems
If the Project installs permanent outdoor amplified sound systems, the systems will be located in discrete areas of the outdoor common opens space areas courtyard such that the sound would be mostly blocked by the proposed on-site building or walls from off-site residential receivers. Section 9.07.055(B) of the CCMC prohibits the operation of a loud speaker or sound amplifying equipment for the purposes of transmitting messages, giving instructions or providing entertainment which is audible at a distance of fifty (50) feet or beyond the subject's property line without first filing an application and obtaining a permit as set forth in Chapter 9.07, Noise Regulations, of the CCMC. The systems will at a minimum be designed so as not to result in a perceivable increase at the nearest noise sensitive residential receptor. Specifically, daytime outdoor amplified sound systems will not result in an increase of 5 dBA L
eq over existing ambient noise
conditions at the nearest noise sensitive residential receptor. Nighttime speaker noise, if it occurs, will comply with the exterior noise standards identified in the Regulation of Stationary Noise Sources (City of Culver City General Plan Noise Element, approved by City Council July 22, 1996). A qualified noise consultant will provide written documentation and submitted to appropriate department of City of Culver City that the design of the system(s) complies with the maximum noise levels at the property line of the nearest off-site sensitive receivers.

POL-PDF-1: Project Site Security
and Access During Construction
During construction of the Project, the Project Site will be fenced and gated with surveillance cameras to monitor the site during off hours.

POL-PDF-2: Project Site Security
and Access During Operation
During operation of the Project, access to the parking structure will be controlled through gated entries, and the entry areas will be well illuminated. Project Site security would include controlled keycard access to office spaces, security lighting within common areas and entryways, and closed-circuit TV monitoring (CCTV).

2. Project Description

City of Culver City 2-33 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary TRAF-PDF-1: Construction
Management Plan
A Final Construction Management Plan (FCMP) will be prepared by the Project contractor in consultation with the Project's traffic and/or civil engineer. The FCMP will define the scope and scheduling of construction activities covering the entire Project Site as well as the Applicant's proposed construction site management responsibilities in order to ensure that disturbance of nearby land uses or interruption of pedestrian, vehicle, bicycle and public transit are minimized to the extent feasible. The FCMP will be subject to review and approval by appropriate building officials, city traffic engineers, civil engineers, and planning manager for the City of Culver City, as required, prior to issuance of any Project demolition, grading or excavation permit. The FCMP will also be reviewed and approved by the respective fire and police departments.

Prior to commencement of construction, the contractor will advise the City’s public works inspector and building inspector (inspectors) of the construction schedule.

As-needed construction management meetings shall be convened with appropriate Culver City staff and representatives of surrounding developments that may have overlapping construction schedules with the Project, to ensure that concurrent construction projects are managed in collaboration with one another.

The FCMP will consider potential project construction disruptions to transportation facilities near the Project Site and provide effective strategies to limit the Project’s use of the public right-of-way (streets and sidewalks) during peak traffic periods, and will be subject to adjustment by City staff as deemed necessary and appropriate to preserve the general public safety and welfare.

Prior to approval of the FCMP and grading permits, the Applicant will conduct once (1) community meeting pursuant to the notification requirements of the City of Culver City community meeting guidelines, to discuss and provide the following information to the surrounding community:

1. Construction schedule and hours.

2. Framework for construction phases.

3. Identify traffic diversion plan by phase and activity.

4. Potential location of construction parking and office trailers.

5. Truck hauling routes and material deliveries (i.e., identify the potential routes and restrictions. Discuss the types and number of trucks anticipated and for what construction activity).

6. Emergency access plan.

7. Demolition plan.

8. Staging plan for the concrete pours, material loading and removal.

9. Crane location(s).

10. Accessible Applicant and contractor contacts during construction activity and during off hours (relevant email address and phone numbers).

11. Community notification procedures.

The FCMP will at a minimum include the following:

1. The name and telephone number of a contact person who can be reached 24 hours a day via telephone regarding construction or construction traffic complaints or emergency situations.

4. Procedures for the training and certification of flag persons.

2. Project Description

City of Culver City 2-34 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary

6. The location of temporary power, portable toilet and trash and materials storage locations.

7. The timing and duration of any street, sidewalk and/or lane closures will be approved in advance by ethe City of Culver City. As traffic lane, parking lane, and/or sidewalk closures are anticipated, worksite traffic control plan(s), approved by the City of Culver City, will be developed and implemented to route vehicular traffic, bicyclists, and pedestrians around any such closures. As applicable at the time of construction, such notices will be made available in digital format for posting on each City website and distribution via email alerts on electronic platforms such as the County of Los Angeles’ "Gov Delivery" system. The FCMP will be updated weekly during the duration of project construction, as determined necessary by the City. The FCMP will require that review and approval of any proposed lane closures include coordination with the Culver City Fire and Police Departments to minimize potential effects on traffic flow and emergency response.

TRAF-PDF-2: Transportation
Demand Management (TDM)
Program
The Project will implement TDM measures that include, but are not limited to, those listed below subject to Culver City Transportation Department review and approval prior to issuance of the first Temporary Certificate of Occupancy (TCO) for the Project in order to reduce drive-alone vehicle trips to/from the Project Site by residents, visitors and employees, as well peak hour traffic. The TDM strategies necessary comply with the TDM and trip reduction requirements of City Municipal Code Section 07.05.015, as well as City’s design requirements for the Project:

On-S
ite Enhancements - The Project design will incorporate mobility features to encourage alternative transportation modes. The features will be designed in accordance with the City Municipal Code requirements and standards. • P edestrian Connections. The Project will provide exclusive pedestrian access separate from vehicular driveways. The Project will provide internal walkways that connect the pedestrian access points to off-site pedestrian facilities, rideshare, and transit.
• B icycle Parking and Amenities. The Project will provide both short-term and long-term bicycle parking spaces on-site in accordance with the City Municipal Code requirements. Short-term bicycle parking, which will include bicycle racks, will be located near the pedestrian entrance. Long-term bicycle parking, which will include bicycle lockers or secure bicycle enclosures, will be placed in an accessible weather protected location.

Electric Vehicle (EV) Parking. In ac
cordance with City Municipal Code Section

17.320.035.O.3, at least 40% of the onsite parking supply will have EV capability, including EV Capable spaces (20%), EV Ready spaces (10%), and Full EV Charger/Charging Stations (10%).

Off-Site Enhancements -
The Project will improve and contribute toward
improvements to off-site mobility facilities to encourage alternative transportation modes.
• Mobility Fees. In accordance with City Municipal Code Section 05.06.015, the Project will be subject to contributing its fair share toward funding the City's mobility infrastructure and improvement projects intended to reduce VMT and support housing and job growth. Pursuant to Resolution No. 2021-R055, the total mobility fee for the Project will be based on a rate of $3,394 per multi- family unit and $14.92 per sf of commercial space.

2. Project Description

City of Culver City 2-35 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary Other TDM Strategies - The Project will implement TDM strategies to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The following details the minimum TDM strategies necessary to comply with the TDM and trip reduction requirements of City Municipal Code Section 07.05.015, as well as City’s design requirements for the Project:
• T ransportation Information Center (TIC). The Project will provide a TIC, a commuter information center where residents, employees, and visitors can obtain information regarding commute programs and individuals can obtain real-time information for planning travel without using an automobile. A TIC provides information about transit schedules, commute planning, rideshare, telecommuting, bicycle routes and facilities, and facilities and resources for carpoolers, vanpoolers, bicyclists, transit riders, and pedestrians. The TIC can be provided via a bulletin board, display case, or kiosk, as well as virtually, providing every resident, employee, and visitor access to commuter information through a website portal.
• B icycle Parking and Amenities. The Project will support bicycling to work through the provision of bike storage facilities throughout the Project site.

Bicycle parking will be provided in accordance with the City Municipal Code requirements for the Project and will include short-term facilities (e.g., bicycle racks) and secure long-term bicycle parking (e.g., fully enclosed rooms or bicycle lockers that protect the bicycle from inclement weather and accessible only to the owner).
• P edestrian-Friendly Environment. The Project is designed to be pedestrian- friendly and accessible to the local neighborhood. The Project’s pedestrian access points will be located separate from vehicular access points. To promote walkability within and around the Project site, internal pedestrian pathways will provide a safe and direct connection to external public pedestrian facilities. Safety measures will also be implemented at the Project driveway to ensure safe crossings to limit potential vehicular-pedestrian conflicts.
• E mployee Parking. At least 10% of employee parking will be reserved, as signed on the spaces, for use by potential carpool or vanpool vehicles and located as close as practical to employee entrances. This preferential parking will be identified on the site plan accompanying the application for a building permit. Vanpool spaces will have a minimum parking space dimension of nine feet wide by 18 feet in length and provide a minimum interior vertical clearance of eight feet two inches. A safe and convenient zone in which vanpool and carpool vehicles may deliver or board their passengers will also be provided. • B us Stop Improvements. If deemed necessary by the City, bus stop improvements will be provided to the satisfaction of the City Director of Transportation.

Plan/Program Management - Th
e Project will take appropriate measures to help
future residents and employees manage each TDM Plan element and maximize program participation through consolidation of information and proactive engagement. The following will be provided as part of the TDM Plan:
• P roject Transportation Coordinator. A Transportation Coordinator will be designated for the site and will be responsible for implementing, coordinating, and maintaining the elements of the TDM Plan. The identity and contact information for the Transportation Coordinator will be supplied to the City and kept current.
• T ransportation Information Packet for New Residents and Employees. Each new resident and employee will receive an information packet summarizing the transit and transportation alternatives available to Project tenants. The packet will emphasize the location of the TIC and include the contact information of the Transportation Coordinator.

2. Project Description

City of Culver City 2-36 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 2-2

SUMMARY OF PROJECT DESIGN FEATURES
Project Design Feature # Project Design Feature Summary Mobility Hub Support and Alternative Transportation - The Project will incorporate measures and design elements to support first-mile/last-mile service connection for transit users and reduce reliance on personal automobiles. The following will be provided as part of the TDM Plan:
• B ike Repair Station. The Project will provide an on-site bike parking station for use by Project residents and employees that has a space and basic tool set for bike repairs.
• S ubsidized Shared-Ride/Uber/Lift Service. Employees who arrive to work via a means other than a single-passenger vehicle or utilize the carpool matching service will automatically be registered in a Subsidized Shared-Ride/Uber/Lift Service by which, upon request to the Transportation Coordinator, the employee will be given a voucher to travel home or Uber/Lyft (or similar shared ride service) in case of illness or emergency. The Project will provide up to $750 in total for this program every year. The subsidy will be for two years after Certificate of Occupancy over a two-year period.
• T ransit Passes. The Project will provide up to $500 per pass per year of subsidies for up to five Transit Access Passes (TAP) cards for a period of three years for employees who opt to take Metro instead of personal vehicles and will not be provided on-site parking accommodations and not receive a car share subsidy.

WATER-PDF-1: Water
Conservation
The Project will implement water conservation measures that include, but are not limited to, the following:
• Landscape and Irrigation
o California Friendly® plants or native plants
o Drip/ Subsurface Irrigation (Micro-Irrigation)
o Proper Hydro-zoning/Zoned Irrigation (groups plants with similar water requirements together)
SOURCE: ESA, 2024.

2.8 Anticipated Project Approvals
Discretionary entitlements, reviews, and approvals required or requested for the Project may include, but would not necessarily be limited to, the following:
• General Plan Map Amendment from Regional Center to General Corridor; • Zone Change Map Amendment from Commercial Regional Business Park to Planned Development;
• Adoption of a Comprehensive Plan for the Project to develop standards for the new PD Zone District;
• Density and Other Bonus Incentives (DOBI) to allow Increased Density with affordable units incorporated into the Project; and
• Approval for Extended Hours of Construction (CCMC Section 9.07.035.C.1).

In addition, the Project would require ministerial permits including but not limited to demolition, grading, building, haul route and engineering permits.

City of Culver City 3-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 3
Environmental Setting

3.1 Overview of Environmental Setting
CEQA Guidelines Section 15125 requires that an EIR include a description of the existing environment. This chapter provides a general overview of the environmental setting for the Project, however, detailed information on existing conditions for each envir onmental resource area evaluated in this Draft EIR is provided in Chapter 4, Environmental Impact Analysis. This chapter also provides an overview of related projects that are considered in the Draft EIR in evaluating cumulative impacts that could result from the Project together with other projects.

3.1.1 On-Site Conditions
The approximately 2.23-acre (97,264 square feet [sf]) Project Site is located at 5700 Hannum Avenue within the Fox Hills neighborhood of the City of Culver City (City). Primary regional access is provided by the San Diego Freeway (1 -405) located approximately 0.7 mile west of the Project Site. Local access to the Project Site is provided to the Project Site via Hannum Avenue, Buckingham Parkway, and Uplander Way.

The Project Site is currently occupied by an approximately 30,672 square foot two-story office building built in the late 1970s. The remainder of the Project Site includes surface parking and associated landscaping. The sidewalks adjoining the Project Site to the north, west, and south are landscaped with street trees and trees are scattered throughout the existing surface parking lot. The office building and surface parking uses are on relatively flat graded land, however, Buckingham Parkway slopes downward from north to south, with the northernmost elevation (at its intersection with Hannum Avenue) at approximately 128 feet and the southernmost elevation (near Windsor Way) at approximately 103 feet. Thus, the topographical street elevation decreases by approximately 25 feet from north to south. A landscaped slope at varying widths up to approximately 50-feet wide and heights up approximately 17 feet high traverses along the Project Site’s eastern edge along Buckingham Parkway.

Existing vehicle access to the Project Site is provided via two ingress and egress points, which are located along Hannum Avenue and Uplander Way. Hannum Avenue, an east -west roadway adjacent to the Project Site, abuts the northern boundary of the Project Site and includes bicycle lanes in both directions. Uplander Way to the east of the Project Site is separated from the Project Site by an intervening business park property but provides access to the Project Site via a driveway to the Project Site’s surface parking area. Buckingham Parkway abuts the eastern and southeastern boundary of the Project Site (due to the curved nature of Buckingham Parkway) and contains limited curbside parking but does not provide direct access to the Project Site. Existing on -site

3. Environmental Setting

City of Culver City 3-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
surface parking includes 109 regular parking spaces and two handicapped parking spaces for a total of 111 parking spaces.

In addition to the existing building and associated surface parking, there is a mix of ornamental landscaping on the Project Site. There are 119 trees on the Project Site including carrotwood, Canary Island Pine, Brazilian pepper, olive, weeping bottlebrush, paperbark, and podocarpus. In addition, there are 14 carrotwood street trees along Buckingham Parkway adjacent to the Project Site.

The General Plan Land Use designation for the Project Site is Regional Center, which allows large- scale commercial uses and is intended to support existing and anticipated regional -serving commercial developments. The Regional Center land use designation does not support residential and/or residential mixed-use projects. As a result, the Project’s requested approvals include a General Plan Amendment to change the Property’s land use designation to General Corridor. Per the Culver City Zoning Code (Zoning Code), the Project Site is zoned Commercial Regional Business Park (CRB). The CRB Zoning District identifies areas appropriate for large-scale office and business park developments with shared parking, including specific light industrial uses and does not permit residential uses. The City adopted a 2021- 2029 Housing Element on January 24, 2022. Pursuant to the City’s adopted Housing Element, the Project Site ’s preferred land use designation is Mixed -Use High, which would allow for high-density residential uses including mixed-use development. In addition, the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update, includes the draft Land Use Map and Land Use designations with appropriate draft densities. The Project Site’s draft land use designation and density is Mixed-Use High which permits 100 dwelling units per acre, consistent with the Housing Element preferred designation and density.

3.1.2 Surrounding Uses
The area surrounding the Project Site is developed primarily with office, business park and residential uses. Land uses located adjacent to the Project Site include: a parking lot and an office building to the north (across Hannum Avenue), a business park building and a surface parking lot to the west, multi-family residential uses to the south/southeast (across Buckingham Parkway), and Fox Hills Parkette to the east across Buckingham Parkway. The surrounding areas to the north of the Project Site across Hannum Avenue and west and south of the Project Site (east side of Buckingham Parkway) have a General Plan land use designation of Regional Center. The multi - family uses across Buckingham Parkway to the east of the Project Site are designated by the General Plan for Planned Residential Development use, while the Fox Hills Parkette has an Open Space land use designation.

3.2 Related Projects
CEQA requires that EIRs analyze cumulative impacts. As defined in CEQA Guidelines Section 15355, a cumulative impact would result from the combination of the project evaluated in the EIR together with other projects that would cause related impacts. CEQA Guidelines Section 15130(a) states that an EIR must discuss cumulative impacts of a project when the project's incremental effect is cumulatively considerable, as defined in Section 15065(a)(3). Where a lead agency is examining a project with an incremental effect that is not “cumulatively considerable,” a lead I

3. Environmental Setting

City of Culver City 3-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
agency need not consider that effect significant but must briefly describe its basis for concluding that the incremental effect is not cumulatively considerable. When the combined cumulative impact associated with the project's incremental effect and the effects of other projects is not significant, the EIR must briefly indicate why the cumulative impact is not significant and is not discussed in further detail in the EIR. A lead agency may determine that a project’s contribution to a significant cumulative impact will be rendered less than cumulatively considerable and thus is not significant.

A project’s contribution is less than cumulatively considerable if a project is required to implement or fund its fair share of mitigation measures designed to allevi ate the cumulative impact. A lead agency must identify facts and analysis supporting the lead agency’s conclusion that the cumulative impact is less than significant.

In addition, CEQA Guidelines Section 15130(b) states that the analysis of cumulative impacts shall reflect the severity of the impacts and the likelihood of occurrence, but the discussion need not provide as great of detail as provided for the effects attributable to the project alone . Instead, the discussion should be guided by the standards of practicality and reasonableness, and should focus on the cumulative impact to which the identified other projects contribute rather than the attributes of the other projects which do not contribute to the cumulative impact.

Under CEQA Guidelines Section 15065(a)(3), a project has “cumulatively considerable” or significant cumulative impacts, when its incremental effects “are significant when viewed in connection with the effects of past projects, the effects of other current projects, and the effects of probable future projects.”
For an adequate discussion of significant cumulative impacts, the CEQA Guidelines (Section 15130(b)(1)(A) and (B)) allow an EIR to determine cumulative impacts and reasonably foreseeable growth based on either of the following methods:

Cumulative impacts are anticipated impacts of the proposed project along with reasonably foreseeable growth. Reasonably foreseeable growth may be based on either:
• A list of past, present, and reasonably anticipated future projects producing related or cumulative impacts; or
• A summary of projections contained in an adopted general plan or related planning document, or in a prior environmental planning document which has been adopted or certified, which described or evaluated regional or area-wide conditions contributing to the cumulative impact.

For the Project’s cumulative impacts analysis, a list of related projects is used as the primary basis for evaluation. Consistent with CEQA Guidelines Section 15130(b)(3), the City has determined in its independent judgement, based on the size and scale of the Project analysis and related projects in the area, 1 mile is the appropriate radius applied for the identification of related projects for this Project. This distance includes a portion of the City of Los Angeles and areas within the County of Los Angeles. The list is based on information obtained from the Culver City Engineering Division and Planning Division , City of Los Angeles Department of Transportation (LADOT) , and the County of Los Angeles. The list of 12 related projects is provided in Table 3-1 , Related Projects List, with their locations identified in Figure 3-1, Related Projects Map. Of the 12 related projects, eight are located within the City of Culver City and four are located within the City of Los Angeles.

3. Environmental Setting

City of Culver City 3-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 3-1

RELATED PROJECTS LIST
No. a Location Jurisdiction Land Use Size Unit
1 b 5800 Bristol Pkwy /
5801 Hannum Ave City of Culver City Office 281,400 SF
2 6221 Bristol Pkwy City of Culver City
Residential 712 DU
Live/Work Office 50 DU
Retail 20,767 SF
3 6101 Slauson Ave City of Culver City Showroom 8,046 SF 4 6001 Centinela Ave City of Culver City Conversion of maintenance yards to burial plots - -
5 5645 Sepulveda Blvd City of Culver City
Medical Office 38,712 SF
Retail 3,193 SF
6 5840 Uplander Way City of Culver City Conversion from Office to School 16,128 SF
7 6161 Centinela Blvd City of Culver City Creative Office 281,194 SF 8 11469 Jefferson Blvd City of Culver City Hotel 183 Rooms 9 6733 Sepulveda Blvd City of Los Angeles Residential 176 DU 10 6711 Sepulveda Blvd City of Los Angeles Residential 180 DU 11 5208 Centinela Ave City of Los Angeles Restaurant 4,642 SF 12 6501 Sepulveda Blvd City of Los Angeles
Residential 362 DU
Restaurant 3,700 SF
NOTES: du = dwelling units
a Related projects list based on information from City of Culver City (January 2023), City of Los Angeles (May 2023), and the County of Los Angeles (May 2023).
b Related Project No. 1 has already been constructed. Thus, Project construction-related cumulative impacts would not occur with Related Project No. 1. Only operational cumulative impacts could occur between the Project and Related Project No. 1.

SOURCE: Gibson Transportation Consulting, 2023

Although the projects listed in Table 3 -1 serve as the primary basis for evaluation of cumulative impacts, the related projects or methodology used to address cumulative impacts may vary among certain environmental issues and topics due to their unique characteristics. The cumulative analyses for each environmental issue, including the identification of relevant related projects are provided in their applicable sections in Chapter 4, Environmental Impact Analysis, of this Draft EIR.

5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 3-1
Related Projects Map
SOURCE: Gibson Transportation Consulting, Inc., 2023Z:\Shared\Projects\2022\d202201041.01 - 5700 hannum avenue eir\05 graphics-gis-modeling-use azure\eir LEGEND
- Project Site
r ESA
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Green Valley Cir
Doverwood Dr
D
a
Howard Hughes Pkwy
D
Hannum Ave
Uplander Way
Slauson Ave
· §
/cSS
i
i
/
/
i i
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D Related Project - Culver City D Related Project - Los Angeles 0 N
Notto Scale

3. Environmental Setting

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City of Culver City 4-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CHAPTER 4
Environmental Impacts Analysis

4.0 Environmental Impacts Analysis

4.0.1 Introduction
The focus of Chapter 4 is on the potential impacts that could occur as a result of the Project . The sections included are those that have the potential to result in significant adverse impacts to the physical environment. The following sections are included in this chapter:
• Aesthetics (Section 4.1)
• Air Quality (Section 4.2)
• Cultural Resources: Archaeological Resources (Section 4.3) • Energy (Section 4.4)
• Geology and Soils - Paleontological Resources (Section 4.5) • Greenhouse Gas Emissions (Section 4.6)
• Land Use and Planning (Section 4.7)
• Noise (Section 4.8)
• Population and Housing (Section 4.9)
• Public Services: Fire Protection, Police Protection, Schools, and Parks (Sections 4.10.1 through

4.10.4)
• Transportation (Section 4.11)
• Tribal Cultural Resources (Section 4.12)
• Utilities and Service Systems: Water Supply and Energy Infrastructure (Sections 4.13.1 and

4.13.2)
Based on the Initial Study, which is contained in Appendix A-2 of this EIR , public comments received during the NOP circulation period, and input received during the EIR Scoping Meeting, it was determined that several issue areas would not be subject to significant impacts due to implementation of the Project. Generally, these issue areas include Agricultural and Forestry Resources, Air Quality (Odor), Biological Resources, Cultural Resources (Historical Resources and Human Remains), Geology and Soils (all except Paleontological Resources), Hazards and Hazardous Materials, Hydrology and Water Quality, Land Use (Physically Divide and Established Community), Mineral Resources, Public Services (Libraries), Utilities and Service Systems (Wastewater and Solid Waste), and Wildfire. Please see Subsection 6.5, Effects Found Not to be

4. Environmental Impacts Analysis

City of Culver City 4-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Significant, of Chapter 6, Other CEQA Considerations, of this Draft EIR for a discussion of those issue areas for which a detailed analysis is not included and the basis for those determinations.

4.0.2 Environmental Impact
Each section in this chapter addresses a specific environmental issue area as listed above and includes the following components:
• Existing Setting: This subsection describes the physical characteristics and existing environmental conditions within and in the vicinity of the Project area. • Regulatory Setting: This subsection presents information on the laws, regulations, plans, and policies that relate to the issue area being discussed. Regulations originating from federal, State, regional, and local levels are discussed as appropriate. • Methodology: This subsection provides a description of the methodology used for the analysis of the environmental issue addressed in the section.
• Thresholds of Significance: This subsection presents the criteria established by the Lead Agency to identify at what level an impact would be considered significant and require implementation of mitigation measures.
• Project Design Features: This subsection presents any relevant Project Design Features (PDFs) applicable to the environmental issue addressed in the section. PDFs are specific design elements or Project commitments that have been voluntarily incorporated into the Project that serve to minimize or avoid significant environmental effects. Because PDFs have been incorporated into the Project, they are accounted for in determining the significance of Project, and do not constitute mitigation measures, as defined by CEQA Guidelines Section 15126.4. However, the PDFs will be included in the Mitigation Monitoring and Reporting Program (MMRP) for the EIR to ensure their implementation is tracked and confirmed as the Project is carried out. • Analysis of Project Impacts: This subsection provides an analysis of the nature and extent of potential Project impacts. These analyses address direct (or primary) effects of the Project as well as the indirect (or secondary) impacts. This subsection also provides any mitigation measures (beyond the PDFs) used to reduce or eliminate P roject impacts that have been determined significant based on the established thresholds of significance. • Cumulative Impacts: A discussion of the effects of the Project when combined with the effects of related projects, which include other past, present and future probable projects is provided. The approach to addressing cumulative impacts, including a list of related projects, is described in Chapter 3, Environmental Setting, of this Draft EIR. • Mitigation Measures: This subsection provides mitigation measures, if necessary, to reduce significant impacts identified in the analysis of the Project. • Level of Significance after Mitigation: A discussion of the significance of each impact after mitigation is provided.

4. Environmental Impacts Analysis

City of Culver City 4-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.0.3 Terminology Used in This EIR
In evaluating the impacts of the Project, the impact is determined by applying the evaluation criteria, or threshold of significance, presented for each resource area. The following terms are used to describe the effect:
• Threshold of significance: A threshold of significance is a criterion applied by the Lead Agency to identify significant adverse environmental impacts. A threshold is defined by a Lead Agency based on guidance found in CEQA or the CEQA Guidelines, scientific and factual data relative to the Lead Agency jurisdiction, views of the public in affected areas, the policy/regulatory environment of affected jurisdictions, and other factors. • Less than significant impact: A less than significant impact does not result in a substantial, or potentially substantial, adverse change in any of the physical conditions within the area affected by the project, including land, air, water, minerals, flora, fauna, ambient noise, and objects of historic or aesthetic significance (see CEQA Guidelines Section 15382). Impacts determined to be less than significant do not require mitigation measures. • Significant impact: Public Resources Code (PRC) Section 21068 defines a significant impact as “a substantial, or potentially substantial, adverse change in the environment.” The environmental checklist included as Appendix G of the CEQA Guidelines provides additional guidance for determining which impacts would be regarded as significant. This EIR applies the thresholds contained within Appendix G and identified in each section’s “Thresholds of Significance,” and uses the CEQA definition of “significant impact.” Feasible mitigation measures or alternatives to the Project must be identified and adopted if they would avoid or substantially reduce the significant impact.
• Significant and unavoidable impact: A significant and unavoidable impact is a substantial adverse effect on the environment that cannot be avoided or mitigated to a less than significant level. A project with significant and unavoidable impacts could still proceed, but the City would be required to prepare a statement of overriding considerations, pursuant to CEQA Guidelines Section 15093, explaining what factors the City considered in approving the project notwithstanding the potential for significant environmental impacts.

As indicated above, the proposed Project includes a number of PDFs which are features or commitments voluntarily committed to as part of the Project that serve to reduce or avoid environmental impacts. PDFs are accounted for in the Draft EIR analyses prior to determining the significance of Project impacts on a given environmental issue area. Table 2-2, which is provided in Chapter 2, Project Description, of this Draft EIR provides a summary of the PDFs. The PDFs in their entirety are provided within each section of the applicable environmental issue area.

Mitigation measures are measures identified to avoid or reduce a significant impact that has been identified through environmental analysis. Mitigation measures generally include provisions for:
• Avoiding the impact by not taking a certain action or parts of an action; • Minimizing the impact by limiting the degree or magnitude of the action and its implementation; • Rectifying the impact by repairing, rehabilitating or restoring the affected environment; • Reducing or eliminating the impact over time by preservation and maintenance operations during the life of the action; and
• Compensating for the effect by replacing or providing substitute resources or environments.

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City of Culver City 4-4 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Both PDFs and mitigation measures will be adopted as part of the MMRP so that their implementation can be tracked by the City to ensure compliance.

4. Environmental Impacts Analysis

City of Culver City 4.1-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.1 Aesthetics

4.1.1 Introduction
This section provides information relative to aesthetic effects that could result from the Project and describes the existing visual setting of the Project Site and vicinity within the context of the surrounding community. This section, in addition, identifies applicable laws, regulations, guidelines and policies relating to aesthetics, and evaluates potential aesthetic impacts related to implementation of the Project.

The CEQA Guidelines specifically require the evaluation of a project’s impact s on scenic vistas, scenic resources, visual character and quality, and light and glare. These issue areas with respect to the Project are discussed and evaluated below, as applicable based on the findings of the Project’s Initial Study (see Appendix A of this Draft EIR) . Although not a CEQA requirement, this section also discusses shade/shadow effects of the Project.

4.1.2 Environmental Setting
Regulatory Framework
State
California Scenic Highways
Appendix G of the CEQA Statute & Guidelines identifies substantial damage to a scenic resource within a California Scenic Highway as a potentially significant impact on the environment. As such the regulations for the establishment and maintenance of State Scenic Highways are set forth in Streets & Highways Code, section 260 et seq. The intent of the system is to establish the State’s responsibility for the protection and enhancement of California’s natural scenic beauty by identifying those portions of the State highway system which, together with the adjacent scenic corridors, require special scenic conservation treatment. By designating scenic highways, the California Legislature assigns responsibility for the development of such scenic highways and for the establishment and application of specific planning and design standards and procedures appropriate to the location and extent of routes and areas requiring continuing and careful coordination of planning, design, construction, and regulation of land use and development, by State and local agencies, in order to protect the social and economic values provided by the State’s scenic resources. Streets & Highways Code, Section 263 establishes the system of State Scenic Highways and composes a list of the highways specified under the system. There are no State Scenic Highways within the City of Culver City. The nearest designated State Scenic Highway within the City of Los Angeles to the Project Site includes portions of the Topanga Canyon State Scenic Highway (State Route [SR] 27, between mile markers 1.0 and 3.5) whose boundaries lie within Topanga State Park and is over 1 2 miles to the northwest of the Project Site. There are eligible State Scenic Highway sections of SR-1 in Los Angeles and Santa Monica to the west, with nearest segment approximately 4 miles west of the Project Site. Note that road segments within the City of Los Angeles that are listed as “eligible” for scenic highway designation in the Scenic Highway System List, such as the Pacific Coast Highway, do not fit the CEQA criteria for State Scenic Highways.

4. Environmental Impacts Analysis

4.1. Aesthetics
City of Culver City 4.1-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
California Historic Parkways
Streets & Highways Code, Section 280 regulates the designation and maintenance of the system of California Historic Parkways. To be designated as a Historic Parkway, a freeway must have: (1) original construction completed prior to 1945; (2) features of hi storical significance as recognized by the State Office of Historic Preservation, including notable landmarks, historical sites, or natural or human achievements that exist or have occurred during the original construction of the parkway or in the immediately adjacent land area through which the parkway currently passes; (3) any portion of the highway or corridor bound on one or both sides by federal, State, or local parkland, Native American lands or monuments, or other open space, greenbelt areas, natural habitat, or wildlife preserves, or similar acreage used for or dedicated to historical or recreational uses; and (4) any portion of the highway traversed, at the time of designation and by Caltrans’s best count or estimate using existing information, by n ot less than 40,000 vehicles per day on an annual daily average basis.

No designated Historic Parkways are located in the City of Culver City. The only designated Historic Parkway, the Arroyo Seco Parkway (SR -110), is located within the City of Los Angeles.

This highway runs northeasterly from the four -level interchange with U.S. 101 just outside of downtown Los Angeles (mile post 23.69) to East Glenarm Street in the City of Pasadena (mile post

31.89).

California’s Density Bonus Law
Originally enacted in 1979, California’s Density Bonus Law (Gov. Code Sections 65915 - 65918) allows a developer to increase density on a property above the maximum set under a jurisdiction’s General Plan land use plan. In exchange for the increased density, a certain number of the new affordable dwelling units must be reserved at below market rate (BMR) rents. Qualifying applicants can also receive reductions in required development standards. Greater benefits are available for projects that reach higher percentages of affordability (with unlimited density available for certain transit-adjacent, 100-percent BMR projects).

Besides granting rights to housing and mixed-used developments to increase density, the law provides three provisions that require local governments to grant qualifying projects: 1) incentives (or concessions) that provide cost reductions; 2) waivers of development standards that would physically preclude the development of a project at the density permitted and with the incentives granted, and; 3) reductions in parking requirements. With regard to waivers of development standards pertaining to aesthetics, increases to maximum allowable height restrictions are permitted under Sections 65915(b) and 65915(d) as an incentive for the inclusion of affordable housing.

Local
Culver City General Plan
The Culver City General Plan Land Use, Circulation, and Open Space Elements include objectives and policies that address the visual environment, urban forest, urban design, and pedestrian amenities. A discussion of applicable objectives and policies is provided in the impact analysis below.

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Culver City Urban Forest Master Plan
The Culver City Urban Forest Master Plan (UFMP) was adopted in 2015 to foster a robust and resilient urban forest. The UFMP articulates a clear vision for the future of Culver City’s urban forest based on analysis of the City’s historical and existing urban forest, as well as on synthesis of current research, best management practices and community input. The Plan provides guiding principles for both long-term and day -to-day management, comprehensive tree designations, technical standards, and resources for City and community members today and for the future. The UFMP provides recommendations for the City’s urban forest as well as a structured framework of five Action Areas and related Strategies to support achievement of this vision. The recommendations also address important functions of the urban forest including wayfinding and placemaking. It also identifies a “Tree Palette” of recommended tree species for Culver City, as a process for selecting certain species for each location in the City. Areas of greatest need are described as “Places of Priority.” In the Project area, Sepulveda Boulevard south of Ballona Creek is defined as a “Place of Priority.” Along with the other recommendations related to habitat and existing conditions, the UFMP’s Tree Palette and Designations provide a plan for creating a more resilient urban forest in The UFMP designates specific tree species for both the 5700- 6099 block of Hannum Avenue and the 5800- 5899 block of Buckingham Parkway. Podocarpus gracilior is designated for Hannum Avenue and Ginkgo biloba is designated for Buckingham Parkway. The Project’s consistency with applicable policies of the UFMP are evaluated below.

Culver City Residential Parkways Standards and Guidelines The goal of the Culver City Residential Parkways Standards and Guidelines (Parkway Guidelines), adopted in 2016 is to support the creation and maintenance of parkways in Culver City that are safe, accessible, resource efficient, ecologically responsible, beautiful, and that preserve the health of City trees. A parkway is defined as the portion of a public street right-of-way lying between the curb and sidewalk . Parkway Guidelines specifically address parkways in residential areas. Trees that are located in the parkway are owned and maintained by the City. However, it is the responsibility of property owners to maintain the rest of the parkway in good condition.

Buckingham Parkway is located within the City’s residential parkways and subject to the requirements of the Parkway Guidelines.

Culver City Municipal Code
Culver City Municipal Code (CCMC) Titles 15 and 17 include regulations related to the aesthetics and visual character including landscaping, lighting, building heights, and setbacks, as described below. However, as discussed below, per CCMC Section 17.560.015.B, Comprehensive Plans set forth development standards such as height as well as landscape plans, lighting, and signage plans, which allow for flexibility in the application of zoning code standards to proposed development.

Landscaping
CCMC Section 17.310. This section of the CCMC provides landscaping regulations and standards to enhance landscaping, conserve water, provide landscape area requirements and general landscaping and irrigation requirements. CCMC Section17.310.030 requires the preparation and submittal of a Preliminary Landscape Plan and Final Landscape Plan. The Preliminary Landscape Plan includes such features as proposed and existing buildings and structures; proposed parking areas; proposed landscaped areas; a calculation of total hardscape and planted areas; and preliminary

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list of plant materials. The Final Landscape Plan identifies such features as plant materials; hardscaped and landscaped areas; water features and fences; existing and proposed buildings and structures; planting and installation details; irrigation design; and maintenance specifications.

Building Height
CCMC Section 17.240.015.E. This section provides that no building or structure in the Planned Development (PD) Zone may exceed 56 feet in height, unless a height exception is granted pursuant to § 17.300.025 (Height Measurement and Height Limit Exceptions).

CCMC Section 17.300.025.C, Exceptions to Height Limits, allows non-habitable design elements, such as spires, turrets, towers, and similar architectural features to extend up to 13 feet, 6 inches above the height of the building.

CCMC Section 17.300.035.C.1, Screening of Utilities, requires mechanical equipment (e.g., air conditioning, heating, exhaust, and ventilation ducts), loading docks, refuse and recyclable materials storage areas, and utility services to be screened from public view from adjoining public streets and rights-of-way.

CCMC Section 17.300.035.C.2 requires the method of screening to be architecturally compatible with other on-site development in terms of colors, materials, and architectural style as determined by the Director.

Lighting
CCMC Section 17.300.040, Outdoor Lighting. This section provides that exterior lighting shall comply with the following requirements:

1. All lighting fixtures shall be architecturally integrated with the character of the structure.

2. All lighting shall be energy-efficient and shielded or recessed so that direct glare and reflections are confined to the maximum extent feasible within the boundaries of the site and shall be directed downward and away from adjoining properties and public rights-of-way.

3. Permanently installed lighting shall not blink, flash, or be of unusually high intensity or brightness.

4. Timers, where acceptable, shall be used to turn off lights during hours when they are not needed.

5. Uniformity or, where appropriate, compatibility of lighting type (i.e., height, wattage, energy efficiency, base support, finish material, texture, color and style of poles and luminaires) shall be provided.

6. Landscaping and pedestrian walkway lights shall be low profile.

7. Freestanding light poles and luminaires shall not exceed a maximum height of 18 feet, or a lesser height determined by the Director, to mitigate any impacts to adjoining properties.

8. Security lighting shall be provided at all entrances/exits, except in a residential zone.

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Signage
CCMC Section 17.330, Signs, provides a comprehensive system for the regulation of signs in the City in order to address community aesthetics, vehicular and pedestrian safety, property values, and the visual environment. Section 17.330.020.B, Table 3.5, and Section 17.330.025 identify the types of signs allowed in non-residential zoning districts and the corresponding maximum sign area, maximum sign height, maximum number of signs, location, and additional requirements.

Section 17.330.030, General Requirements for All Signs, includes requirements for sign area measurement, sign height measurement, sign location requirements, aesthetic design standards, sign illumination, installation, and maintenance standards.

CCMC Section 17.330.050, Review Process and Appeals, identifies permit requirements, sign - related decisions and appeals, and other requirements for Comprehensive Sign Programs.

Art in Public Places
CCMC Section 15.06.100 et seq. establishes an Art in Public Places Program (APPP) to fund and develop cultural and artistic outlets to improve the environment, image, and character of the community. All new residential development of five or more units, and all commercial, industrial, and public building development projects, with a building valuation of $500,000 or more are subject to this requirement. The APPP allocation can be placed into a Cultural Trust Fund; used to commission original, site-specific artwork; used to donate artwork to the City; used to incorporate a Cultural Facility; or used to designate a building or portion thereof as “Architecture as Art;” as specified in this section.

Density Bonuses and Other Bonus Incentives
Chapter 17.580, Density Bonuses and Other Bonus Incentives, of the CCMC implement s the requirements of State law for density bonuses and other bonus incentives, pursuant to Cal. Gov’t Code Section 65915, or as may be amended, and the goals and policies of the Housing Element of the City ’s General Plan. Consistent with the State’s Density Bonus Law, the City allows development incentives, such as the waiver of certain development standards, for projects that provide affordable housing. With regard to waivers of development standards pertaining to aesthetics, increases to maximum allowable height restrictions are permitted under Chapter 17.580 as an incentive for the inclusion of affordable housing.

Comprehensive Plan
CCMC Section 17.560, Comprehensive Plans, provides procedures for reviewing Comprehensive Plans, which allow for flexibility in the application of Z oning Code standards to proposed development. Per the Zoning Code, a Comprehensive Plan is appropriate for large -scale development as it allows flexibility in the application of zoning code standards to encourage innovation in site planning and design and to support more effective responses to the set tings of such properties and other environmental considerations.

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City of Culver City 4.1-6 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Existing Conditions
Scenic Vistas and Scenic Resources
The Project Site is currently a component of an existing business park and is surrounded to the north (north of Hannum Avenue), south, and west by commercial buildings. The Project Site is not located in the vicinity of a City of Culver City or State-designated scenic highway. In addition, the Project Site does not contain any unique or locally recognized, natural (i.e., rock outcroppings and trees), features or designated historic buildings.1 Four-story multi-family residential uses are located to the east (east of Buckingham Parkway). The fully developed area, specifically the dense buildout of the area between Slauson Avenue and Hannum Avenue with multi -story office buildings and above grade parking garages does not provide any expansive scenic vistas, such as mountain views, views across the expansive Holy Cross Catholic Cemetery (to the north of Slauson Avenue) or views of unique urban settings across the Project Site from Hannum Avenue or Buckingham Parkway. The surrounding area is also completely developed and does not contain any natural scenic resources or historical buildings that would comprise scenic resources. For the above reasons, the Project Site and its surroundings are not a prominent component of a scenic vista as may be viewed from a distant scenic highway.

Aesthetic Character of the Project Site and Surrounding Area Aesthetic Character of the Project Site
As discussed in Chapter 2, Project Description , of this Draft EIR, the Project Site is currently occupied by an approximately 30,672 square foot two-story office building. As discussed in the Project’s historical resources memorandum prepared by Architectural Resources Group (ARG) in September 2022 for the Project (provided in Appendix B of the Initial Study) , the office building is located in the Fox Hills Business Center, a 55 -acre complex constructed between 1978 -1982.

Constructed between 1978-1980, the subject office building is a modest, vernacular office building, and one of dozens of office buildings constructed in Culver City during the late 1970s and early 1980s. While the business center represents a development of architecturally cohesive office buildings that housed a number of notable technology companies by the early 1980s, the complex is only 40 years old and is not considered a historic district, nor is the Project’s office building considered a historic resource. Generally, the office building is not considered to possess a high aesthetic value or positively contribute in a substantial manner to the aesthetic character of the area.

The remainder of the Project Site includes surface parking and associated landscaping. There are 14 carrotwood street trees along Buckingham Parkway, in addition to landscaped areas and other mature trees scattered throughout the existing surface parking lot areas. There are 119 trees on the Project Site including carrotwood, Canary Island Pine, Brazilian pepper, olive, weeping bottlebrush, paperbark, and podocarpus. The office building and surface parking uses are on relatively flat graded land, however, Buckingham Parkway slopes downward from north to south, with the northernmost elevation (at its intersection with Hannum Avenue) at approximately 128 feet and the southernmost elevation (near Windsor Way) at approximately 103 feet. Thus, the topographical street elevation decreases by approximately 25 feet from north to south. A

1 City of Culver City, Historic Preservation, https://www.culvercity.org/Explore/Arts-Culture/Preservation#section-

2. Accessed April 5, 2023.

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landscaped slope at varying widths up to approximately 50-feet wide and heights up approximately 17 feet high traverses along the Project Site’s eastern edge along Buckingham Parkway.

Aesthetic Character of the Surrounding Area
Area to the North of the Project Site
The area to the north of the Project Site between Hannum Avenue and Slauson Avenue is highly developed with a solid street frontage of multi -story office buildings and parking structures along both of these roadways. Both sides of Hannum Avenue, including along the Project Site, are lined with Podocarpus gracilior trees. The exit driveway from a two-story (above grade) and multiple below-grade stories parking structure is located directly north of the Buckingham Parkway terminus as the fourth leg of the Hannum Avenue/Buckingham Parkway intersection. Several 5- to 12-story buildings are located along Hannum Avenue between Buckingham Parkway and Bristol Parkway to the north of the Project Site. The various buildings have a variety of commercial tenants, and also include several above-ground parking structures up to at least six levels. The Holy Cross Catholic Cemetery is located directly to the north of the Antioch University building to the north of Slauson Avenue, further north of the Project Site.

Area to the East of the Project Site
Three- and four -story multi-family residential buildings are located directly to the east of the Project Site across Buckingham Parkway. Fox Hills Parkette, a deep, landscaped setback is located at the intersection of Buckingham Parkway and Hannum Avenue. The 0.33 acre landscaped open area is a passive park that tapers to a narrower parkway along Buckingham Parkway in the vicinity of Windsor Way. The park includes an open plaza area and benches for area residents. Three large, multi-family complexes built in the late 1960s and early 1970s with varied architectural styles are located between Hannum Avenue and Windsor Way and a large multi-family development built in the late 1960s is located to the south of Windsor Avenue. Buckingham Parkway, which curves in a downhill gradient to the south/southwest from Hannum Avenue, features an approximately 70- foot-wide roadway, with sidewalks, several varieties of street trees, and on-street parking.

Area to the South of the Project Site
The area directly to the south of the Project Site is a continuation of the business park in which the Project Site is a component. Buildings directly to the south/southwest are the US Veterans Affairs Department benefits office, the Hass Entertainment studios, and TOMS Corporate Offices. These are stand alone, large single- and two-story buildings with surface parking and landscaped parking lots. Developed between 1978-1982, the surrounding buildings have similar architectural elements to the exiting Project Site , including flat roofs, stone aggregate wall panels separated by smooth stucco and concrete bands and concrete block pilasters, and grouped, fixed metal windows with tinted glass. The 10-acre Fox Hills Park, which provides a grassy lawn, play yard, and tennis and basketball courts fronting Buckingham Parkway, is located to the south/southwest of the TOMS Corporate Offices building.

Area to the West of the Project Site
The area to the west of the Project Site is a continuation of the business park of which the Project Site forms the northeast corner. The entire business park, which extends to the Westfield Culver City Mall just east of the I -405 Freeway, features street trees, landscaped parking lots, uniform

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design streetlights, and underground utility lines. Uses include, for example, professional offices, corporate headquarters, light manufacturing, studios, law offices, architectural and engineering services, film studios, and research and development labs. A large business park building is located directly to the west of the Project Site. The building’s surface parking lot and loading docks are concealed within an “L” formed by the building at the back (south side) of the building. Uplander Way is located t o the west of the business park building. Uplander Way, which features an approximately 50-foot -wide roadway, sidewalks, landscaped parkways, and on -street parking begins at Hannum Avenue as a north -south street and makes a 90 degree turn to the west to terminate at Bristol Parkway. The intersection of Uplander Way and Hannum Avenue is signalized and marked with continental crosswalks, which are high visibility crosswalks consisting of wide bars spaced and placed perpendicular to the path of travel . The intersection of Uplander Way and Bristol Parkway has a single stop sign and marked (not continental) pedestrian crossing at Uplander Way. The Westfield Culver City Mall is located approximately 0.5 miles to the west of the Project Site at the west edge of the business park.

Light and Glare
The Project Site is located in an urbanized setting characterized by streetlights, stoplights, building security and architectural lighting, surface parking lot lights, vehicle lights and interior building lighting from the multi-story residential building s. The existing business park and adjacent mult i- family residential uses generate relatively low ambient light because of the absence of retail signage and other illuminated signs.

Daytime glare is generally associated with sunlight reflected from buildings with large continuous expanses of highly reflective materials. Activities that would be sensitive to daytime glare from reflected sunlight include motorists traveling on the adjacent roadways and people working in adjacent buildings. The existing buildings that are visible from the adjacent roadways and other sensitive uses are partially screened by street trees and other landscaping and do not generate substantial glare. Landscaping and trees within surface parking lots around the existing business park subdues any glare from parked vehicles. Therefore, under existing conditions, there are no notable sources of daytime glare from or around the Project Site.

Nighttime glare is associated with the degree of contrast occurring between the darkened environment and the light source, or the direct visibility of the light source. In the Project area sources of nighttime glare include streetlights, parking lot lighti ng, and car headlights. Most streetlights and parking lot lights are directed onto the surface intended to be illuminated and are not a significant source of glare. The most notable source of nighttime glare from the Project Site and area is the movement of motor vehicles on public streets or from surface parking lots. However, in the current urban setting, vehicle headlights would be set primarily at “low beam,” in which the light source is also directed to the roadway. As such, under existing conditions, there are no notable sources of nighttime glare from or around the Project Site.

Shading can occur when shade-sensitive uses are located to the north, east, or west of a tall building.

No shade sensitive uses are located to the north or west of the Project Site. However, the residential buildings, including yards, patios, balconies, courtyards, and swimming pools, to the east of Buckingham Parkway are considered to be shade sensitive areas. In addition, the Fox Hills Parkette

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could be considered a shade sensitive area, however, it is acknowledged that large street trees along Buckingham Parkway and internal trees within the central seating area, currently provide shading to much of the Parkette. The existing buildings on the Project Site do not create any shadows across Buckingham Parkway that affect the existing residential uses or Parkette across Buckingham Parkway.

4.1.3 Project Impacts
Thresholds of Significance
The following threshold of significance is based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in significant adverse impact related to aesthetics if it would:
• AES-1: In nonurbanized areas, substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). If the project is in an urbanized area, would the project conflict with applicable zoning and other regulations governing scenic quality? Potentially significant impacts related to the Project’s potential to conflict with applicable zoning and other regulations governing scenic quality are discussed and analyzed further below.

The City determined in the Initial Study that the following environmental issue areas would result in no impacts or less-than -significant impacts and, therefore, are scoped out of this Draft EIR.

Please refer to Appendix A-2 of this Draft EIR for a copy of the Initial Study and additional information regarding the following issue areas:

Would the Project:
• Have a substantial adverse effect on a scenic vista;
• Substantially damage scenic resources, including but not limited to trees, rock outcroppings, and historic buildings within a state scenic highway;
• Create a new source of substantial light or glare which would adversely affect day or nighttime views in the area?
As detailed in the Initial Study, the Project Site is located in an urbanized area, with a mix of office, business park, and residential uses in the nearby vicinity. The Project Site is not located in a scenic vista or area with protected views designated by the City. The Project Site is not located in the vicinity of a City of Culver City or State -designated scenic highway. In addition, the Project Site does not contain any unique or locally recognized, natural (i.e., rock outcroppings and trees), features or designated historic buildings which qualify as a scenic resources within a state scenic highway. The Project Site is characterized by moderate ambient nighttime lighting levels due to the developed nature of the area, existing building and parking lot on-site, as well as from adjacent properties. Similar to the existing site and surrounding uses, the Project would include low to moderate levels of interior and exterior lighting for security, parking, signage and architectural highlighting. Soft accent lighting used for signage, and architectural highlighting would be directed to permit visibility of the highlighted elements but, would not be so bright as to cause substantial

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light spillover. All proposed signage and outdoor lighting would be subject to applicable regulations contained within the CCMC and as included in the Project’s Comprehensive Plan, as applicable. Compliance with these regulations would ensure that impacts regarding Project lighting are less than significant.

Methodology
Under Threshold AES -1, for projects in nonurbanized areas, an evaluation must be made to determine if the project would substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point). Since the Project Site is in an urbanized setting, an evaluation is provided to determine whether the Project would conflict with applicable zoning and other regulations governing scenic quality . Specifically, the City of Culver City has several plans and regulations that govern scenic quality. These include the Culver City Municipal Code, the Culver City General Plan, the Culver City Urban Forest Master Plan , and the Culver City Residential Parkways Standards and Guidelines.

Importantly, a conflict between a project and an applicable plan is not necessarily a significant impact under CEQA unless the inconsistency will result in an adverse physical change to the environment that is a “significant environmental effect” as defined by CEQA Guidelines Section 15382. As provided in CEQA Guidelines Section 15126.2 “an EIR shall identify and focus on the significant effects of the proposed project on the environment.” An excerpt from the legal practice guide, Continuing Education of the Bar, Practice Under the California Environmental Quality Act, Section 12.34 illustrates the point:
“An inconsistency between a proposed project and an applicable plan is a legal determination not a physical impact on the environment. …if a project affects a river corridor, one standard for determining whether the impact is significant might be whether the project violates plan policies protecting the corridor; the environmental impact, however, is the physical impact on the river corridor.” Under the Planning and Zoning law (Government Code Section 65000 et seq.) strict conformity with all aspects of a plan is not required. Plans reflect a range of competing interests and agencies are given great deference to determine consistency with their own plans. A proposed project should be considered consistent with a general plan or elements of a general plan if it furthers one or more policies and does not obstruct other policies. Generally, a project should be compatible with a plan’s overall goals and objectives but need not be in perfect conformity with every plan policy.

To determine if the Project would conflict with such plans and regulations, the features and characteristics of the Project are compared to individual policies and regulations discussed below.

The analyses are based on the Project’s Comprehensive Plan, graphics/renderings of the Project, and descriptions of the Project in the Project Description.

In addition, although the CEQA Guidelines do not provide a threshold pertinent to shade/shadow, the analysis also takes into account the effects of shade and shadow as a visual character and quality effect. Shadow figures prepared for the Project are included as Appendix B – Shadow Study, of this Draft EIR.

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Project Design Features
The following project design feature related to aesthetics will be implemented as part of the Project:

AES-PDF-1: Screening of Utilities. Mechanical, electrical, and roof top equipment (including Heating, Ventilation, and Air Conditioning [HVAC] systems), as well as building appurtenances (such as rooftop elevator stops), will be integrated into the Project’s architectural design (e.g., placed behind parapet walls) and will be screened from view from public rights-of-way.

Analysis of Project Impacts
Threshold AES-3: In nonurbanized areas, the Project c ould have a significant impact if it w ould substantially degrade the existing visual character or quality of public views of the site and its surroundings. (Public views are those that are experienced from publicly accessible vantage point).

If the Project is in an urbanized area, the Project could have a significant impact if it would conflict with applicable zoning and other regulations governing scenic quality.

Impact Analysis
The Project is located within an urbanized area and, as such, the concern of this threshold is whether the Project would conflict with regulations that govern scenic quality. Such regulations pertinent to the Project site are set forth in the Culver City General Plan, the Culver City Urban Forest Master Plan, the Culver City Residential Parkways Standards and Guidelines, and in the CCMC . Section

4.7, Land Use and Planning, of this Draft EIR includes detailed analysis of the Project’s consistency with applicable plans and specific relevant policies governing scenic quality, which are summarized herein.

The Project would not conflict with General Plan Land Use Objective 10 (Visual Open Space) to increase visual open space through landscaping of sidewalks, and provision of a 11,378-sf internal courtyard (available to Project residents), which would be landscaped. The Project would also not conflict with Land Use Objective 11 (Urban Forest) to create a sustainable urban forest that would enhance Culver City’s image and quality of life. For the trees being removed from the Project Site, new replacement trees would be planted on the Project Site per Section 9.08.215 of the CCMC.

The Project would not conflict with Land Use Objective 12 (Urban Design) to ensure that new construction and streetscapes are accomplished with the highest quality of architectural and site design. As shown in renderings of the future buildings, including Figure 2-4 , Conceptual Project Rendering – Hannum Avenue; Figure 2 -5, Conceptual Project Rendering – Northeast Corner of Hannum Avenue and Buckingham Parkway ; Figure 2 -6, Conceptual Project Rendering – Buckingham Parkway; Figure 2-12, North and West Elevations; Figure 2-13, East Elevation; and Figure 2-14, South Elevation, in Chapter 2, Project Description, of this Draft EIR, the Project would change the character and quality of the existing office building and parking lot site with a new, modern high-quality architecturally design building. The Project is proposing a contemporary architectural design defined by simple lines, along with a neutral and unified color palette. The first story of the building would be buffered from the sidewalks by landscaped planters along Buckingham Parkway, as shown in Figure 2 -8, C onceptual Project Rendering – Looking North along

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Buckingham Parkway. The Project design includes a curved facade along Buckingham Parkway and a distinct architectural volume anchoring the corner of Hannum Avenue and Buckingham Parkway as shown in Figure 2 -6, Conceptual Project Rendering – Northeast Corner of Hannum Avenue and Buckingham Parkway and Figure 2-7, Conceptual Project Rendering – Looking West from Fox Hills Parkette. At the ground level, the corner retail component would include storefront glazing and a covered outdoor patio. Floating above the double height space, the facade would include textured corrugated and flat panels with large windows for the units. On the sixth floor, the building would become more transparent with a broad canopy and vertical fins framing the amenity deck.

A tripartite scheme along Buckingham Parkway would punctuate the massing along the longer lengths of the site to create a varied visual effect and break up the buildings’ sense of mass. The middle portion of the building is defined as a solid frame with semi -recessed unit balconies and inset panels with windows. Along Buckingham Parkway, the top floor would be set back 29 to 40 feet with large unit patios and an expansive amenity deck with views out towards the hills, with a pool, lounge seating and smaller gathering spaces. The exterior overhangs would provide for shading and cooling of the buildings’ common area interiors, as well as contributing to the visual character of the Project. A large opening into the second -floor courtyard would divide the Buckingham Parkway facing facade into two separate masses while also providing more light and air into the courtyard. Another large opening in the frame closer to Hannum Avenue would provide a view into the courtyard. Units with front stoops would line the ground level facade along Buckingham Parkway, providing direct access to the street and planted areas in between patios, similar to the residential uses across Buckingham Parkway. As noted above, under CCMC Section

17.560.015.B, the Comprehensive Plan sets forth development standards including setbacks. The Project would follow Project-specific development standards (including setbacks) as provided in the Comprehensive Plan. The Comprehensive Plan includes 0 foot setback standards at the ground level and five-feet above the ground level along both Hannum Avenue and Buckingham Parkway.

However, the Project aims to activate the ground level with pedestrian oriented design to enhance the neighborhood, as the area currently has minimal streetscape improvements. The first floor along Hannum Avenue would be setback between 20 - to 35-feet to create a public plaza (the Hannum Plaza) with landscaping and a variety of seating areas open to the community. Along Buckingham Parkway, as well as the southern and western boundaries, the building would be set back at least 10-feet from the property line. The Project would also not conflict with Open Space Element Objective 3 (Passive Recreation) by providing 7,507 sf of publicly accessible, privately maintained open space with direct access off Hannum Avenue , where it would have ready access to visitors from surrounding land uses, pedestrians, and cyclists.

As discussed in Section 4. 7, Land Use and Planning, of this Draft EIR, the Project would not conflict with the policies of the UFMP. The Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza, located along Hannum Avenue . In addition, new replacement trees would be planted on the Project Site per Section 9.08.215 of the CCMC .

The selected street tree species would meet the UFMP Tree Palette as and meet the UFMP’s performance criteria.

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Under CCMC Section 17.2 20.020, Table 2-7 , building setback requirements for Commercial Regional Business Park (CRB) zone are 5 feet at the front yard (which apply to both Hannum Avenue and Buckingham Parkway) with no side yard or rear yard building setback requirements.

As noted above, under CCMC Section 17.560.015.B, the Comprehensive Plan sets forth development standards including setbacks. The Project would follow Project- specific development standards (including setbacks) as provided in the Comprehensiv e Plan. The Comprehensive Plan includes minimum setback development standards of 0-feet at the ground level and five-feet above the ground level along both Hannum Avenue and Buckingham Parkway.

However, the Project aims to activate the ground level with pedestrian oriented design to enhance the neighborhood, as the area currently has minimal streetscape improvements. The first floor along Hannum Avenue would be setback between 10- to 35- feet to create a public plaza with landscaping and a variety of seating areas open to the community. Along Buckingham Parkway, as well as the southern and western boundaries, the building would be set back at least 10 -feet from the property line. With the provision of the Comprehensive Plan, the Project would be consistent with the current setback criterion.

In order to provide a n aesthetically succinct and unified development, the Project is seeking to redevelop the Project Site under the PD zone. CCMC Sections 17.240.010 and 17.240.015 describe the purpose and requirements of the PD Zoning District as allowing large scale commercial complexes within a physically integrated and contiguous area. Within the PD zone, no building may exceed 56 feet in height. However, the Project is proposing to include 27 units (12 percent of base density) of its residential units as Very Low Income affordable units. By doing so, consistent with the CCMC, State Density Bonus Law (Gov’t Code §65915), the Project is entitled to receive development incentives including a height increase. The Project is requesting a height increase of 22 feet beyond the maximum allowable height as a development incentive for providing affordable units. With this incentive, the Project would have a maximum building height of 78 feet. Even with this height increase, given that no views of scenic vistas or scenic resources occur across or through the Project Site, the Project would not substantially alter scenic views from surrounding areas.

CCMC Section 17.300.035.C.1 requires the screening of utilities, including mechanical equipment (e.g., air conditioning, heating, exhaust, and ventilation ducts), loading docks, refuse and recyclable materials storage areas, and utility services, from public view from adjoining public streets and rights-of-way. CCMC Section 17.300.035.C.2 requires the method of screening to be architecturally compatible with other on -site development in terms of colors, materials, and architectural style as determined by the Director. The Project would screen all utilities from public view. Any utilities located on the building roof would be screened by fencing, the design of which would be coordinated with the building’s architectural materials, color, and design. This regulation would be further implemented under Project Design Feature AES -PDF-1, which requires mechanical, electrical, and roof top equipment [including heating, ventilation, and air conditioning (HVAC) systems], as well as building appurtenances, to be integr ated into the Project’s architectural design (e.g., placed behind parapet walls) and will be screened from view from public rights-of-way. Plans related to rooftop screening would be submitted to the current Planning Division for review. Other utility areas, such as refuse and recyclable storage loading areas would be located in the parking garage and would not be visible from the public streets and highways.

4. Environmental Impacts Analysis

4.1. Aesthetics
City of Culver City 4.1-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
CCMC Section 15.06.100.A (Art in Public Places) requires the inclusion of visual artwork, performing and architectural resources to enhance the quality of life for individuals living in, working in, and visiting the City. The Project would feature high quality architecture, distinguished by a curved facade along Buckingham Parkway and a distinct architectural volume anchoring the corner of Hannum Avenue and Buckingham Parkway; street -accessible and inviting main entrances; coordinated use of building materials and structural design; and neutral and unified color palette with textured corrugated and flat panels with large windows for the units , thus, resulting in distinctive and creative building exteriors. The Project would provide public art or pay in lieu fees for public art to the City’s requirements. With compliance with CCMC re gulations that govern scenic character, such as building heights, setbacks, and screening, the Project would not conflict with the policies of the CCMC that regulate scenic quality.

Based on the above, the Project would not conflict with zoning and other regulations governing scenic quality. Therefore, impacts would be less than significant.

Supplemental Shading Analysis
Potential shading effects could occur when shadow -sensitive uses are located in proximity to new structures. The potential for shading is highest when a shadow -sensitive use is immediately adjacent to a new structure and decreases the further the sensitive use is located from a Project Site.

Facilities and operations sensitive to the effects of shading include routinely useable outdoor spaces associated with residential, recreational, or institutional (e.g., schools, convalescent homes) land uses; commercial uses such as pedestrian -oriented outdoor spaces or restaurants with outdoor eating areas; nurseries; and existing solar collectors. These uses are considered sensitive because sunlight is important to function, physical comfort, or commerce. As the sun moves from the east to the west throughout the day, shadow lengths and direction move accordingly. Shadows are longest during the winter, with the maximum length occurring during the Winter Solstice (December 22). During the spring, fall, and summer, shadow lengths are shorter than winter shadows. The maximum shadow lengths during the spring, fall , and summer are approximately

2.18 times the height of a building.
2 The Project would be up to 78 feet tall.3 As such, it could cast a maximum shadow of approximately 170 feet during the spring, fall, and summer.

Shadow sensitive uses that could potentially be affected by Project shadows during these times of the year are the routinely usable outdoor spaces associated with the multi-family residential uses and the Fox Hills Parkette to the east across Buckingham Parkway. These properties are located approximately 50 feet from the Project at their closest point.

Project shadows are illustrated in Appendix B of this Draft EIR, and are shown during the Winter Solstice, Summer Solstice and Fall/Spring Equinox between the hours of 10:00 A.M. and 4:00 P.M.

The shadows figure identifies that the Project would add no shading on any shade sensitive uses to the west, north, or south of the Project Site. During the Summer Solstice, Project shadows would

2 City of Los Angeles, L.A. CEQA Thresholds Guide, Exhibit A.3-1, 2006. Exhibit A 3-1 is sourced to Planning Consultants Research, 1995.
3 The height of the along the north property line adjacent to Hannum Avenue, would be 70 feet and up to 78 feet at the south property line along Buckingham Parkway due to the existing site topography. Although the bulkhead would rise to a height of 78 feet, it would be substantially set back from the edges of the building and would not contribute to shadow length.

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4.1. Aesthetics
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not extend across Buckingham Parkway to the east . During the Sprin g/Fall Equinox, shadows would not reach the residential properties across Buckingham, but would extend minimally into the western portion of Fox Hills Parkette along Buckingham Parkway after approximately 3:00 P.M.

However, the existing street trees and Parkette trees already shade the majority of this area, so there would be only an incremental change in shading to the Parkette during these late afternoon hours of the Spring/Fall Equinox. During the Winter Solstice, shadows would reach only a small, landscaped area just south of Cambridge Way near the adjacent residential properties across Buckingham Parkway after approximately 3:00 P.M. No portion of any individual residential property would be shaded by the Project. Also, after approximately 3:00, the Fox Hills Parkette would be entirely shaded by the Project. However, the existing street trees and Parkette trees already shade the majority of the Parkette at this time of year and the sun sets at roughly 5:00 P.M., so there would be only an incremental change in shading to the Parkette during these late afternoon hours of the Winter Solstice.

Based on the above, the Project would add limited incremental shadows to the Fox Hills Parkette during the winter season in the afternoon hours, and not shade any portion of the residential uses across Buckingham Parkway year around. Given the Project’s limited shading of off-site routinely usable outdoor spaces, shading would not be an adverse effect of the Project's implementation.

Mitigation Measures
No mitigation measures are required as impacts would be less than significant.

Level of Significance After Mitigation
Not applicable. Project -specific impacts related to conflicts with applicable zoning and other regulations governing scenic quality would be less than significant.

Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR, provides the list of the 1 2 related projects planned or are under construction within an approximately 1.0-mile radius of the Project Site . Of these 12 related projects, eight (8) are located within the City of Culver City and four (4) are located within the City of Los Angeles. These projects are summarized in Table 3-1, Related Projects List, and shown on Figure 3-1, Related Projects Map, in Chapter 3.

The related projects list primarily reflects infill development within existing, built out Culver City and Los Angeles communities. As such, the related projects contribute to a variety of local urban settings with varied aesthetic characteristics. The majority of the related projects are located in different viewsheds from the Project when viewed at the pedestrian level within the flatter, urban area, and thus do not allow for panoramic views of the area. From more distant locations at higher elevations, the related projects and Project would contribute cumulatively to visual changes in the area’s urban composition. Project 1 located along Hannum Avenue west of the Project Site would be visible from the Project. Areas east of the Project Site could potentially have views of the Project and related Project 1. However, views, if any, would be very limited and largely obscured by the Project, topographical variations and/or intervening development. A ny such views would not obstruct views of a scenic vista or scenic resource within a state designated scenic highway. Further,

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any such combined views would not substantially change the urbanized nature of the view together with the Project and its surroundings.

Related projects, as with the Project, are expected to comply with regulations governing scenic quality, including CCMC regulations regarding street trees, exterior lighting, and illuminated signage, as applicable, as well as building height, setbacks, open space, lot coverage, and landscaping requirements. Additionally, the related projects would be required, as applicable, to demonstrate compliance with other plans governing scenic quality, which may include, but are not limited to the following: Culver City General Plan, the Culver City Redevelopment Plan, the Culver City Urban Forest Master Plan, and the Citywide Design Guidelines.

Because the Project and related projects would be required to comply with applicable policies and regulations governing scenic quality, the Project and related projects would not cumulatively conflict with policies and regulations governing scenic quality. Therefore, cumulative impacts with respect to regulations governing scenic quality would be less than significant.

Mitigation Measures
No mitigation measures are required as impacts would be less than significant.

Level of Significance After Mitigation
Not applicable. Cumulative impacts related to aesthetics would be less than significant.

4. Environmental Impacts Analysis

City of Culver City 4.2-1 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.2 Air Quality

4.2.1 Introduction
This section evaluates the Project’s potential air quality impacts, including potential cumulative impacts generated by construction and operation of the Project. This section estimates the air pollutant emissions generated by Project construction and oper ation and assesses whether Project emissions would conflict with or obstruct implementation of the air quality policies set forth within the South Coast Air Quality Management District’s (SCAQMD) Air Quality Management Plan (AQMP); result in a cumulatively considerable net increase of any criteria pollutant in non - attainment of federal or State ambient air quality standard; or, expose sensitive receptors to substantial pollutant concentrations. This section relies on the information, data, assumptions, calculation worksheets, and model outputs are provided in Appendix C of this Draft EIR.

4.2.2 Environmental Setting
Air Quality Background
Air Quality and Public Health
Certain air pollutants have been recognized to cause notable health problems and consequential damage to the environment either directly or in reaction with other pollutants, due to their presence in elevated concentrations in the atmosphere. Such pollutants have been identified and regulated as part of an overall endeavor to prevent further deterioration and to facilitate improvement in air quality.

The National Ambient Air Quality Standards (NAAQS ) and California Ambient Air Quality Standards (CAAQS) have been set at levels considered safe to protect public health, including the health of sensitive populations such as asthmatics, children, and the elderly with a margin of safety, and to protect public welfare, including protection against decreased visibility and damage to animals, crops, vegetation, and buildings.
1 As the scientific methods for the study of air pollution health effects have progressed over the past decades, adverse effects have been shown to occur at lower levels of exposure. For some pollutants, no clear thresholds for effects have been demonstrated. New findings over time have, in turn, led to the revision and lowering of NAAQS which, in the judgment of the U.S. Environmental Protection Agency (USEPA), are necessary to protect public health. Ongoing assessments of the scientific evidence from health studies continue to be an important part of setting and informing revisions to federal and state air quality standards. 2 The NAAQS and CAAQS are
listed in Table 4.2-1 in the Regulatory Framework subsection.

At the regional level, the SCAQMD is the regulatory agency responsible for improving air quality for large areas of Los Angeles, Orange County, Riverside and San Bernardino Counties, including the Coachella Valley. 3 Culver City is located within the South Coast Air Basin (Air Basin) which is a distinct geographic subarea within the SCAQMD’s jurisdiction. The SCAQMD, together with the Southern California Association of Governments (SCAG ), has the

1 USEPA, NAAQS Table, https://www.epa.gov/criteria-air-pollutants/naaqs-table. Accessed October 30, 2023. 2 South Coast Air Quality Management District (SCAQMD), 2022 Air Quality Management Plan, 2022.

Appendix I-154.
3 SCAQMD, Map of Jurisdiction, 1999.

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City of Culver City 4.2-2 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
responsibility for ensuring that national and State ambient air quality standards are achieved and maintained for the Air Basin. Failure to comply with these standards puts State and local agencies at risk for penalties in the form of lawsuits, fines, a federal takeover of state implementation plans, and a loss of funds from federal agencies such as the Federal Highway Administration and Federal Transit Administration.

To meet the air quality standards, regional plans are developed, including the SCAQMD’s AQMP, w
hich incorporates regional demographic projections and integrated regional land use and transportation strategies from SCAG’s 2020- 2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), known as Connect SoCal. These plans work together to examine multiple pollutants, cumulative effects, and transport issues related to attaining healthful air quality in the region. In addition, a host of regulatory standards at the federal, State, regional, and local level function to identify and limit exposure of air pollutants and toxic air contaminants (TACs).

Local Air Quality and Air Pollution Sources
As mentioned previously, Culver City is located South Coast Air Basin, which is an approximately 6,745-square-mile area bounded by the Pacific Ocean to the west; the San Gabriel, San Bernardino, and San Jacinto Mountains to the north and east; and San Diego County to the south. The Air Basin includes all of Orange County and the non-desert portions of Los Angeles, Riverside, and San Bernardino Counties, in addition to the Coachella Valley area in Riverside County. The regional climate within the Air Basin is considered semi -arid and is characterized by warm summers, mild winters, infrequent seasonal rainfall, moderate daytime onshore breezes, and moderate humidity.

The air quality within the Air Basin is primarily influenced by meteorology and a wide range of emissions sources, such as dense population centers, heavy vehicular traffic, and industry.

The Air Basin experiences a persistent temperature inversion (increasing temperature with increasing altitude) as a result of the Pacific high. This inversion limits the vertical dispersion of air contaminants, holding them relatively near the ground. As the sun warms the ground and the lower air layer, the temperature of the lower air layer approaches the temperature of the base of the inversion (upper) layer until the inversion layer finally breaks, allowing vertical mixing with the lower layer. This phen omenon is observed in mid to late afternoons on hot summer days. Winter inversions frequently break by midmorning.

The combination of stagnant wind conditions and low inversions produces the greatest pollutant concentrations. On days of no inversion or high wind speeds, ambient air pollutant concentrations are lowest. During periods of low inversions and low wind speeds, air pollutants generated in urbanized areas are transported predominantly onshore into Riverside and San Bernardino Counties. In the winter, the greatest pollution problem is the accumulation of carbon monoxide (CO) and nitrogen oxides (NO
X) due to low inversions and air stagnation during the night and early morning hours. In the summer, the longer daylight hours and the brighter sunshine combine to cause a reaction between hydrocarbons and NO
X to form photochemical smog.

Air pollutant emissions within the Air Basin are generated primarily by stationary and mobile sources. Stationary sources can be divided into two major subcategories: point and area sources.

Point sources occur at a specific location and are often identifi ed by an exhaust vent or stack.

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City of Culver City 4.2-3 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Examples include boilers or combustion equipment that produce electricity or generate heat. Area sources are widely distributed and include such sources as residential and commercial water heaters, painting operations, lawn mowers, agricultural fields, landfills, and some consumer products. Mobile sources refer to emissions from motor vehicles, including tailpipe and evaporative emissions, and are classified as either on-road or off-road. On-road sources may be legally operated on roadways and highways. Off -road sources include aircraft, ships, trains, and self -propelled construction equipment. Air pollutants can also be generated by the natural environment, such as when high winds suspend fine dust particles.

Air Pollutant Types
Criteria Pollutants
The six principal pollutants for which national and State criteria and standards have been promulgated, known as “criteria pollutants”, and which are most relevant to current air quality planning and regulation in the Air Basin include O
3, respirable and fine particulate matter (PM 10
and PM2.5, respectively), carbon monoxide (CO), nitrogen dioxide (NO 2), sulfur dioxide (SO 2), and lead (Pb). These pollutants are referred to as “criteria air pollutants” as a result of the specific standards, or criteria, which have been adopted for them.

Ozone (O3): Ozone is a gas that is formed when volatile organic compounds (VOCs) and NO X - both byproducts of internal combustion engine exhaust - undergo slow photochemical reactions in the presence of sunlight. O3 concentrations are generally highest during the summer months when direct sunlight, light wind, and warm temperature conditions are favorable. An elevated level of O3 irritates the lungs and breathing passages, causing coughing and pain in the chest and throat, thereby increasing susceptibility to respiratory infections and reducing the ability to exercise. Effects are more severe in people with asthma and other respiratory ailments. Long -term exposure may lead to scarring of lung tissue and may lower lung efficiency.

Particulate Matter (PM10 and PM2.5): Particulate matter pollution consists of very small liquid and solid particles floating in the air, which can include smoke, soot, dust, salts, acids, and metals.

Particulate matter can form when gases emitted from industries and motor vehicles undergo chemical reactions in the atmosphere. Respirable and fine particulate matter, PM 10 and PM2.5, consist of extremely small, suspended particles or droplets 10 microns and 2.5 microns or smaller in diameter, respectively. Som e sources of particulate matter, such as pollen and windstorms, are naturally occurring. However, in dense urban areas, such as the City of Culver City most particulate matter is caused by road dust, diesel soot, combustion products, abrasion of tires and brakes, and construction activities. The human body naturally prevents the entry of larger particles into the body. However, small particles can enter the body and become trapped in the nose, throat, and upper respiratory tract. These small particulates can potentially aggravate existing heart and lung diseases, change the body’s defenses against inhaled materials, and damage lung tissue. The elderly, children, and those with chronic lung or heart disease are most sensitive to PM 10 and PM2.5. Lung impairment can persist for two to three weeks after exposure to high levels of particulate matter. Some types of particulates can become toxic after inhalation due to the presence of certain chemicals and their reaction with internal body fluids.

4. Environmental Impacts Analysis

4.2. Air Quality
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Carbon Monoxide (CO): Carbon monoxide (CO) is a colorless, odorless gas primarily emitted from combustion processes and motor vehicles due to incomplete combustion of carbon-containing fuels, such as gasoline or wood. In dense urban areas, such as Culver City where the Project is located, automobile exhaust accounts for the majority of CO emissions. CO concentrations tend to be the highest during the winter morning, when little to no wind and surface-based inversions trap the pollutant at ground levels. Bec ause CO is emitted directly from internal combustion engines, unlike O3, motor vehicles operating at slow speeds are the primary source of CO in the Air Basin.

The highest ambient CO concentrations are generally found near congested transportation corridors and intersections. Elevated concentrations of CO weaken the heart’s contractions and lower the amount of oxygen carried by the blood. It is especially dangerous for people with chronic heart disease. Inhalation of CO can cause nausea, dizziness, and headaches at moderate concentrations and can be fatal at high concentrations.

Nitrogen Dioxide (NO
2) and Nitrogen Oxides (NOX): NO2 is a nitrogen oxide compound that is produced by the combustion of fossil fuels, such as in internal combustion engines (both gasoline and diesel powered), as well as point sources, especially power plants. Of the seven types of NO X compounds, NO2 is the most abundant in the atmosphere. As ambient concentrations of NO 2 are related to traffic density, commuters in heavy traffic areas, particularly in dense urban areas, such as where the Project is located, may be exposed to higher concentrations of NO 2 than those
indicated by regional monitors. NO 2 absorbs blue light and results in a brownish-red cast to the atmosphere and reduced visibility. NO2 also contributes to the formation of PM10. NOX irritate the nose and throat, and increase one’s susceptibility to respiratory infections, especially in people with asthma. The principal concern of NO
X is as a precursor to the formation of O3.

Sulfur Dioxide (SO2): Sulfur oxides (SOX) are compounds of sulfur and oxygen molecules. SO 2 is the predominant form found in the lower atmosphere and is a product of burning sulfur or burning materials that contain sulfur. Major sources of SO
2 include power plants, large industrial facilities,
diesel vehicles, and oil-burning residential heaters. Generally, the highest levels of SO 2 are found near large industrial complexes. In recent years, SO 2 concentrations have been reduced by the increasingly stringent controls placed on stationary source emissions of SO2 and limits on the sulfur content of fuels. Emissions of SO2 aggravate lung diseases, especially bronchitis. It also constricts the breathing passages, especially in asthmatics and people involved in moderate to heavy exercise.

SO
2 potentially causes wheezing, shortness of breath, and coughing. High levels of particulates appear to worsen the effect of SO2, and long-term exposures to both pollutants leads to higher rates of respiratory illness.

Lead (Pb): Pb is a metal found naturally in the environment as well as in manufactured products.

The highest levels of Pb in air are usually found near Pb smelters. The major sources of Pb emissions to the air are ore and metals processing and piston -engine aircraft operating on leaded aviation gasoline. Pb is also emitted from the sanding or removal of old lead-based paint (LBP). Pb emissions are primarily a regional pollutant. Pb affects the brain and other parts of the body’s nervous system. Exposure to Pb in very young children impairs the development of the nervous system, kidneys, and blood forming processes in the body.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-5 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Additional Criteria Pollutants (California Only)
In addition to the national standards, the State of California regulates State -identified criteria pollutants, including sulfates (SO42), hydrogen sulfide (H2S), visibility-reducing particles, and vinyl chloride. With respect to the State-identified criteria pollutants, most land use development projects either do not emit them (i.e., H 2S [nuisance odor ] and vinyl chloride), or otherwise account for these pollutants (i.e., SO 42and visibility reducing particles) through other criteria pollutants. For example, SO42are associated with SO X emissions, and visibility-reducing particles are associated with particulate matter emissions. A description of the health effects of the State-identified criteria air pollutants is provided below.

Sulfates (SO42): SO42 are the fully oxidized ionic form of sulfur. SO42 occur in combination with metal and/or hydrogen ions. In California, emissions of sulfur compounds occur primarily from the combustion of petroleum -derived fuels (e.g., gasoline and diesel fuel) that contain sulfur. This sulfur is oxidized during the combustion process and subsequently converted to SO 42 in the
atmosphere. Effects of sulfate exposure at levels above the standard include a decrease in ventilatory function, aggravation of asthmatic symptoms, and an increased risk of cardio- pulmonary disease. SO
42 are particularly effective in degrading visibility, and, due to the fact that they are usually acidic, can harm ecosystems and damage materials and property.

Hydrogen Sulfide (H2S): H2S is a colorless gas with the odor of rotten eggs. The most common sources of H2S emissions are oil and natural gas extraction and processing, and natural emissions from geothermal fields. Industrial sources of H 2S include petrochemical plants and kraft paper mills. H 2S is also formed during bacterial decomposition of human and animal wastes, and is present in emissions from sewage treatment facilities and landfills. 4 Exposure to H2S can induce tearing of the eyes and symptoms related to overstimulation of the sense of smell, including headache, nausea, or vomiting; additional health effects of eye irritation have only been reported with exposures greater than 50 parts per million (ppm), which is considerably higher than the odor threshold.
5 H2S is regulated as a nuisance based on its odor detection level; if the standard were based on adverse health effects, it would be set at a much higher level.6 Visibility-Reducing Particles: Visibility-reducing particles come from a variety of natural and manmade sources and can vary greatly in shape, size and chemical composition. Visibility reduction is caused by the absorption and scattering of light by the particles in the atmosphere before it reaches the observer. Certain visibility-reducing particles are directly emitted to the air, such as windblown dust and soot, while others are formed in the atmosphere through chemical transformations of gaseous pollutants (e.g., SO
42, nitrates, organic carbon particles) which are the
major constituents of particulate matter. As the number of visibility-reducing particles increases, more light is absorbed and scattered, resulting in less clarity, color, and visual range. 7 Exposure to

4 CARB, Hydrogen Sulfide & Health, https://ww2.arb.ca.gov/resources/hydrogen-sulfide-and-health. Accessed October 30, 2023.
5 CARB, Hydrogen Sulfide & Health, https://ww2.arb.ca.gov/resources/hydrogen-sulfide-and-health. Accessed October 30, 2023.
6 CARB, Hydrogen Sulfide & Health, https://ww2.arb.ca.gov/resources/hydrogen-sulfide-and-health. Accessed October 30, 2023.
7 CARB, Visibility-Reducing Particles & Health. Last reviewed https://ww2.arb.ca.gov/resources/visibility-reducing- particles-and-health. Accessed October 30, 2023

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some haze-causing pollutants have been linked to adverse health impacts similar to PM 10 and PM2.5, as discussed above.8
Vinyl Chloride: Vinyl chloride is a colorless gas with a mild, sweet odor. Most vinyl chloride is used to make polyvinyl chloride (PVC) plastic and vinyl products and is generally emitted from industrial processes. Other major sources of vinyl chloride have been detected near landfills, sewage plants, and hazardous waste sites, due to microbial breakdown of chlorinated solvents. 9 Short-term health effects of exposure to high levels of vinyl chloride in the air include central nervous system effects, such as dizziness, drowsiness, and headaches while long-term exposure to vinyl chloride through inhalation and oral exposure causes liver damage and has been shown to increase the risk of angiosarcoma, a rare form of liver cancer in humans. 10 Most health data on
vinyl chloride relate to carcinogenicity and control methodologies applied to industrial facilities generally prevent emissions to the ambient air. There are no known sources of vinyl chloride emissions outside of occupational or industrial settings. 11 Volatile Organic Compounds and Toxic Air Contaminants Although the SCAQMD’s primary mandate is attaining the NAAQS and the CAAQS for criteria pollutants within the Air Basin, SCAQMD also has a general responsibility to control emissions of air contaminants and prevent endangerment to public health. As a result, the SCAQMD has regulated pollutants other than criteria pollutants such as VOCs, TACs, greenhouse gases (GHGs), and stratospheric O
3-depleting compounds.

VOCs: VOCs are organic chemical compounds of carbon and are not “criteria” pollutants themselves; however, VOCs are a prime component (along with NO X) of the photochemical processes by which such criteria pollutants as O3, NO2, and certain fine particles are formed. They are therefore regulated as “precursors” to formation of these criteria pollutants. Some are also identified as TACs and have adverse health effects. VOCs are typically formed from combustion of fuels and/or released through evaporation of organic liquids, internal combustion associated with motor vehicle usage, and consumer products (e.g., architectural coatings).

TACs: TACs is a term used to describe airborne pollutants that may be expected to result in an increase in mortality or serious illness or which may pose a present or potential hazard to human health, and includes both carcinogens and non- carcinogens. The California Air Resources Board (CARB) and the California Office of Environmental Health Hazard Assessment ( OEHHA) determine if a substance should be formally identified, or “listed,” as a TAC in California. CARB has listed approximately 200 toxic substances, including those identified by the USEPA, which are identified on the California Air Toxics Program’s TAC List. TACs are also not classified as “criteria” air pollutants. The greatest potential for TAC emissions during construction is related to

8 CARB, Visibility-Reducing Particles & Health. Last reviewed https://ww2.arb.ca.gov/resources/visibility-reducing- particles-and-health. Accessed October 30, 2023
9 CARB, Visibility-Reducing Particles & Health. Last reviewed https://ww2.arb.ca.gov/resources/visibility-reducing- particles-and-health. Accessed October 30, 2023
10 CARB, Vinyl Chloride & Health, https://ww2.arb.ca.gov/resources/vinyl-chloride-and-health. Accessed October 30, 2023.
11 CARB, Vinyl Chloride & Health, https://ww2.arb.ca.gov/resources/vinyl-chloride-and-health. Accessed October 30, 2023.

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diesel particulate matter (DPM) emissions associated with heavy-duty equipment. During long-term operations, sources of DPM may include heavy duty diesel -fueled delivery trucks and stationary emergency generators. The effects of TACs can be diverse and their health impacts tend to be local rather than regional; consequently ambient air quality standards for these pollutants have not been established, and analysis of health effects is instead based on cancer risk and exposure levels.

Regulatory Framework
Federal
Federal Clean Air Act
The Federal Clean Air Act (CAA) was enacted in 1970 and has been amended numerous times in subsequent years, with the latest amendments occurring in 1990. 12 The CAA is the comprehensive
federal law that regulates air emissions in order to protect public health and welfare.13 The USEPA is responsible for the implementation and enforcement of the CAA, which establishes NAAQS, specifies future dates for achieving compliance, and requires the USEPA to designate areas as attainment, nonattainment, or maintenance. The CAA also mandates that each state submit and implement a State Implementation Plan (SIP) for each criteria pollutant for which the state has not achieved the applicable NAAQS. The SIP includes pollution control measures that demonstrate how the standards for those pollutants will be met. The sections of the CAA most applicable to land use development projects include Title I (Nonattainment Provisions) and Title II (Mobile Source Provisions).
14 Title I requirements are implemented for the purpose of attaining NAAQS for criteria air pollutants.

Table 4.2-1, Ambient Air Quality Standards, shows the NAAQS currently in effect for each criteria air pollutant. The Air Basin fails to meet national standards for O3 and PM2.5 and, therefore, is considered a federal “non-attainment” area for these pollutants.

Title II pertains to mobile sources, which includes on-road vehicles (e.g., cars, buses, motorcycles) and non-road vehicles (e.g. , aircraft, trains, construction equipment). Reformulated gasoline and automobile pollution control devices are examples of the mechanisms the USEPA uses to regulate mobile air emission sources. The provisions of Title II have resulted in tailpipe emission standards for vehicles, which have been strengthened in recent years to improve air quality. For example, the standards for NO
X emissions have been lowered substantially and the specification requirements for cleaner burning gasoline are more stringent.

The NAAQS, and the CAAQS for the California criteria air pollutants (discussed below), have been set at levels considered safe to protect public health, including the health of sensitive populations and to protect public welfare.

12 42 United States Code Section 7401 et seq. (1970).
13 USEPA, Clean Air Act, 1963.
14 USEPA, Clean Air Act Overview, Clean Air Act Table of Contents by Title, Last Updated January 3, 2017.

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City of Culver City 4.2-8 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.2-1

AMBIENT AIR QUALITY STANDARDS
Pollutant
Averaging
Period
Federal
Standarda,b
California
Standarda,b
South Coast Air Basin Attainment Statusc
Federal Standardd California Standardd
Ozone (O3) 1-hour — 0.09 ppm
(180 μg/m3)
— Non-Attainment
8-hour 0.070 ppm
(137 μg/m3)

0.07 ppm
(137 μg/m3)
Non-Attainment
(Extreme)
Non-Attainment
Respirable Particulate
Matter (PM10)
24-hour 150 μg/m3 50 μg/m3 Attainment Non-Attainment
Annual — 20 μg/m3
Fine Particulate Matter
(PM2.5)
24-hour 35 μg/m3 — Non-Attainment
(Serious)
Non-Attainment
Annual 12 μg/m3 12 μg/m3
Carbon Monoxide (CO) 1-hour 35 ppm
(40 mg/m3)
20 ppm
(23 mg/m3)
Attainment Attainment
8-hour 9 ppm
(10 mg/m3)

9.0 ppm
(10 mg/m3)
Nitrogen Dioxide (NO2) 1-hour 0.10 ppm
(188 μg/m3)

0.18 ppm
(339 μg/m3)
Unclassified/
Attainment
Attainment
Annual 0.053 ppm
(100 μg/m3)

0.030 ppm
(57 μg/m3)
Sulfur Dioxide (SO2) 1-hour 0.075 ppm
(196 μg/m3)

0.25 ppm
(655 μg/m3)
Unclassified/
Attainment
Attainment
3-hour 0.5 ppm
(1,300 μg/m3)
—
24-hour 0.14 ppm
(365 μg/m3)

0.04 ppm
(105 μg/m3)
Annual 0.03 ppm
(80 μg/m3)
—
Lead (Pb) 30-day average — 1.5 μg/m3 Partial Non-
Attainmente
Attainment
Rolling 3‑month
average

0.15 μg/m3 —
Sulfates 24-hour — 25 μg/m3 — Attainment
Hydrogen Sulfide (H2S) 1-hour — 0.03 ppm
(42 μg/m3)
— Unclassified
NOTES: ppm = parts per million by volume; µg/m3 = micrograms per cubic meter a An ambient air quality standard is a concentration level expressed in either ppm or µg/m3and averaged over a specific time period (e.g., 1 hour).

The different averaging times and concentrations are meant to protect against different exposure effects. Some ambient air quality standards are expressed as a concentration that is not to be exceeded. Others are expressed as a concentration that is not to be equaled or exceeded. b Ambient Air Quality Standards set by USEPA and CARB as displayed in the 2022 AQMP. c “Attainment” means that the regulatory agency has determined based on established criteria, that the Air Basin meets the identified standard. “Non-attainment” means that the regulatory agency has determined that the Air Basin does not meet the standard. “Unclassified” means there is insufficient data to designate an area, or designations have yet to be made. d California and Federal standard attainment status as determined by USEPA and CARB as displayed in SCAQMD’s 2022 AQMP and 2022 updates from CARB. https://ww2.arb.ca.gov/resources/documents/maps-state-and-federal-area-designations. e An attainment re-designation request is pending.

SOURCES: USEPA, NAAQS Table, https://www.epa.gov/criteria- air-pollutants/naaqs-table. March 2023 CARB, Ambient Air Quality Standards May 4, 2016.

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4.2. Air Quality
City of Culver City 4.2-9 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
State
California Clean Air Act
The California Clean Air Act (CCAA), signed into law in 1988, requires all areas of the state to achieve and maintain the CAAQS by the earliest practicable date. (CARB, a part of the California Environmental Protection Agency (CalEPA), is responsible for the coordination and administration of both State and federal air pollution control programs within California. In this capacity, CARB conducts research, sets the CAAQS, compiles emission inventories, develops suggested control measures, and provides oversight of local programs. CARB establishes emissions standards for motor vehicles sold in California, consumer products, and various types of commercial equipment.

It also sets fuel specifications to further reduce vehicular emissions. Table 4.2 -1 includes the CAAQS currently in effect for each of the criteria pollutants, as well as other pollutants recognized by the state. As shown in Table 4.2-1, the CAAQS include more stringent standards than the NAAQS. The Air Basin fails to meet S tate standards for O 3, PM10, and PM2.5 and, therefore, is
considered “non-attainment” for these pollutants.

California Code of Regulations
The California Code of Regulations (CCR) is the official compilation and publication of regulations adopted, amended or repealed by state agencies pursuant to the Administrative Procedure Act. The CCR includes regulations that pertain to air quality emissions. Specifically, Section 2485 in Title 13 of the CCR states that the idling of all diesel-fueled commercial vehicles (weighing over 10,000 pounds) during construction shall be limited to five minutes at any location. In addition, Section 93115 in Title 17 of the CCR states that operations of any stationary, diesel -fueled, compression- ignition engines shall meet specified fuel and fuel additive requirements and emissions standards.

State Programs for Toxic Air Contaminants
The California Air Toxics Program is an established two-step process of risk identification and risk management to address potential health effects from exposure to toxic substances in the air. In the risk identification step, CARB and OEHHA determine if a substance should be formally identified, or “listed,” as a TAC in California. In the risk management step, CARB reviews emission sources of an identified TAC to determine whether regulatory action is needed to reduce risk. Based on results of that review, CARB has promulgated a number of Airborne Toxic Control Measures (ATCMs), both for stationary and mobile sources, including On-Road and Off-Road Vehicle Rules.

These ATCMs include measures such as limits on heavy -duty diesel motor vehicle idling and emission standards for off -road diesel construction equipment in order to reduce public exposure to DPM and other TACs. These actions are also supplemented by the Assembly Bill (AB) 2588 Air Toxics “Hot Spots” program and Senate Bill (SB) 1731, which require facilities to report their air toxics emissions, assess health risks, notify nearby residents and workers of significant risks if present, and reduce their risk through implementation of a risk management plan. SCAQMD has further adopted two rules to limit cancer and non-cancer health risks from facilities located within its jurisdiction. Rule 1401 (New Source Review of Toxic Air Contaminants) regulates new or modified facilities, and Rule 1402 (Control of Toxic Air Contaminants from Existing Sources) regulates facilities that are already operating. Rule 1402 incorporates requirements of the AB 2588 program, including implementation of risk reduction plans for significant risk facilities.

4. Environmental Impacts Analysis

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City of Culver City 4.2-10 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Diesel Risk Reduction Program
CARB identified particulate emissions from diesel -fueled engines as TACs in August 1998.

Following the identification process, CARB was required by law to determine if there is a need for further control, which moved us into the risk management phase of the program. CARB developed the Risk Reduction Plan to Reduce Particulate Matter Emissions from Diesel -Fueled Engines and the Vehicles and the Risk Management Guidance for the Permitting of New Stationary Diesel - Fueled Engines . The Diesel Advisory Committee approved these documents on September 28, 2000, paving the way for the next step in the regulatory process: the control measure phase. During the control measure phase, specific statewide regulations designed to further reduce DPM emissions from diesel -fueled engines and vehicles have and continue to be evaluated and developed. The goal of each regulation is to make diesel engines as clean as possible by establishing state-of-the-art technology requirements or emission standards to reduce DPM emissions.

Regional
South Coast Air Quality Management District
The SCAQMD is primarily responsible for planning, implementing, and enforcing air quality standards for the South Coast Air Basin. The Air Basin is a subregion within the western portion of the SCAQMD jurisdiction, as the SCAQMD also regulates portions of the Salton Sea Air Basin and Mojave Desert Air Basin within Riverside County.

Air Quality Management Plan and Regional Transportation Plan/Sustainable Communities Strategy
To meet the NAAQS and CAAQS, the SCAQMD has adopted a series of Air Quality Management Plans (AQMPs), which serve as a regional blueprint to develop and implement an emission reduction strategy that will bring the Air Basin into attainment with the standards in a timely manner. The most current AQMP is the 2022 Air Quality Management Plan (2022 AQMP) 15, which was adopted on
December 2, 2022. The goal of the 2022 AQMP is to provide a regional roadmap to help the Air Basin achieve the USEPA's NAAQS 2015 8-hour ozone standard (70 parts per billion).

On January 26, 2023, CARB adopted Resolution 23-4, which directs the CARB Executive Officer to submit the 2022 AQMP to the USEPA for inclusion in the California SIP to be effective, for purposes of federal law, after notice and public hearing as required b y Section 110(l) of the Clean Air Act and 40 Code of Federal Regulations Section 51.102 and approval by the USEPA. USEPA approval has not yet occurred.

The 2022 AQMP builds upon measures already in place from previous AQMPs. It also includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emissions technologies, when cost -effective and feasible, and low NOx technologies in other applications), best management practices, co-benefits from existing programs (e.g., climate and energy efficiency), incentives, and other CAA measures to achieve the 2015 8 - hour ozone standard.

The 2022 AQMP incorporates the transportation strategy and transportation control measures from SCAG’s Connect SoCal (2020- 2045 Regional Transportation Plan/Sustainable Communities

15 SCAQMD, 2022 Air Quality Management Plan, 2022.

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Strategy [2020-2045 RTP/SCS]).16 SCAG is the regional planning agency for Los Angeles, Orange, Ventura, Riverside, San Bernardino, and Imperial Counties, and addresses regional issues relating to transportation, the economy, community development and the environment. SCAG coordinates with various air quality and transportation stakeholders in Southern California to ensure compliance with the federal and state air quality requirements. Pursuant to California Health and Safety Code Section 40460, SCAG has the responsibility of preparing and approving the portions of the AQMP relating to the regional demographic projections and integrated regional land use, housing, employment, and transportation programs, measures, and strategies. SCAG is required by law to ensure that transportation activities “conform” to, and are supportive of, the goals of regional and state air quality plans to attain the NAAQS. Connect SoCal includes transportation programs, measures, and strategies generally designed to reduce vehicle miles traveled (VMT), which are contained in the AQMP.

The 2022 AQMP forecasts future emissions inventories with growth based on SCAG’s Connect SoCal. According to the 2022 AQMP, t he South Coast Air Basin is projected to see a 12 percent growth in population, 17 percent growth in housing units, 11 percent growth in employment, and an 8 percent growth in VMT between 2018 and 2037. Despite regional growth in the past, air quality has improved substantially over the years, primarily due to the effects of air quality control programs at the local, state and federal levels.
17 Noteworthy c ontrol strategies for mobile sources in the AQMP with potential applicability to reducing short -term emissions from construction activities associated with the Project include strategies denoted in the 2022 AQMP as MOB-06, MOB-11, and MOB-15, which are intended to reduce emissions from on-road and off-road heavy-duty vehicles and equipment.18 Descriptions of measures MOB-06, MOB-11, and MOB-15 are provided below:
• MOB-06 – Accelerated Retirement of Older On-Road Heavy-Duty Vehicles: This measure seeks additional emission reductions from existing heavy-duty vehicles with GVWR greater than 8,500 lbs through an accelerated vehicle replacement program with zero or low NO X emission vehicles.
• MOB-11 – Emission Reductions from Incentive Programs: This control measure seeks to quantify and take credit for the emission reductions achieved through the implementation of SCAQMD administered incentive programs for SIP purposes. The South Coast AQMD has been implementing a variety of incentive programs including, but not limited to, Carl Moyer Memorial Air Quality Standards Attainment Program, Proposition 1B, Lower Emission School Bus, Community Air Protection Program, a nd Volkswagen Environmental Mitigation Trust.

Examples of projects funded by these programs include heavy-duty vehicle/equipment replacements, installation of retrofit units, and engine repowers. These incentive programs result in substantial emission redu ctions that are typically not eligible for credit in plans to attain ozone standards because they are not required by regulation. However, actual emission reductions that are realized and quantified may qualify for credit.

16 SCAG, Final 2020-2045 RTP/SCS (Connect SoCal), 2020. 17 SCAQMD, 2022 Air Quality Management Plan, Table 3-3, 2022. 18 SCAQMD, 2022 Air Quality Management Plan, pages 4-21 through 4-30, 2022.

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• MOB-15 – Zero Emission Infrastructure for Mobile Sources: This control measure is intended to support and accelerate the deployment of zero emission infrastructure needed for the widespread adoption of zero emission vehicles and equipment. AB 2127 estimated that the State will need 157,000 electric vehicle charging stations for medium and heavy-duty vehicles by 2030.

AB 8 assessed the fueling needs for hydrogen fuel cell vehicles and found that 1,700 hydrogen stations will be needed to support 1.8 million f uel cell electric vehicles (FCEVs) statewide by 2035. The proposed measure seeks to address these concerns and identify the unique challenges and opportunities for zero emission infrastructure development in the South Coast Air Basin, particularly as it relates to zero emission medium and heavy vehicle deployments.

SCAQMD Air Quality Guidance Documents
The SCAQMD published the CEQA Air Quality Handbook (approved by the SCAQMD’s Governing Board in 1993) to provide local governments with guidance for analyzing and mitigating project - specific air quality impacts.19 The CEQA Air Quality Handbook provides standards, methodologies, and procedures for conducting air quality analyses. The SCAQMD has also provided supplemental guidance on the SCAQMD website to assist the CEQA practitioner s in conducting an air quality analyses, such as the Final Localized Significance Threshold Methodology , which is discussed below.20
The SCAQMD has also adopted land use planning guidelines in its Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, which considers impacts to sensitive receptors from facilities that emit TAC emissions. 21 SCAQMD’s siting distance
recommendations are the same as those provided by CARB (e.g., a 500 -foot siting distance for sensitive land uses proposed in proximity to freeways and high-traffic roads, and the same siting criteria for distribution centers and dry-cleaning facilities). The SCAQMD’s document introduces land use-related policies that rely on design and distance parameters to minimize emissions and lower potential health risk. SCAQMDs guidelines are voluntary initiatives recommended for consideration by local planning agencies.

The SCAQMD has published a guidance document called the Final Localized Significance Threshold Methodology for CEQA evaluations that is intended to provide guidance when evaluating the localized effects from mass emissions during construction or operation of a project. 22 The SCAQMD adopted additional guidance regarding PM2.5 emissions in a document called Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds.23 The latter document has been incorporated by the SCAQMD into its CEQA significance thresholds and Final Localized Significance Threshold Methodology.

19 SCAQMD, CEQA Air Quality Handbook 1993, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis- handbook/ceqa-air-quality-handbook-(1993). Accessed October 30, 2023. 20 SCAQMD, Air Quality Analysis Guidance, http://www.aqmd.gov/home/rules-compliance/ceqa/air-quality- analysis-handbook#. Accessed October 30, 2023.
21 SCAQMD Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, 2005. 22 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 (Revised July 2008). 23 SCAQMD, Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds, 2006.

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4.2. Air Quality
City of Culver City 4.2-13 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
SCAQMD Rules and Regulations
The SCAQMD has adopted several rules and regulations to regulate sources of air pollution in the Air Basin and to help achieve air quality standards for land use development projects, which include, but are not limited to the following:

Regulation IV – Prohibitions: This regulation sets forth the restrictions for visible emissions, odor nuisance, fugitive dust, various air emissions, fuel contaminants, start -up/shutdown exemptions and breakdown events. The following list of rules which apply to the Project:
• Rule 401 – Visible Emissions : This rule states that a person shall not discharge into the atmosphere from any single source of emission whatsoever any air contaminant for a period or periods aggregating more than three minutes in any one hour which is as dark or darker in shade as th at designated No. 1 on the Ringelmann Chart or of such opacity as to obscure an observer’s view.
• Rule 402 – Nuisance: This rule states that a person shall not discharge from any source whatsoever such quantities of air contaminants or other material which cause injury, detriment, nuisance, or annoyance to any considerable number of persons or to the public, or which endanger the comfort, repose, health or safety of any such persons or the public, or which cause, or have a natural tendency to cause, injury or damage to business or property. • Rule 403 – Fugitive Dust: This rule requires projects to prevent, reduce or mitigate fugitive dust emissions from a site. Rule 403 restricts visible fugitive dust to the project property line, restricts the net PM10 emissions to less than 50 micrograms per cubic meter (µg/m3) and restricts the tracking out of bulk materials onto public roads. Additionally, projects must utilize one or more of the best available control measures (identified in the tables within the rule).

Mitigation measures may include adding freeboard to haul vehicles, covering loose material on haul vehicles, watering, using chemical stabilizers and/or ceasing all activities. Finally, a contingency plan may be required if so determined by the USEPA.

Regulation XI – Source Specific Standards: Regulation XI sets emissions standards for specific sources. The following is a list of rules which may apply to the Project:
• Rule 1113 – Architectural Coatings: This rule requires manufacturers, distributors, and end users of architectural and industrial maintenance coatings to reduce VOC emissions from the use of these coatings, primarily by placing limits on the VOC content of various coating categories.
• Rule 1146.2 – Emissions of Oxides of Nitrogen from Large Water Heaters and Small Boilers and Process Heaters: This rule requires manufacturers, distributors, retailers, refurbishers, installers, and operators of new and existing units to reduce NO X emissions from
natural gas-fired water heaters, boilers, and process heaters as defined in this rule. • Rule 1186 – PM10 Emissions from Paved and Unpaved Roads, and Livestock Operations:

This rule applies to owners and operators of paved and unpaved roads and livestock operations.

The rule is intended to reduce PM10 emissions by requiring the cleanup of material deposited onto paved roads, use of certified street sweeping equipment, and treatment of high-use unpaved roads (see also Rule 403).

Regulation XIII – New Source Review (NSR): Regulation XIII sets requirements for preconstruction review required under both federal and state statutes for new and modified sources located in areas that do not meet the Clean Air Act standards ("non-attainment" areas). NSR applies

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City of Culver City 4.2-14 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
to both individual permits and entire facilities. Any permit that has a net increase in emissions is required to apply Best Available Control Technology (BACT). Facilities with a net increase in emissions are required to offset the emission increase by use of Emission Reduction Credits (ERCs). The regulation provides for the application, eligibility, registration, use and transfer of ERCs. For low emitting facilities, the SCAQMD maintains an internal bank that can be used to provide the required offsets. In addition, certain facilities are subject to provisions that require public notice and modeling analysis to determine the downwind impact prior to permit issuance.

Regulation XIV – Toxics and Other Non-Criteria Pollutants: Regulation XIV sets requirements for new permit units, relocations, or modifications to existing permit units which emit toxic air contaminants or other non-criteria pollutants. The following is a list of rules which may apply to the Project:
• Rule 1403 – Asbestos Emissions from Demolition/Renovation Activities: This rule requires owners and operators of any demolition or renovation activity and the associated disturbance of asbestos-containing materials, any asbestos storage facility, or any active waste disposal site to implement work practice requirements to limit asbestos emissions from building demolition and renovation activities, including the removal and associated disturbance of asbestos - containing materials.
• Rule 1470 – Requirements for Stationary Diesel-Fueled Internal Combustion and Other Compression Ignition Engines: This rule applies to stationary compression ignition (CI) engines greater than 50 brake horsepower and sets limits on emissions and operating hours. In general, new stationary emergency standby diesel -fueled engines greater than 50 brake horsepower are not permitted to operate more than 50 hours per year for maintenance and testing.

Local
City of Culver City
Culver City General Plan
The Culver City General Plan includes nine elements that have been updated at various points between 1968 and 2014. The current General Plan does not have an Air Quality Element. However, the Circulation Element of the General Plan contains objectives and policies focused on public transit (Objective #2), bikeways (Objective #3), pedestrian access (Objective #4), participating in regional system improvements (Implementation Measure #1), and roadway improvement (Implementation Measure #2).

Consistency with these goals and policies have the potential to reduce single occupancy vehicle trips and VMT, thus reducing air pollutants from mobile sources.

The growth projections within the General Plan inform the development of SCAQMD’s AQMP.

Culver City Green Building Program
In 2009, the City of Culver City adopted the Mandatory Green Building Program which contains a number of features that would indirectly reduce air pollut ant emissions such as enhanced building insulation, low -flow fixtures, efficient lighting and heating, ventilation, and air conditioning (HVAC) systems.24 The City of Culver City Mandatory Green Building Program also includes a specific feature for parking garages which requires all new lighting to be motion sensor controlled and efficient minimum base level lighting.

24 City of Culver City, Municipal Code Chapter 15.02.1100, Green Building Program and Requirements.

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4.2. Air Quality
City of Culver City 4.2-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Existing Conditions
Regional Air Quality
The Southern California region lies in the semi-permanent high-pressure zone of the eastern Pacific that leads to mild climate, moderated by cool sea breezes. The usually mild climatological pattern is interrupted infrequently by periods of extremely hot weather, winter storms, or Santa Ana winds.

The area’s natural physical characteristics (weather and topography), as well as man -made influences (development patterns and lifestyle) play a major role in degree and severity of the air pollution problem in the Air Basin where factors, such as wind, sunlight, temperature, humidity, rainfall, and topography, affect the accumulation and dispersion of air pollutants throughout the Air Basin, making it an area of high pollution potential.

The greatest air pollution throughout the Air Basin occurs from June through September that is generally attributed to light winds, shallow vertical atmospheric mixing, as well as the large amount of pollutant emissions. This frequently reduces pollutant dispersion, resulting in elevated air pollution levels. In addition, pollutant concentrations in the Air Basin vary with location, season, and time of day. For instance, O
3 concentrations tend to be lower along the coast, higher in the near inland valleys, and lower in the far inland areas of the Air Basin and adjacent desert. While substantial progress has been made in reducing air pollution levels in Southern California, the Air Basin still fails to meet the national standards for O
3 and PM2.5 and, therefore, is considered a
federal “non-attainment” area for these pollutants. In addition, Los Angeles County still fails to meet the national standard for Pb and, therefore, is considered a federal “non-attainment” area for Pb.

As described above, at the regional level, SCAQMD is the regulatory agency responsible for improving air quality for large areas of Los Angeles, Orange County, Riverside and San Bernardino Counties. Specifically, the SCAQMD has the responsibility for ensuring that all national and State ambient air quality standards are achieved and maintained throughout the Air Basin. To meet the standards, SCAQMD has adopted a series of AQMPs. The 2022 AQMP builds upon measures already in place from previous AQMPs and includes a variety of additional strategies such as regulation, accelerated deployment of available cleaner technologies (e.g., zero emissions technologies and low NOx technologies), best management practices, co -benefits from existing programs (e.g., climate and energy efficiency), incentives, and other CAA measures to achieve the 2015 8-hour ozone standard by 2037. However, the 2037 NO X limit is 60 tons per day and emissions
from federal and international sources are estimated to be 85 tons per day in 2037; thus, federal sources alone would emit more than the 60 tons per day limit in 2037. The SCAQMD and CARB cannot sufficiently reduce NO
X emissions to meet the standard without federal action.

The 2022 AQMP states that despite the projected growth in the region, air quality has improved substantially over the years. This is largely due to the effects of local, State and federal air quality control programs as described above. As seen in Figure 1-4 on page 1-9 of the AQMP, the percent change in air quality is shown along with demographic data for the 4-county region from the 2022 AQMP where in particular, the trends since 1995 of the 8-hour O 3 levels, the 1-hour O3 levels, and
annual average PM2.5 concentrations (since 2001), compared to the regional gross domestic product, total employment and population. In addition, the O3 and particulate matter levels continue

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City of Culver City 4.2-16 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
to trend downward as the economy and population increase, demonstrating that it is possible to maintain a healthy economy while improving public health through air quality improvements.25 Attainment Status
The extent and severity of pollutant concentrations in the Air Basin are a function of the area’s natural physical characteristics (weather and topography) and man-made influences (development patterns and lifestyle). Factors, such as wind, sunlight, temperature, humidity, rainfall, and topography, all affect the accumulation and dispersion of pollutants throughout the Air Basin, making it an area of high pollution potential. The Air Basin’s meteorological conditions, in combination with regional topography, are conducive to the formation and retention of ozone, which is a secondary pollutant that forms through photochemical reactions in the atmosphere.

California Health and Safety Code S ection 39607(e) requires CARB to establish and periodically review area designation criteria. Table 4.2-2, South Coast Air Basin Attainment Status (Los Angeles County), provides a summary of the attainment status of the Los Angeles County portion of the Air Basin with respect to the federal and State standards. The Air Basin is designated as attainment for the California standards for sulfates and unclassified for hydrogen sulfide and visibility-reducing particles.
26 The Air Basin is currently in non-attainment for O 3, PM10, and PM2.5 under the CAAQS and O 3, and PM2.5 under the NAAQS. Since vinyl chloride is a carcinogenic toxic air contaminant, CARB does not classify attainment status for this pollutant. Health and Safety Code Section 39607(e) requires CARB to establish and periodically review area designation criteria.

The Los Angeles County portion of the Air Basin is designated as nonattainment for the federal lead standard; however, this is due to localized emissions from two lead-acid battery recycling facilities in the City of Vernon and the City of Industry that are no longer operating. 27 Trace amounts of hydrogen sulfide may be emitted by common municipal solid waste such as household food wastes. Vinyl chloride is used in the process of making polyvinyl chloride (PVC) plastic and vinyl products and is primarily emitted from industrial processes. 28 Vinyl chloride
generally is not emitted directly during operations or during construction of a land use development project. The proposed Project does not include vinyl chloride emitting processes. L and developments only emit trace amounts or otherwise account for sulfates and visibility -reducing particles through other criteria pollutants. As previously stated, sulfates are associated with SO 2 emissions and visibility -reducing particles are associated with particulate matter emissions.

Therefore, these pollutants will not independently be evaluated as they are associated with other criteria pollutants.

25 SCAQMD, 2022 AQMP, December 2022, page 1-9.
26 Unclassified is the category designation of an area for a pollutant with insufficient data. CARB, Proposed 2017 Amendments to Area Designations for State Ambient Air Quality Standards, December 19, 2017 (release date). 27 SCAQMD, Board Meeting, Agenda No. 30, Adopt the 2012 Lead State Implementation Plan for Los Angeles County, May 4, 2012.
28 CARB, Vinyl Chloride & Health, https://ww2.arb.ca.gov/resources/vinyl-chloride-and-health. Accessed October 30, 2023.

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City of Culver City 4.2-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.2-2

SOUTH COAST AIR BASIN ATTAINMENT STATUS (LOS ANGELES COUNTY) Pollutant Federal Standards California Standards
O3 (1-hour standard) N/Aa Non-attainment
O3 (8-hour standard) Non-attainment – Extreme Non-attainment CO Attainment Attainment
NO2 Attainment Attainment
SO2 Attainment Attainment
PM10 Attainment Non-attainment
PM2.5 Non-attainment – Serious Non-attainment
Lead Non-attainment (Partial, Los Angeles County)b Attainment Visibility Reducing Particles N/A Unclassified
Sulfates N/A Attainment
Hydrogen Sulfide N/A Unclassified
Vinyl Chloride N/A N/Ac
NOTES: N/A = not applicable.
a The NAAQS for 1-hour ozone was revoked on June 15, 2005, for all areas except Early Action Compact areas. b Partial Nonattainment designation – Los Angeles County portion of the Air Basin only for near-source monitors. c In 1990, CARB identified vinyl chloride as a TAC and determined that it does not have an identifiable threshold. Therefore, CARB does not monitor or make status designations for this pollutant.

SOURCES: USEPA, The Green Book Non-Attainment Areas for Criteria Air Pollutants. Accessed October 2023. https://www.epa.gov/green-book.

CARB, Area Designations Maps/State and National. Accessed April 2022. http://www.arb.ca.gov/desig/adm/adm.htm.

Sources of Emissions
As detailed in the AQMP, the major sources of air pollution in the Air Basin are divided into four major source classifications: point stationary sources, area stationary sources, on -road mobile sources, and off -road mobile sources. Point and area sources are the two major subcategories of stationary sources. 29 Point sources are permitted facilities that contain one or more emission sources at an identified location (e.g., power plants, refineries, emergency generator exhaust stacks). Area sources consist of many small emission sources (e.g., residential water h eaters, architectural coatings, and consumer products), which are distributed across the region. Mobile sources consist of two main subcategories: On-road sources (such as cars and trucks), and off-road sources (such as heavy construction equipment).

Local Air Quality
Existing Criteria Pollutants Levels at Nearby Monitoring Stations The SCAQMD maintains a network of air quality monitoring stations located throughout the Air Basin to measure ambient pollutant concentrations. As shown in Figure 4.2-1, SCAQMD General Forecast Areas and Air Monitoring Areas, the Project Site is located in SCAQMD Source Receptor Area (SRA) 3; therefore, the monitoring station most representative of the Project Site is the Southwest Coastal LA County Monitoring Station. Criteria pollutants monitored at this station

29 SCAQMD, 2022 Air Quality Management Plan, p. 3-1.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-18 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
include ozone, NO2, CO, SO2, lead, and PM10. Since the Southwest Coastal LA County Monitoring Station does not monitor PM2.5, T he next closest station, the Central LA station was used for PM2.5 monitoring data. The most recent data available from the SCAQMD for these monitoring stations are from years 2019 to 202 2. The pollutant concentration data for these years are summarized in Table 4.2-3, Ambient Air Quality Data.

Toxic Air Contaminants
In August 2021, the SCAQMD released the Final Multiple Air Toxics Exposure Study V (MATES V).30 The MATES V study includes a fixed site monitoring program with ten stations, an updated emissions inventory of TACs, and a modeling effort to characterize risk across the Air Basin. The purpose of the fixed site monitoring is to characterize long-term re gional air toxics levels in residential and commercial areas. In addition to new measurements and updated modeling results, several key updates were implemented in MATES V. MATES V estimates cancer risks by taking into account multiple exposure pathways, which includes inhalation and non-inhalation pathways.

This approach is consistent with how cancer risks are estimated in SCAQMD’s programs such as permitting, Air Toxics Hot Spots (AB 2588), and CEQA. Previous MATES studies quantified the cancer risks based on the inhalation pathway only. Along with cancer risk estimates, MATES V includes information on the chronic noncancer risks from inhalation and non-inhalation pathways for the first time. Cancer risks and chronic noncancer risks from MATES II through I V measurements have been re-examined using current OEHHA and CalEPA risk assessment methodologies and modern statistical methods to examine the trends over time. This has led to a reduction of the Basin Average Air Toxics Cancer Risk in MATES V, 455 in a m illion, from MATES IV, 997 in a million. 31 The key takeaways from the MATES V study are as follows: air toxics cancer risk has decreased by about 50 percent since MATES IV based on modeling data, MATES V Basin average multi-pathway air toxics cancer risk is 455 in a million, with the highest risk locations being near Los Angeles International Airport, downtown and the ports areas, DPM is the main risk driver for air toxics cancer risk, goods movement and transportation corridors have the highest air toxics cancer risks, and the chronic noncancer risk was estimated for the first time with a chronic hazard index of approximately 5 to 9 across the ten fixed stations. As shown in Figure 4.2-2, MATES Cancer Risk, the Project Site has an average background cancer risk of 464 in 1 million in zip code 90230 (Culver City).32

30 SCAQMD, MATES V, http://www.aqmd.gov/home/air-quality/air-quality-studies/health-studies/mates-v.

Accessed October 30, 2023.
31 SCAQMD, MATES V, http://www.aqmd.gov/home/air-quality/air-quality-studies/health-studies/mates-v.

Accessed July 8, 2022.
32 SCAQMD, MATES V, http://www.aqmd.gov/home/air-quality/air-quality-studies/health-studies/mates-v.

Accessed October 30, 2023.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-19 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.2-3

AMBIENT AIR QUALITY DATA
Pollutant/Standarda,b 2019 2020 2021
O3 (1-hour)
Maximum Concentration (ppm)
Days > CAAQS (0.09 ppm)

0.082
0 0.117
1 0.059
0 O3 (8-hour)
Maximum Concentration (ppm)
4th High 8-hour Concentration (ppm)
Days > CAAQS (0.070 ppm)
Days > NAAQS (0.075 ppm)

0.067

0.060
0 0

0.074

0.066
2 0

0.049

0.047
0 0
NO2 (1-hour)
Maximum Concentration (ppm)
98th Percentile Concentration (ppm)
NO2 (Annual)
Annual Arithmetic Mean (0.030 ppm)

0.057

0.049

0.010

0.060

0.051

0.010

0.063

0.048

0.007
CO (1-hour)
Maximum Concentration (ppm)
CO (8-hour)
Maximum Concentration (ppm)

1.8 1.3

1.6 1.3

1.7 1.3
SO2 (1-hour)
Maximum Concentration (ppm)
99th Percentile Concentration (ppm)
SO2 (24-hour)
Maximum Concentration (ppm)

0.008

0.004

0.006

0.003

0.008

0.004

--
PM10 (24-hour)
Maximum Concentration (µg/m3)
Samples > CAAQS (50 µg/m3)
Samples > NAAQS (150 µg/m3)
PM10 (Annual Average) c
Annual Arithmetic Mean (20 µg/m3)

62 2
0 19.2

43 0
0 22.5

33 0
0 17.7
PM2.5 (24-hour)
Maximum Concentration (µg/m3)
98th Percentile Concentration (µg/m3)
Samples > NAAQS (35 µg/m3)
PM2.5 (Annual) d
Annual Arithmetic Mean (12 µg/m3)

43.5 28.3
1 10.85

47.3 28.0
2 12.31

61.0 44.8
12 12.77
Lead
Maximum 30-day average (µg/m
3)

0.004

0.008

0.003
NOTES ppm = parts per million; µg/m3 = micrograms per cubic meter a The monitoring station most representative of the Project Site the Southwest Coastal LA County Monitoring Station and Criteria pollutants monitored at this station include ozone, NO 2, CO, SO2, lead, and PM10 . The Central LA Station was used to report data for PM2.5 The most recent data available from SCAQMD for th ese monitoring stations are from years 2019 to 2021.
b CAAQS are based on a not to exceed standard. NAAQS are based on a 3- year average of the annual 4th highest daily maximum 8-hour concentration for ozone; 98 th percentile of 1-hour daily maximum concentrations averaged over 3 years for 1-hr NO2; and not to be exceeded more than once per year on average over 3 years for 24-hr PM. c State annual average (AAM) PM10 standard is > 20 µg/m3. Federal annual PM10 standard (AAM > 50 µg/m3) was revoked in 2006.
d Both Federal and State standards are annual average (AAM) > 12.0 µg/m3.

SOURCE: SCAQMD, Historical Data by Year, www.aqmd.gov/home/air-quality/air-quality-data-studies/historical-data- by-year; USEPA, AirData, www.epa.gov/airdata/ad_rep_mon.html. Accessed October 2023.

5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.2-1
SCAQMD General Forecast Areas and Air Monitoring Areas
SOURCE: South Coast Air Quality Management District, 1999D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR\Illustrator 27 13
21 2824
38 36
19 4
2 15
*Not Shown: San Clemente Island
30 31
25 6
29 20
163
34 10
9 11
87 512
1 23
22 26
35 32 37
17 33
18 RIVERSIDE COUNTY

LOS ANGELES COUNTY

VENTURA COUNTY

MOJAVE DESERT AIR QUALITY

MANAGEMENT DISTRICT
(San Bernardino County)

VENTURA COUNTY

AIR POLLUTION

CONTROL DISTRICT

SAN DIEGO COUNTY

AIR POLLUTION CONTROL DISTRICT

RIVERSIDE COUNTY

AIR POLLUTION CONTROL DISTRICT

IMPERIAL COUNTY

ANTELOPE VALLEY

AIR POLLUTION

CONTROL DISTRICT
(Los Angeles County)

RIVERSIDE
COUNTY

LOSANGELESCOUNTY
COUNTY
COUNTY

ORANGE COUNTYRIVERSIDE

ORANGECOUNTY

LOSANGELES

BERNARDINOSAN
COUNTY

MOJAVE DESERT AIR QUALITY

MANAGEMENT DISTRICT
(San Bernardino County)

RIVERSIDE COUNTY
Legend
Water Bodies
Fwys/Hwys
County Boundaries
Air Monitoring Areas
Hemet
Fullerton
Buena Park
Inglewood
Big Bear Lake
West Hollywood
Glendale
Santa Monica
Covina
CulverCity
Center
Downey
Torrance
Perris
Hawthorne
NewportBeach
Beaumont
Azusa
Brea
Fernando
Agoura
Los Alamitos
BeachSeal
La Habra
Walnut
Irwindale
Monrovia
Rosemead
San Dimas
Montebello
Palos VerdesEstates
Rancho PalosVerdes
Placentia
Montclair
Huntington
Beach
CostaMesa
LagunaHills
San
San Jacinto
Lake
Banning
Calimesa
Redlands
Loma Linda
LakeElsinore
Cucamonga Highland
Crestline
Murrieta
Coachella
La Quinta
Rancho Mirage
Desert HotSprings
Palmdale
Lancaster
Simi Valley
Thousand Oaks
Twentynine Palms
Castaic
Pasadena
Rubidoux
Moreno Valley
San
Reseda La CanadaFlintridge
MontereyPark
Huntington Park
Industry
Hills
La
Mirada
Cerritos
Whittier
Pico Rivera
Rialto
Rancho
Yucaipa
Canyon
Irvine
LagunaNiguel
Mission Viejo
Orange
Cypress
Indio
Desert
Pope
Corona
Norco
Chino Hills
Pomona
Villa
Park
Glendora
Palm Springs
Fontana
ManhattanBeach
El
Segundo
Beverly
Hills
Burbank
Diamond Bar
Fallbrook
Calabasas
Los Angeles
Riverside
Upland
Clemente
San JuanCapistrano
Cathedral City
Indian
Wells
Palm Desert
Temecula
Ontario
RedondoBeach
Tustin
SantaAna
Lake Forest
Malibu
South Gate
BeachLaguna
Dana
Point
SanBernardino
Chino
Catalina
Avalon
Lynwood
Lakewood
Long
Beach
Hesperia
Victorville
Claremont
Colton
Grand Terrace
Anaheim
Yorba
Linda
LaPalma
Stanton
Garden
WestminsterGrove
FountainValley
Yucca Valley
SantaClarita
Air Monitoring Stations
Since 1977, the South Coast
Air Quality Management District has
served as the local government
agency responsible for measuring,
reporting and taking steps to improve
air quality.

To inform the AQMD’s 15
million residents about air quality
conditions, the AQMD issues an air
quality forecast each day and reports
current air quality conditions for each
numbered Monitoring Area and
General Forecast Area depicted here.

This air quality information is
transmitted to the public through
newspapers, television, radio and
pager services, through faxes to
schools, through recorded messages
on the AQMD’s toll−free Smog
Update telephone line, 1−800−CUT−
SMOG, and on the AQMD’s Internet
Website http://www.aqmd.gov.

Newspapers, television and
radio stations typically will report air
quality information using the General
Forecast Areas, shown in color below,
which are larger groupings of the more
specific Air Monitoring Areas.

The 1−800−CUT−SMOG (1−
800−288−7664) line also provides
smog forecast and current smog level
information by ZIP code.

The AQMD’s Internet
Website provides both forecasts as
well as smog levels for that day and
the previous day. Forecasts for the
next day normally are posted by noon.

Northwest Los Angeles County Coastal
Southwest Los Angeles County Coastal
South Los Angeles County Coastal
North Orange County Coastal
Central Orange County Coastal
2 3
4 18
20 Central Los Angeles County
Southeast Los Angeles County
South Central Los Angeles County
North Orange County
1 12
5 16
West San Fernando Valley
East San Fernando Valley
Santa Clarita Valley
6 7
13 West San Gabriel Valley
East San Gabriel Valley
Pomona/Walnut Valley
South San Gabriel Valley
8 9
10 11
Central Orange County
Saddleback Valley
Capistrano Valley
17 19
21 Corona/Norco Area
Metropolitan Riverside
22 23
Northwest San Bernardino Valley
Southwest San Bernardino Valley
Central San Bernardino Valley
East San Bernardino Valley
32 33
34 35
Perris Valley
Lake Elsinore
Hemet/San Jacinto Valley
24 25
28 Temecula Valley
Anza Area
26 27
15 West San Bernardino Mountains
Central San Bernardino Mountains
36 37
38 29
Coachella Valley
East Riverside County
30 31
14 Victor Valley
Northern Mojave Desert
Central Mojave Desert
39 40
41 *These agencies contract with the South Coast AQMD for forecasting services. Also, the Antelope Valley APCD contracts with the Mojave Desert AQMD for other services. For more air quality information in these areas, please call the Mojave Desert AQMD at (760) 245−1661, extension 5067.

Copyright 1999 by Sierra Wade Associates
www.sierrawade.com
r ESA
~
Air Quality Reporting
L--, , __ _
......
,1 ( __
I
I L _______ _
.,
+
I~
General Forecast Areas & Air Monitoring Areas
= Coastal
= San.htrum<hLYalley
c:::::::::JSan Gabriel Valley
=lnland_Or_angeJ:ounty _
C=::J San Bernardino Valley
c:::::::::JHemetfElsinnre Area
c:::::::::JTemeculafAnza Area
c::=:::JSan Gabriel Moontaim
= sJUlJlemacdiooMoJllll.ams_
- Big Bear Lake
c:::::::::JBanning__Pass___Area
c::=:::JCoachellaU..ow Desert
ANTELOPE VALLEY Aecn•
MOJAVE DFSERT AQMD•
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.2-2
MATES Cancer Risk
SOURCE: South Coast Air Quality Management District, 2023D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR\Illustrator 01 500
FeetN
Project Site
Cancer Risk 464 per million
Residential Air Toxics Cancer Risk
Calculated from Model Data
Cancer Risk [per million]
551 - 700
401 - 550
0-=====--
r ESA
~
I I
CJ
c=J

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-22 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Existing Project Site Emissions
The Project Site is currently developed with a 30,672 square foot two-story office building with associated landscaping and surface parking, which would be demolished and removed to support development of the Project. Existing emissions are associated with vehicle trips to and from the Project Site, on-site combustion of natural gas for heating, and fugitive emissions of volatile organic compounds (VOCs) from consumer product usage and architectural coatings. Existing emissions were estimated using the California Emissions Estimator Model (CalEEMod), Version 2022.1 software, an emissions inventory software program recommended by the SCAQMD.

CalEEMod is a Statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental profe ssionals to quantify potential criteria pollutant and greenhouse gas (GHG) emissions from a variety of land use projects.

CalEEMod was developed in collaboration with the air districts of California. Regional data (e.g., emission factors, trip lengths, met eorology, source inventory, etc.) have been provided by the various California air districts to account for local requirements and conditions. CalEEMod is considered to be an accurate and comprehensive tool for quantifying air quality and GHG emissions impacts from land use projects throughout California.
33 CalEEMod was used to estimate the existing site emissions from vehicle trips, natural gas combustion, consumer products usage, and architectural coatings. Mobile source emissions estimates were calculated outside of CalEEMod and were based on the California Air Resource Boards (CARB) latest on -road vehicle EMissions FACtor (EMFAC) model, EMFAC2021, and daily VMT for existing conditions was provided by the Project’s Traffic Consultant where VMT analysis used the City’s VMT analysis procedures and Culver City VMT Tool. 34 Existing criteria pollutant emissions
are presented in Table 4.2-4, Estimated Existing Emissions (pounds per day), identifies the emissions from the site’s existing usage and emissions removed due to the Project. These existing emissions are subtracted from the regional operational emissions from the Project in Table 4.2 -6 Detailed assumptions and emissions calculations are provided in Appendix C of this Draft EIR.

TABLE 4.2-4
ESTIMATED EXISTING EMISSIONS (POUNDS PER DAY)a
Source VOC NOX CO SO2 PM10 PM2.5
Existing Emissions
Area (Consumer products, Landscaping) 1 <1 1 <1 <1 <1
Energy (Natural Gas) <1 <1 <1 <1 <1 <1
Mobile 1 1 7 <1 1 <1
Total Existing Operational Emissionsa 2 1 8 <1 1 <1
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix C of this Draft EIR.

SOURCE: ESA, 2023.

33 See: http://www.caleemod.com.
34 Gibson Transportation Consulting, Inc provided existing use and Project VMT outputs using the City’s VMT Calculator Tool. The existing use outputs are included in Appendix C of this Draft EIR, while the Project VMT outputs are within the Project’s Transportation Study. Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-23 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Air Quality Sensitive Receptors and Locations
Certain population groups, such as children, elderly, and acutely and chronically ill persons (especially those with cardio -respiratory diseases), are considered more sensitive to the potential effects of air pollution than others. 35 As a result, certain land uses that are occupied by these population groups, such as residences, schools, playgrounds and childcare center, hospitals, rehabilitation centers, convalescent centers, and retirement homes are considered to be air quality sensitive land uses (i.e., air quality–sensitive receptors). Sensitive land uses within 1,000 feet of the Project Site are shown in Figure 4.2-3, Air Quality Sensitive Receptors, and include the following:

1. Multi-family residential uses to the south of the Project Site, east of Buckingham Parkway and south of Windsor Way, approximately 450 feet from the Project boundary.

2. Fox Hills Park to the south/southwest of the Project Site, west of Buckingham Parkway, approximately 670 feet from the Project boundary.

3. Multi-family residential uses to the south of the Project Site, on the east side of Buckingham Parkway between Cambridge Way and Windsor Way, approximately 50 feet from the Project boundary.

4. Multi-family residential uses and Fox Hills Parkette to the east of the Project Site, on the east side of Buckingham Parkway north of Cambridge Way, approximately 50 feet to the south of the Project Site.

5. Multi-family residential uses to the east of the Project Site, on the east side of Buckingham Parkway and north of Canterbury Drive, approximately 550 feet from the Project boundary.

All other air quality sensitive receptors are located at greater distances from the Project Site, and would be less impacted by Project emissions. Impacts are quantified for the sensitive receptors listed here.

Commercial Land Uses
Commercial land uses, such as retail and office, are not considered sensitive receptors. However, for informational purposes only, the following commercial land uses near the Project Site were evaluated where warranted:
• Commercial land uses north of the Project Site, approximately 100 feet from the Project boundary.
• Commercial land uses west of the Project Site, approximately 50 feet from the Project boundary.
• Commercial land uses south/southwest of the Project Site, approximately 250 feet from the Project boundary.

35 SCAQMD, CEQA Air Quality Handbook 1993, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis- handbook/ceqa-air-quality-handbook-(1993). Accessed October 30, 2023.

Slauson Ave
Hannum Ave
BuckinghamPkwy
Canterbury Dr
Windsor Way
Cambridge Way
Uplander Way
Holy Cross
Catholic Cemetery
Fox Hills
Parkette
Path: U:\GIS\GIS\Projects\2022xxx\D202201041_01_5700HannumAvenue_EIR\03_Project\Fig4.2-3_AQ_Sensitive_Receptors.mxd, dkaneshiro 11/3/2023 SOURCE: ESA, 2022; ESRI Imagery, 2022
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.2-3
Air Quality Sensitive Receptors
Project Site
Sensitive Receptors
Residential
ParkN
0 200
Feet
Buckingham
Pkwy
1 2
3 4
5 0 -D

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-25 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024

4.2.3 Project Impacts
Thresholds of Significance
The following significance thresholds below are based on the Environmental Checklist contained in Appendix G of the CEQA Guidelines. A project would have a significant impact related to air quality if it would:
• AIR-1: Conflict with or obstruct implementation of the applicable air quality plan; • AIR-2: Result in a cumulatively considerable net increase of any criteria air pollutant for which the project region is non-attainment under an applicable federal or state ambient air quality standard;36 or
• AIR-3: Expose sensitive receptors to substantial pollutant concentrations.

Potentially significant impacts related to air quality are discussed and analyzed further below.

The City determined in the Initial Study that the following environmental issue areas would result in no impacts or less-than -significant impacts and, therefore, are scoped out of this Draft EIR.

Please refer to Appendix A-2 of this Draft EIR for a copy of the Initial Study and additional information regarding the following issue area:

Would the Project:
• Result in other emissions (such as those leading to odors) adversely affecting a substantial number of people.

As detailed in the Initial Study, impacts related to other emissions, such as those leading to odors , were determined to be less than significant, and therefore are not addressed in this Draft EIR.

Pursuant to the CEQA Guidelines (Section 15064.7), a lead agency may consider using, when available, significance thresholds established by the applicable air quality management district or air pollution control district when making determinations of significance. For purposes of this analysis, the City has determined to assess the potential air quality impacts of the Project in accordance with the latest thresholds adopted by the SCAQMD in connection with its CEQA Air Quality Handbook, Air Quality Analysis Guidance Handbook, and subsequent SCAQMD guidance. While the SCAQMD CEQA Air Quality Handbook contains significance thresholds for lead, Project construction and operation would not include sources of lead emissions and would therefore not exceed the significance thresholds for lead. Unleaded fuel and unleaded paints have virtually eliminated lead emissions from mixed-use land use projects such as the Project. As a result, lead emissions are not further evaluated in this Draft EIR.

Consistency with Applicable Air Quality Plan
CEQA Guidelines Section 15125 requires an analysis of project consistency with applicable governmental plans and policies. In accordance with the SCAQMD’s CEQA Air Quality

36 For the purposes of this Draft EIR, the City of Culver City has included analysis of all regulated criteria pollutants, regardless of attainment status, for exceedances of applicable federal or state ambient air quality standards.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-26 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Handbook, the following criteria were used to evaluate the Project’s consistency with the SCAQMD’s 2022 AQMP:
• Criterion 1: Will the Project result in any of the following:
– An increase in the frequency or severity of existing air quality violations; or – Cause or contribute to new air quality violations; or – Delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.
• Criterion 2: Will the Project exceed the assumptions utilized in preparing the AQMP? Construction and Operational Emission Air Quality Standards A significant impact may occur if a project would add a cumulatively considerable contribution of a federal or S tate non-attainment pollutant. The Air Basin is currently in non -attainment for O 3, PM10, PM2.5, and lead (which is only in non-attainment for the Los Angeles County portion of the Basin) .37 SCAQMD methodology recommends that significance thresholds be used to determine the potential cumulative impacts to regional air quality along with a project’s consistency with the current AQMP.

SCAQMD has established numerical significance thresholds for construction and operational activities. The numerical thresholds are based on the recognition that the Air Basin is a distinct geographic area with a critical air pollution problem for which amb ient air quality standards have been promulgated to protect public health.
38 Given that construction impacts are temporary and
limited to the construction phase, SCAQMD has established numerical significance thresholds specific to construction activity. Based on the thresholds in the SCAQMD CEQA Air Quality Handbook, the Project would potentially result in a significant impact of a federal or State non - attainment pollutant if emissions of O
3 precursors (VOC and NOx), PM10, or PM2.5 would exceed the values shown in Table 4.2-5, SCAQMD Regional Emissions Thresholds (pounds per day).39 TABLE 4.2-5

SCAQMD REGIONAL EMISSIONS THRESHOLDS (POUNDS PER DAY)
Activity VOC NOx CO SO2 PM10 PM2.5
Construction 75 100 550 150 150 55
Operation 55 55 550 150 150 55
SOURCE: SCAQMD, SCAQMD Air Quality Significance Thresholds, March 2023.

37 SCAQMD has the Partial Nonattainment designation – Los Angeles County portion of the Basin resulted from localized emissions from the two sources in the City of Vernon and the City of Industry that are no longer in operation. It is expected that this area would receive redesignation to attainment based on current monitoring data.

SCAQMD, National Ambient Air Quality Standards (NAAQS) and California Ambient Air Quality Standards (CAAQS) Attainment Status for South Coast Air Basin.
38 SCAQMD, CEQA Air Quality Handbook 1993, http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis- handbook/ceqa-air-quality-handbook-(1993). Accessed October 30, 2023. 39 SCAQMD, Air Quality Significance Thresholds, March 2023.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-27 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Localized Significance Thresholds
In addition, SCAQMD has developed a methodology to assess the potential for localized emissions to cause an exceedance of applicable ambient air quality standards or ambient concentration limits.

Impacts would be considered significant if the following would occur:
• Maximum daily localized emissions of NO
X and/or CO during construction or operation are
greater than the applicable localized significance thresholds, resulting in predicted ambient concentrations in the vicinity of the Project Site greater than the most stringent ambient air quality standards for NO2 and/or CO.40
• Maximum daily localized emissions of PM 10 and/or PM2.5 during construction are greater than the applicable localized significance thresholds, resulting in predicted ambient concentrations in the vicinity of the Project Site to exceed 10.4 μg/m3 over 24 hours (SCAQMD Rule 403 control requirement).
• Maximum daily localized emissions of PM 10 and/or PM2.5 during operation are greater than the applicable localized significance thresholds, resulting in predicted ambient concentrations in the vicinity of the Project Site to exceed 2.5 μg/m3 over 24 hours (SCAQMD Rule 1303 allowable change in concentration).
• The following conditions would occur at an intersection or roadway within one-quarter mile of a sensitive receptor:
– The Project would cause or contribute to an exceedance of the CAAQS one-hour or eight- hour CO standards of 20 or 9.0 ppm, respectively.
– Where the CO standard is exceeded at the intersection, a project would result in a significant impact if the incremental increase due to the project is equal to or greater than

1.0 ppm for the California one -hour CO standard, or 0.45 ppm for the eight -hour CO standard.

SCAQMD has established screening criteria that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance thresholds and therefore not cause or contribute to an exceedance of the applicable ambient air quality standards or ambient concentration limits without project-specific dispersion modeling. 41 This analysis uses the
screening criteria to evaluate impacts from localized emissions where applicable.

Toxic Air Contaminants
Based on criteria set forth by the SCAQMD, the Project would expose sensitive receptors to substantial concentrations of toxic air contaminants if any of the following were to occur:42 • The Project would expose sensitive receptors to substantial concentrations of TACs if it emits carcinogenic materials or TACs that exceed the maximum incremental cancer risk of 10 in one

40 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008. 41 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008. 42 South Coast Air Quality Management District, CEQA Air Quality Handbook, Chapter 6 (Determining the Air Quality Significance of a Project) and Chapter 10 (Assessing Toxic Air Pollutants), (1993); SCAQMD Air Quality Significance Thresholds, (March 2011), http://www.aqmd.gov/docs/default-source/ceqa/handbook/scaqmd-air- quality-significance-thresholds.pdf?sfvrsn=2. Accessed October 2022.

4. Environmental Impacts Analysis

4.2. Air Quality
City of Culver City 4.2-28 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
million or a cancer burden greater than 0.5 excess cancer cases (in areas greater than or equal to one in one million) or an acute or chronic hazard index of 1.0.

As discussed further below, Methodology, construction impacts from TACs are evaluated quantitatively in a construction Health Risk Assessment (HRA) due to the use of heavy-duty, diesel equipment. For operations, the impacts are analyzed qualitatively due to the limited and minimal sources of TACs associated with operation of the proposed land uses.

Methodology
The evaluation of potential impacts to regional and local air quality that may result from the construction and long-term operations of the Project is discussed below. Additional details are provided in the Air Quality and Greenhouse Gas Emissions Calculations in Appendix C of this Draft EIR.

SCAQMD Air Quality Guidance Documents
The SCAQMD published the CEQA Air Quality Handbook to provide local governments with guidance for analyzing and mitigating project-specific air quality impacts.43 The CEQA Air Quality Handbook provides standards, methodologies, and procedures for conducting air quality analyses in EIRs and was used extensively in the preparation of this analysis. SCAQMD is currently in the process of replacing the CEQA Air Quality Handbook with the Air Quality Analysis Guidance Handbook.

Supplemental guidance/information to assist lead agencies is provided on the SCAQMD website (www.aqmd.gov/ceqa/hdbk.html) and includes: (1) EMission FACtor model (EMFAC) on-road vehicle emission factors; (2) background CO concentrations; (3) localized significance thresholds; (4) mitigation measures and control efficiencies; (5) mobile source toxics analysis; (6) off -road mobile source emission factors; (7) PM

2.5 significance thresholds and calculation methodology; and (8) updated SCAQMD Air Quality Significance Thresholds. The SCAQMD also recommends using approved models to calculate emissions from land use projects, such as the CalEEMod software, which is a model developed for the California Air Pollution Control Officers Association (CAPCOA) in collaboration with the California Air Districts. CalEEMod is a Statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professionals to quantify potential criteria pollutant and GHG emissions from a variety of land use projects.

The SCAQMD has published a guidance document called the Final Localized Significance Threshold Methodology for CEQA Evaluations that is intended to provide guidance when evaluating the localized effects from mass emissions during construction. 44 The SCAQMD adopted
additional guidance regarding PM2.5 emissions in a document called Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds. 45 This latter document

43 SCAQMD, CEQA Air Quality Handbook, April 1993.
44 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008. 45 SCAQMD, Final Methodology to Calculate Particulate Matter (PM)2.5 and PM2.5 Significance Thresholds, 2006.

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has been incorporated by the SCAQMD into its CEQA significance thresholds and Final Localized Significance Threshold Methodology.

Consistency with Air Quality Management Plan
The SCAQMD’s 2022 AQMP contains a comprehensive list of pollution control strategies directed at reducing emissions and achieving NAAQS related to these pollutants, including transportation control strategies from SCAG’s Connect SoCal designed to reduce VMT. 46 The 2022 AQMP
control strategies was developed, in part, based on regional growth projections prepared by SCAG through 2045.47 For this reason, projects whose growth is consistent with the assumptions used in Connect SoCal will be deemed to be consistent with, and therefore not conflict with, nor obstruct implementation of the 2022 AQMPs because their growth has already been included in the growth projections utilized in the formulation of the control strategies in the 2022 AQMP. Thus, emissions from projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the 2022 AQMP would not jeopardize attainment of the air pollutant reductio n goals identified in the AQMPs even if their emissions exceed the SCAQMD’s thresholds of significance.
48 As noted above, the 2022 AQMPs have been adopted by
the SCAQMD and CARB. Therefore, this analysis considers whether the Project would be in conflict with the 2022 AQMPs based on the Project’s consistency with applicable growth projections and emission control strategies developed for the AQMP. Therefore, this analysis considers whether the Project (see Chapter 2, Project Description, of this Draft EIR for additional details) would conflict with the 2022 AQMP based on the Project’s consistency with applicable growth projections and emission control strategies.

Existing Project Site Emissions
Existing operational site emissions were estimated using CalEEMod Version 2022.1, as described below. For mobile sources, the daily vehicle miles traveled were obtained for the existing uses from the Project’s transportation consultant, Gibson Transportation. 49 As discussed in the CalEEMod User’s Guide, emissions from on-site natural gas combustion were based on usage data from the CEC’s (2020, 2021) 2018 –2030 Uncalibrated Commercial Sector Forecast (Commercial Forecast) and the 2019 Residential Appliance Saturation Survey (RASS).50 Other sources of emissions from existing uses include equipment used to maintain landscaping, such as lawnmowers and trimmers. The CalEEMod software uses landscaping equipment emission factors from CARB’s Small Off-Road Engines Model v1.1 (SORE2020). The CalEEMod software assumes that landscaping equipment operates for 250 days per year in the Air Basin. Fugitive VOC

46 SCAQMD, 2022 Air Quality Management Plan (AQMP), 2022. 47 SCAQMD, 2022 AQMP, 2022.
48 SCAQMD, CEQA Air Quality Handbook, April 1993, p. 12-1. 49 Gibson Transportation Consulting, Inc provided existing use and Project VMT outputs using the City’s VMT Calculator Tool. The existing use outputs are included in Appendix C of this Draft EIR, while the Project VMT outputs are within the Project’s Transportation Study. Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR. 50 https://caleemod.com/documents/user-guide/01_User%20Guide.pdf

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emissions are based on consumer product usage factors provided by the SCAQMD within CalEEMod and architectural coating emission factors based on SCAQMD Rule 1113.

Project Construction Emissions Methodology
Construction air quality impacts were assessed based on the incremental increase in emissions compared to baseline conditions. Project construction activities that would have the potential to create regional air quality impacts include the use of heavy -duty construction equipment, such as excavators, backhoes, loaders, tractors, pavers, forklifts, vehicle trips generated by construction workers, vendor trucks, and haul trucks traveling to and from the Project Site and building activities, such as the application of paint and other surface coatings. The Project’s daily regional criteria pollutant emissions during construction have been estimated by assuming a conservative scenario for construction activities (i.e., assuming all construction occurs at the earliest feasible date, given that regulatory requirements will improve future emissions associated with fleet, vehicle, and equipment mixes) and applying the mobile source and fugitive dust emissions factors.

The emissions have been estimated using the CalEEMod software (Version 2022.1), an emissions inventory software program recommended by the SCAQMD, and the CARB on-road vehicle EMFAC2021 model. The input values used in this analysis were adjusted to be Project -specific based on equipment types and the construction schedule based on information provided by the Project’s construction representative. When information was unknown, CalEEMod defaults were used. Emissions from off-road equipment and off-road vehicles were estimated through CalEEMod since CalEEMod is based on outputs from the CARB off -road emissions factor (OFFROAD), which is the emissions estimation model developed by CARB and used to calculate emissions from construction activities, including off -road vehicles. Worker trip, concrete truck, vendor truck and haul truck trip estimates were provided by the Project’s construction representative. Emissions from construction vehicles including worker vehicles, haul trucks, vendor trucks, and concrete trucks were also estimated outside of CalEEMod using EM FAC2021 emission factors for haul, vendor and concrete trucks because CalEEMod assumes that the number of heavy -duty trucks input into the model occurs across the entire length of the applicable construction phases. However, since the applicable construction phases would not have the same number of haul trucks, vendor trucks, and concrete trucks on -site every day within each particular phase, the emissions calculations performed outside of CalEEMod are able to account for the varying maximum numbers of dail y haul truck and concrete truck trips within each of the demolition, grading/excavation and foundations phases. Haul truck trip estimates were based on excavation volumes obtained from the Project’s construction representative and 40 cubic yard demolition debris capacity haul trucks for the demolition phase and 14 cubic yard soil capacity haul trucks for the grading/excavation phase; cement truck trip estimates were based on the Project’s construction representative and 9 cubic yard concrete capacity concrete trucks. Emissions from worker trips, haul truck trips, concrete truck trips, and vendor truck trips were estimated using the CARB EMFAC2021 model. These values were applied to the construction phasing assumptions used in the criteria pollutant analysis to generate criteria pollutant emissions values for each construction activity. The Project would export approximately 57,000 cubic yards (CY) of soil during the grading/excavation phase, all of which would be exported from the Project Site. Emissions from these activities were estimated by construction phase. As discussed in Chapter 2, Project Description, of this Draft EIR, the extended construction hours are being requested over the course of approximately four (4) months during the

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grading/excavation and foundation phases of construction. The maximum daily emissions were estimated based on maximum construction activity conditions for heavy-duty off-road construction equipment and on-road mobile sources and do not represent the emissions that would occur every day during Project construction. The maximum daily emissions were compared to the SCAQMD daily regional thresholds of significance. A detailed discussion of the Project’s construction phasing and equipment list is available in Appendix C of this Draft EIR. 51 The localized effects from the on -site portion of construction emissions are evaluated at nearby sensitive receptor locations potentially impacted by the Project according to the SCAQMD’s Localized Significance Threshold Methodology.
52 The localized significance thresholds are only applicable to NOX, CO, PM10, and PM2.5. The SCAQMD has established screening criteria for projects that disturb five acres or less that can be used to determine the maximum allowable daily emissions that would satisfy the localized significance thresholds and therefore not cause or contribute to an exceedance of the applicable ambient air quality standards without project -specific dispersion modeling. The localized analysis is based on this SCAQMD screening criteria. The screening criteria depend on: (1) the area in which the Project is located SRA, (2) the size of the Project Site, and (3) the distance between the Project Site and the nearest sensitive receptor. The Project Site is located in the SCAQMD SRA 3 and could disturb up to approximately 2.23 acres on a given day. The nearest off-site air quality sensitive receptors include the residences located approximately 50 feet to the east and southeast and park uses located approximately 50 feet east of the Project Site. The maximum net daily emissions from construction of the Project were compared to the screening levels from SRA 3 with sensitive receptors located within 25 meters of the Project Site. 53 As stated above, fugitive dust emissions would result from demolition and various soil -handling activities during construction of the Project. Construction contractors are required to comply with the applicable provision of SCAQMD Rule 403 (Fugitive Dust). As discussed in subsection, Regulatory Framework , above, SCAQMD Rule 403 requires construction activities to control fugitive dust emissions during construction by complying with best available control measures, such as ensuring sufficient freeboard height for haul vehicles, covering loose material on haul vehicles, applying water or non-toxic soil stabilizers in sufficient quantities to prevent the generation of visible dust plumes on disturbed or unpaved road surfaces, and limiting vehicle speeds to 15 miles per hour on unpaved surfaces. Applicable fugitive dust control measures are incorporated into the construction emissions modeling within the SCAQMD-approved CalEEMod software.

Project construction is anticipated to commence in 2025 and require up to 30 months. If construction commences at a later date, construction emissions would be lower than those estimated below due to the use of a more energy-efficient and cleaner burning construction vehicle fleet mix,

51 Impacts from asbestos and lead-based paint from Project demolition are expected to be less than significant with compliance with regulations. For additional details please refer to the Project’s Initial Study, included in Appendix A-2 of this Draft EIR.
52 South Coast Air Quality Management District, Localized Significance Thresholds, (2003, revised 2008), http://www.aqmd.gov/home/regulations/ceqa/air-quality-analysis-handbook/localized-significance-thresholds.

Accessed October 2022.
53 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008, page 3-3. “Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.”

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pursuant to State regulations that require vehicle fleet operators to phase -in less polluting trucks.

As a result, should Project construction commence at a later date than analyzed in this Draft EIR, air quality impacts would be lower than the impacts disclosed herein.

Project Operational Emissions Methodology
Project operational emissions were estimated using CalEEMod Version 2022.1 to forecast the daily regional criteria pollutant emissions from on-site area and stationary sources that would occur during long-term Project operations.

Operation of the Project has the potential to generate criteria pollutant emissions through vehicle and truck trips traveling to and from the Project Site. For mobile sources, the estimated vehicle trips and maximum daily VMT were provided for the Project uses in the Project’s Transportation Study where the VMT analysis used the City’s VMT analysis procedures and Transportation Study Criteria and Guidelines.
54 Therefore, the Project’s mobile source operational emissions represent a maximum day with the highest estimated VMT. The EMFAC2021 model was run in the emissions mode (also referred to as the “Burden” mode) and used to generate County-specific vehicle fleet emission factors in units of grams or metric tons per mile. These emission factors were then applied to the daily VMT to obtain daily mobile source emissions. The Project’s operational emissions were estimated using the CalEEMod software. CalEEMod was used to forecast the daily regional criteria pollutant emissions from on-site areas and stationary sources that would occur during long- term Project operations. Emissions would result from area sources located on-site, such as landscaping equipment, architectural coating, and use of consumer products. The Project is not expected to contain any large stationary combustion equipment, such as large boilers or combustion turbines. CalEEMod generates default natural gas usage factors based on the California Energ y Commission (CEC) Electricity Demand Forecast Zone (EDFZ) and based on energy consumption estimates from the CEC’s (2020, 2021) 2018–2030 Uncalibrated Commercial Sector Forecast and 2019 Residential Appliance Saturation Survey. The Project would be required to meet the Title 24 standards in effect at the time of building permit application. For example, the Project would be required to comply with the 2022 Title 24 Building Energy Efficiency Standards (which are effective for building permit applications that are applied for on or after January 1, 2023).

CalEEMod includes building energy efficiency factors for the 2019 Ti tle 24 Building Energy Efficiency Standards but does not include correction factors for the 2022 standards. 55 As described
in GHG-PDF-1, the Project will utilize only electricity and no natural gas in all land uses except for the retail space, supporting local and State sustainability goals and decarbonization strategies consistent with the City’s All -Electric Building Ordinance and CARB’s 2022 Climate Change Scoping Plan for Achieving Carbon Neutrality (see Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for additional details). While building electrification would result in higher electricity usage, it would eliminate the use of a fossil fuel and the associated criteria pollutant emissions (i.e., natural gas combustion) from building energy demand.

54 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR
55 This would be considered conservative because the Project would be required to comply with newer and more stringent 2022 Title 24 standards compared to the default 2019 Title 24 standards incorporated in CalEEMod version 2022.1.

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Operational air quality impacts were assessed based on the incremental increase in emissions compared to baseline conditions. As discussed previously, t he Project Site is currently developed with a 30,672 square foot two -story office building with associated landscaping and surface parking, which would be demolished and removed to support development of the Project. Existing site emissions are associated with vehicle trips to and from the Project Site, landscaping equipment, on-site combustion of natural gas for heating, and fugitive emissions of VOCs from the use of aerosol products and coatings. Therefore, the net change in operational emissions is based on the difference between the existing Project Site emissions and the emissions of the Project Site at full buildout. The maximum daily net emissions from operation of the Project are compared to the SCAQMD daily regional significance thresholds.

The localized effects from the on -site portion of the maximum daily net emissions from Project operation were evaluated at the nearby sensitive receptor locations that would be potentially impacted by operation of the Project according to the SCAQMD’s Final Localized Significance Threshold Methodology .
56 The localized impacts from operation of the Project were assessed similar to the construction emissions, as discussed previously. For further explanation, please see the Air Quality and Greenhouse Gas Emissions Technical Documentation in Appendix C of this Draft EIR.

Operational impacts were assessed for the Project buildout year (i.e., as early as 2027 assuming construction begins at the earliest possible time in 2025). If the onset of Project operations is delayed to a later date than assumed in the modeling analysis, operational impacts would be less than those analyzed here in 2027 due to the improving vehicle technology that would be more fuel- efficient and lead to a cleaner vehicle fleet mix traveling to and from the Project Site as reflected in EMFAC mobile source emission factors. As a result, Project buildout at a later date than analyzed in emissions modeling would result in air quality emission impacts that would be lower than the impacts disclosed herein.

Carbon Monoxide Hotspots
Emissions of CO are generated in greatest quantities from motor vehicle combustion of fossil fuels, and are usually concentrated at or near ground level because they do not readily disperse into the atmosphere, particularly under cool, stable (i.e., low or no wind) atmospheric conditions. Localized areas where ambient concentrations exceed State and/or federal standards are termed CO hotspots.

The potential for the Project to cause or contribute to the formation of offsite CO hotspots are evaluated based on prior dispersion modeling of the four busiest intersections in the Air Basin that has been conducted by SCAQMD for its CO Attainment Demonstration Plan in the conducted CO modeling for the 2003 AQMP for the four worst -case intersections in the Air Basin that include:

Wilshire Boulevard and Veteran Avenue; Sunset Boulevard and Highland Avenue; La Cienega Boulevard and Century Boulevard; and Long Beach Boulevard and Imperial Highway. 57 In the
2003 AQMP, SCAQMD notes that the intersection of Wilshire Boulevard and Veteran Avenue is the most congested intersection in Los Angeles County, with an average daily traffic volume of approximately 100,000 vehicles per day. This intersection is located near the on- and off-ramps to

56 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008. 57 The 2003 AQMP is the most current AQMP that provides modeling and attainment demonstration for CO.

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Interstate (I) 405 in Westwood. The 2003 AQMP estimated that the 1 -hour concentration for this intersection was 4.6 ppm, which indicates that the most stringent 1 -hour CO standard (20.0 ppm) would likely not be exceeded until the daily traffic at the intersection exceeded more than 400,000 vehicles per day. The AQMP CO hotspots modeling also took into account worst -case meteorological conditions and background CO concentrations. As an initial screening step, if a project intersection does not exceed 400,000 vehicles per day, then the project does not need to prepare a detailed CO hot spot analysis. If a project would potentially result in a CO hotspot based on the initial screening, detailed modeling may be performed using California LINE Source Dispersion Model, version 4 (CALINE4), which is a model used to assess air quality impacts near transportation facilities (i.e., roadways, intersections, street canyons, and parking facilities).

Toxic Air Contaminants Impacts
The SCAQMD has also adopted land use planning guidelines in the Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, which considers impacts to sensitive receptors from facilities that emit TAC emissions . SCAQMD’s siting distance recommendations are the same as those provided by CARB (e.g., a 500 -foot siting distance for sensitive land uses proposed in proximity of freeways and high-traffic roads, and the same siting criteria for distribution centers and dry-cleaning facilities). The SCAQMD’s document introduces land use-related policies that rely on design and distance parameters to minimize emissions and lower potential health risk . SCAQMD’s guidelines are voluntary initiatives recommended for consideration by local planning agencies.

Construction
The greatest potential for TAC emissions during construction would be related to DPM emissions associated with heavy -duty equipment during demolition, excavation and grading activities .

Construction activities associated with the Project would be sporadic, transitory, and short term in nature (approximately 30 months). Although Project construction would be temporary, construction impacts associated with TACs are addressed quantitatively in a refined HRA. OEHHA is responsible for developing and revising guidelines for performing health risk assessments (HRAs) under the State’s the Air Toxics Hot Spots Program Risk Assessment (AB 2588) regulation. In March 2015, OEHHA adopted revised guidelines that update the previous guidance by incorporating advances in risk assessment with consideration of infants and children using Age Sensitivity Factors (ASF). The construction HRA was performed in accordance with the revised OEHHA Air Toxics Hot Spots Program Guidance Manual for Preparation of Health Risk Assessments (OEHHA Guidance).
58 The analysis incorporates the estimated construction emissions, as previously discussed, and dispersion modeling using the USEPA AERMOD model with meteorological data from the closest SCAQMD monitoring station.

Operations
During long-term operations, TACs could be emitted as part of periodic maintenance operations, from routine cleaning, from periodic painting, etc., and from periodic visits from delivery trucks and service vehicles, and from maintenance . However, these events are expected to be occasional

58 California Environmental Protection Agency, Office of Health Hazard Assessment, Air Toxics Hot Spots Program, Risk Assessment Guidelines, Guidance Manual for Preparation of Health Risk Assessments, 2015.

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and result in minimal emissions exposure to off -site sensitive receptors. As the Project consists only of residential and retail uses, the Project would not include sources of substantial TAC emissions identified by the SCAQMD or CARB siting recommendations. 59, 60 For operations, the impacts are analyzed qualitatively due to the limited and minimal sources of TACs associated with operation of the proposed land uses.

Project Design Features
No specific project design features are proposed with regard to air quality. However, the Project would incorporate project design features to support and promote environmental sustainability as discussed under Section 4.6, Greenhouse Gas Emissions, of this Draft EIR (refer to Project Design Features GHG-PDF-1 and TRAF -PDF-2). While these features are designed primarily to reduce GHG emissions, they would also serve to reduce criteria air pollutants discussed herein.

Analysis of Project Impacts
Threshold AIR-1: The Project would result in a significant impact if it would conflict with or obstruct the implementation of the applicable air quality plan.

Impact Analysis
SCAQMD CEQA Air Quality Handbook Policy Analysis
The following analysis addresses the Project’s consistency with applicable SCAQMD and SCAG policies, inclusive of regulatory compliance. In accordance with SCAQMD’s CEQA Air Quality Handbook, Chapter 12, the following criteria are required to be addressed to determine the Project’s consistency with applicable SCAQMD and SCAG policies:
• Criterion 1: Will the Project result in any of the following:
– An increase in the frequency or severity of existing air quality violations; or – Cause or contribute to new air quality violations; or – Delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.
• Criterion 2: Will the Project exceed the assumptions utilized in preparing the AQMP – Is the Project consistent with the population and employment growth projections upon which AQMP forecasted emission levels are based;
– Does the Project include air quality mitigation measures; or – To what extent is Project development consistent with the AQMP control measures? The Project’s potential impacts with respect to these criteria are discussed to assess the consistency with the SCAQMD’s 2022 AQMP and other applicable plans and policies.

59 SCAQMD, Guidance Document for Addressing Air Quality Issues in General Plans and Local Planning, 2005, Table 2-3.
60 CARB, Air Quality and Land Use Handbook: A Community Health Perspective, 2005, Table 1-1.

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Criterion 1
With respect to the first criterion, as discussed in more detail under the analysis for Threshold AIR- 2 below, regional concentrations of NO 2 as NOX, VOC, SO2, CO, PM10, and PM 2.5 have been analyzed for the Project. As shown in Table 4.2 -6 in Threshold AIR-2 below, regional maximum daily Project construction emissions would not exceed the SCAQMD regional construction emissions thresholds. As shown in Table 4.2-7 in Threshold AIR-2 below, regional maximum daily Project operations emissions would not exceed the SCAQMD regional operations emissions thresholds. Therefore, the Project would not increase in the frequency or severity of existing air quality violations, cause or contribute to new air quality violations or delay timely attainment of air quality standards or the interim emission reductions specified in the AQMP.

As discussed under the analysis for Threshold AIR -3 below, localized concentrations of NO 2 as
NOX, CO, PM10, and PM2.5 have been analyzed for the Project. SO2 emissions would be negligible during construction and long-term operations and, therefore, would not have the potential to cause or effect a violation of the SO
2 ambient air quality standard. Since VOCs are not a criteria pollutant, there is no ambient standard or localized threshold for VOCs. However, due to the role VOCs play in O
3 formation, it is classified as a precursor pollutant, and only a regional emissions threshold has been established.

The Project’s NOX, CO, PM10, and PM2.5 emissions during construction and operations were analyzed: (1) to ascertain potential effects on localized concentrations; and (2) to determine if there is a potential for such emissions to cause or effect a violation of the ambient air quality standards for NO
2, CO, PM10, and PM2.5. As shown in Table 4.2 -8, the increases in localized emissions of NO2, CO, PM10, and PM2.5 during construction would not exceed the SCAQMD -recommended localized significance thresholds at sensitive receptors in proximity to the Project Site. As shown in Table 4.2-9, the increases in localized emissions of NO X, CO, PM10, and PM2.5 emissions
during operation of the Project would not exceed the SCAQMD -recommended localized significance thresholds at sensitive receptors in proximity to the Project Site.

The 2022 AQMP is the current SCAQMD -adopted management plan for continued progression toward clean air and compliance with State and federal requirements (it is not yet adopted by the USEPA for inclusion in the State Implementation Plan). It includes a comprehensive strategy aimed at controlling pollution from all sources, including stationary sources, on- and off -road mobile sources, and area sources. It builds upon measures already in place from previous AQMPs and includes a variety of new strategies (e.g., regulation, accelerated deployment of available cleaner technologies, best management practices, co -benefits from existing programs, incentives, etc.) to achieve the NAAQS. The Project would be required to comply with all new and existing regulatory measures set forth by the SCAQMD so as not to potentially increase the frequency or severity of an existing violation or cause or contribute to a new violation. Implementation of the Project would not interfere with air pollution control measures listed in the 2022 AQMP and therefore would not delay attainment of the air quality standards.

The Project would not introduce any substantial stationary sources of emissions; therefore, CO is the appropriate benchmark pollutant for assessing local area air quality impacts from post -

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construction motor vehicle operations.61 As indicated below in Threshold AIR-3, no intersections would result in a CO hotspot in excess of the ambient air quality standards, and impacts would be less than significant. Therefore, the Project would not increase the frequency or severity of an existing CO violation or cause or contribute to new CO violations.

Therefore, in response to Criterion 1, the Project would not increase the frequency or severity of an existing violation or cause or contribute to new violations for ozone or other criteria pollutants.

Impacts regarding the timely attainment of air quality standards or interim emission reductions specified in the AQMP and impacts would be less than significant.

Criterion 2
With respect to the second criterion for determining consistency with 2022 AQMP growth assumptions, the projections in the AQMP for achieving air quality goals are based on assumptions in Connect SoCal regarding population, housing, and growth trends. Determining whether or not a project exceeds the assumptions reflected in the 2022 AQMP involves the evaluation of consistency with applicable population, housing, and employment growth projections and appropriate incorporation of 2022 AQMP control measures. The following discussion provides an analysis with respect to these criteria.

Conflict with Air Quality Management Plan
Construction and operation of the Project would comply with applicable required fleet rules and control strategies to reduce on-road truck emissions (i.e., 13 CCR, Section 2025 [CARB Truck and Bus regulation]), and other applicable SCAQMD rules specified and incorporated in the 20 22 AQMP. As discussed under Air Quality - Methodology, projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the AQMP would not jeopardize attainment of the air quality levels identified in the AQMP even if their emissions exceed the SCAQMD’s thresholds of significance. As discussed below, compliance with the applicable required fleet rules and control strategies and requirements would render it consistent with, and meet or exceed, the AQMP requirements for control strategies intended to reduce emissions from construction equipment and activities. Thus, the Project’s construction-related and operations-related criteria pollutant emissions would not cause the Air Basin’s criteria pollutant emissions to worsen so as to impede the SCAQMD’s efforts to achieve attainment with respect to any criteria pollutant for which it is currently not in attainment of the NAAQS and CAAQS (e.g., ozone, PM10, and PM2.5),
62 or to cause the Air Basin to deteriorate
from its current attainment status with respect to any other criteria pollutant emissions.

With respect to the determination of consistency with or potential conflicts with the 2022 AQMP growth assumptions, the projections in the 2022 AQMP for achieving air quality goals are based on assumptions in Connect SoCal regarding population, housing, and growth trends. Determining whether or not a project exceeds the assumptions reflected in the AQMP involves the evaluation of

61 SCAQMD, CEQA Air Quality Handbook, Chapter 12, Assessing Consistency with Applicable Regional Plans, April 1993.
62 The Los Angeles County portion of the Air Basin is designated as nonattainment for the federal lead standard; however, this was due to localized emissions from two lead-acid battery recycling facilities in the City of Vernon and the City of Industry that are no longer operating. For reference see SCAQMD, Board Meeting, Agenda No. 30, Adopt the 2012 Lead State Implementation Plan for Los Angeles County, May 4, 2012.

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three criteria: (1) consistency or conflict with applicable population, housing, and employment growth projections; (2) project mitigation measures (discussed under Section 2, Mitigation Measures, below); and (3) appropriate incorporation of AQMP land use planning strategies (discussed under Subsection (ii), Operations, below).
• Is the Project consistent with or would the Project conflict with the population and employment growth projections upon which AQMP forecasted emission levels are based? Construction Growth Projections
The Project would generate short-term construction jobs, but these jobs would not necessarily bring new construction workers or their families into the region since construction workers are typically drawn from an existing regional pool of construction workers who travel among construction sites within the region as individual projects are completed, and are not typically brought from other regions to work on developments such as the Project. Moreover, these jobs would be relatively small in number and temporary in nature, lasting at a maximum of approximately 30 months for the entire duration of the construction period, but would likely be shorter due to varying construction phases.

Therefore, the Project’s construction jobs would not conflict with the employment or population projections upon which the 2022 AQMP forecasted emissions levels are based.

Operation Growth Projections
As stated above, for purposes of the air quality modeling, the Project is assumed to be operational in 2027 to provide a conservative estimate of emissions. However, if the Project buildout occurs at a later time, the emissions would be less than disclosed herein. As discussed in Chapter 4.9, Population and Housing, of this Draft EIR, the Project’s growth would fall within the growth projections contained in Connect SoCal, which forms the basis of the growth projections in the 2022 AQMP. As discussed in Section 4.9, Population and Housing, of this Draft EIR, based on Connect SoCal growth projections, the Project’s proposed 309 units would comprise approximately 36 percent of SCAG’s year 2045 estimated increase of 862 households within the City, relative to 2020.
63 Based on Connect SoCal growth projections, the Project’s projected 733 resident population would comprise approximately 57 percent of SCAG’s year 2045 estimated increase of 1,293 population within the City, relative to 2020. 64 Based on Connect SoCal growth projections, the Project would result in an decrease in the number of employees on the Project Site of approximately 127 net new employees, compared to existing uses which would comprise a decrease of less than 1 percent of SCAG’s year 2045 estimated increase of 4,138 employees within the City, relative to 2020.65 Therefore, the Project’s contribution to population, households and employment would be consistent with SCAG population and employment projections for the City and would be

63 SCAG, 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020, page 34, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth- forecast.pdf?1606001579. Accessed July 3, 2023. Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information.
64 SCAG, 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020, page 34, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth- forecast.pdf?1606001579. Accessed July 3, 2023. Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information.
65 SCAG, 2020 RTP/SCS: Demographics and Growth Forecast (Technical Report), September 2020, page 34, https://scag.ca.gov/sites/main/files/file-attachments/0903fconnectsocal_demographics-and-growth- forecast.pdf?1606001579. Accessed July 3, 2023. Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information.

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consistent with SCAG’s Connect SoCal goals and with the growth projections contained in Connect SoCal. Accordingly, the Project’s generation of population, households and employees would not conflict with employment generation projections contained in Connect SoCal . Furthermore, as discussed in Section 4.9, Population and Housing, of this Draft EIR, the Culver City October 2021- 2029 Housing Element, which is based on the SCAG’s 6th Cycle Regional Housing Needs Assessment (RHNA)
66 allocations, indicates the total housing growth need for the City during this planning period through 2029 is 3,341 units. Accordingly, the Project’s proposed housing would constitute 9.2 percent of the 6th Cycle RHNA allocations between 2021 and 2029 (re fer to Section 4.9, Population and Housing , of this Draft EIR for additional details). Therefore, the Project would promote fulfillment of the City’s future updated Housing Element goals and is consistent with SCAG and the City’s 6th Cycle RHNA allocations. Refer to Section 4.7, Land Use and Planning , and 4.9, Population and Housing, of this Draft EIR, for additional information regarding consistency with Connect SoCal. As discussed above under Air Quality - Methodology, projects, uses, and activities that are consistent with the applicable growth projections and control strategies used in the development of the 2022 AQMP would not jeopardize attainment of the air quality reductions identified in the 2022 AQMP, even if t heir emissions exceed the SCAQMD’s thresholds of significance.
67 The Project would not obstruct implementation of the 2022 AQMP, as discussed below under Thresholds AIR-2 and AIR-3, since its regional construction and operational emissions would be less than significant, and its localized construction and operational emissions would be less than significant. As a result, the Project would not conflict with the growth projections and control strategies used in the development in the 2022 AQMP. Impacts would be less than significant.
• Does the Project include air quality mitigation measures? As further discussed below, see under Threshold AIR-2 and Threshold AIR-3, and as shown in Table

4.2-6 through Table 4.2-9 , regional and localized maximum daily Project construction and operations emissions would not be expected to exceed the SCAQMD numerical indicator s of significance and the Project would not require implementation of mitigation measures during construction and operations. As such the Project would not conflict with this AQMP criterion. • To what extent is Project development consistent with the AQMP control measures? Control Strategies
Construction
During its construction phase, the Project is required to comply with CARB’s requirements to reduce short-term emissions from on -road and off -road diesel equipment, and with SCAQMD’s regulations, such as Rule 403 for controlling fugitive dust and Rule 1113 for controlling VOC emissions from architectural coatings. The Project is also required to utilize construction contractors in compliance with State on-road and off-road vehicle rules, including the ATCM that limits heavy-duty diesel motor vehicle idling to five minutes at any location (Title 13 CCR, Section

66 SCAG’s 6th Cycle Regional Housing Needs Assessment focused on existing need (current housing shortages and overcrowding) plus projected growth, which takes into account factors beyond what was used to determine the 2020 RTP/SCS’s (Connect SoCal) projected growth. Therefore, the 6th Cycle RHNA allocation for the City results in a higher allocation of housing than what is represented in Connect SoCal, which is focused solely on projected or future growth (see Section 4.9, Population and Housing, of this Draft EIR, for additional details). 67 SCAQMD, CEQA Air Quality Handbook, April 1993, page 12-1.

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2485), the Truck and Bus regulation that reduces NOX, PM10, and PM2.5 emissions from existing diesel vehicles operating in California (13 CCR, Section 2025), and the In-Use Off -Road Diesel Fueled Fleets regulation that reduces emissions by the installation of diesel soot filters and encouraging the retirement, replacement, or repower of older, dirtier engines with newer emission controlled models (13 CCR, Section 2449). The Project’s construction contractor would be required to comply with these regulatory control measures. As discussed above, the Project regional and localized maximum daily Project construction emissions would not exceed the SCAQMD regional construction emissions thresholds and would not conflict with or obstruct implementation of the applicable AQMP. Therefore, Project impacts would be less than significant. As the achievement and maintenance of NAAQS and CAAQS is the goal of the 2022 AQMP, the Project would therefore not interfere with air pollution control strategies listed in the 2022 AQMP. Compliance with these regulatory control measures would ensure the Project would not conflict with 2022 AQMP control strategies intended to reduce emissions from construction equipment and activities.

Operations
The Project’s location, design, and land uses would be consistent with the 2022 AQMP during operations. As discussed above, the 2022 AQMP include s land use and transportation strategies from Connect SoCal that are intended to reduce VMT and resulting regional mobile source emissions. The majority of these strategies are to be implemented by cities, counties, and other regional agencies, such as SCAG and SCAQMD, although some can be furthered by individual development projects.

The Project’s location, design, and land uses would support transportation control strategies related to reducing vehicle trips for patrons and employees by increasing residential and retail density near public transit. The Project Site is served by several public transit options, including Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 306 Hannum Ave/Buckingham Parkway, approximately 210 feet west of the Project Site. In addition, the Project Site is located 0.6 mile east of the Culver City Transit Center which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6 . Furthermore, the Project would also implement transportation demand management (TDM) measures in the Project’s Transportation Demand Management (TDM) Program (see Project Design Feature TRAF -PDF-2) which includes Transportation Information Center (TIC); Bicycle Parking and Amenities, which includes 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section 7.05.015; EV parking and charging would be available for residential and commercial use. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready in accordance with City Municipal Code Section

17.320.035.O.3. Forty-four (44) total spaces (41 residential + 3 commercial) would have EV charging stations. Pedestrian-Friendly Environment; Employee Parking; Bus Stop Improvements that would reduce Project-related VMT (refer to Section 4.11, Transportation, of this Draft EIR, for additional details regarding the TDM Program). The Project is an infill project that provides increased opportunities to use alternative transportation modes by co- locating complementary residential and retail land uses on an infill Project Site that is in close proximity to existing off-site commercial and residential uses, being located within a quarter -mile of off -site commercial and residential uses, and would occupy a location that is highly accessible by existing public transit options along Hannum Avenue and Buckingham Parkway in a highly walkable area well served by

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public transportation for visitors, residents, employees and patrons, the Project would reduce vehicle trips and VMT, and achieve a corresponding reduction in air pollutant emissions.

The Project’s mobile source emissions are calculated based on the VMT generated by the Project, as obtained from the Project’s Transportation Study. 68 While the Project would also implement transportation demand management (TDM) measures in the Project’s Transportation Demand Management (TDM) Program (see Project Design Feature TRAF -PDF-2) that would reduce Project-related VMT (refer to Section 4.11, Transportation, of this Draft EIR, for additional details regarding the TDM Program), these TDM measures in TRAF -PDF-2 were conservatively not credited to the GHG analysis as the exact amount of VMT reduction associated the measures are not precisely quantifiable and ar e qualitatively discussed in the analysis in Section 4.11, Transportation. Thus, Project development would not conflict with the 2022 AQMP with respect to transportation control strategies from Connect SoCal that are intended to reduce VMT and resulting regional mobile source emissions.

Based on the above, the Project would not conflict with the criteria identified in SCAQMD’s CEQA Air Quality Handbook and would not conflict with or obstruct the implementation of both the 2022 AQMP. Therefore, Project impacts related to the 2022 AQMP would be less than significant.

The City of Culver City General Plan and Mandatory Green Building Program Although the City’s General Plan does not have an Air Quality Element, the project would be consistent with General Plan and the Circulation Element of the General Plan. The Project Site is located within the Fox Hills neighborhood. The Project Site’s Land Use designation of Regional Center has a corresponding Zone of Regional Business Park (CRB). The Project is proposing to change the Project Site’s zoning designation to Planned Development (PD) with adoption of a Comprehensive Plan that would serve as the overarching entitlement mechanism for the Project Site. Per the Zoning Code, a Comprehensive Plan is appropriate for large -scale development as it allows flexibility in the application of zoning code standards to encourage innovation in site planning and design and to support more effective responses to the settings of such properties and other environmental considerations.
69 To permit this, a Comprehensive Plan regulates permitted uses, development standards, and conditions of approval on a Project Site. To achieve the Project’s proposed density and mix of uses, a General Plan Amendment Map would be needed to designate the Project Site as General Corridor. The Project’s unit count is consistent with the recently-adopted October 2021-2029 Housing Element’s Mixed-Use High Designation and state density bonus law.

Refer to Draft EIR, Section 4.7, Land Use and Planning, for additional details regarding requested zoning actions for the Project.

The Project would be consistent with the Circulation Element of the General Plan through encouraging pedestrian-oriented design where the Project design allows residents to be able to walk through and around the Project Site with multiple access points and community connections to the development.

68 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
69 City of Culver City Zoning Code, Title 17, Section 17.560, Comprehensive Plans, https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-56855#JD_CHAPTER17.560.

Accessed April 2023.

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In addition, the first floor retail use at the corner of Hannum Avenue and Buckingham Parkway would serve as a pedestrian point of interest on the Project Site where the Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza fronting Hannum Avenue, which would provide open space for both residents and visitors. Furthermore, as discussed previously, the Project is served by several public transit options, including Metro Bus Line 5C2 – Overland/Fox Hills, which includes Stop 306 Hannum Ave/Buckingham Parkway, approximately 210 feet west of the Project Site. In addition, the Project Site is located 0.6 mile east of the Culver City Transit Center which serves Los Angeles County Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6.

Per CCMC Section 7.05.015, the Project proposes a TDM Program as described in Project Design Feature TRAF-PDF-2. The Project’s TDM Program (TRAF-PDF -2) includes TDM measures to reduce peak hour vehicular traffic and air emissions to and from the Project Site (see 4.11, Transportation, of this Draft EIR, for additional details) . The Project’s TDM Program (TRAF- PDF-2) includes TDM measures to reduce peak hour vehicular traffic and air emissions to and from the Project Site. The Project's TDM Program (TRAF- PDF-2) includes a comprehensive program of measures, design features, transportation services, education programs, and incentives intended to reduce the effect of Project traffic from residents, employees, and visitors to the Project Site during the most congested time periods of the day. The TDM measures include, but are not limited to, the following: Transportation Information Center (TIC); b icycle parking and amenities, which includes 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section 7.05.015; and EV parking and charging would be available for residential and commercial use. A total of 86 parking spaces (81 residential + 5 commercial) would be electric vehicle (EV) capable. Forty -four (44) total spaces (41 residential + 3 commercial) would be EV ready in accordance with City Municipal Code Section 17.320.035.O.3. The Project would provide pedestrian connections; employee parking; and bus stop improvements (if deemed necessary by the City). Additional TDM strategies that will be provided by the Project to further reduce VMT and reliance on single-passenger vehicles, and help future residents and employees manage each TDM element and maximize program participation include: Project Transportation Coordinator; Transportation Information Packet for New Residents and Employees; b ike repair station; subsidized shared-ride/Uber/Lift service; and transit passes (see Section 4.11, Transportation, of this Draft EIR for a detailed explanation of all TDM measures contained in TRAF -PDF-2). Thus, the Project would implement strategies and action plans as part of a comprehensive TDM Program (TRAF-PDF-2) in compliance with the requirements set forth in CCMC Section 07.05.015 to reduce single occupancy vehicle trips while promoting the use of alternative transportation modes, thereby reducing Project VMT. Providing pedestrian and bicycle access that minimizes barriers and links the Project Site with external streets encourages people to walk, bike and take public transit, instead of driv ing reduces VMT. Therefore, the Project would support a land use pattern that encourages reduced vehicle trips and transportation air pollutant emissions.

As described in Section 4.6, Greenhouse Gas Emissions, the Project would be designed with Project Design Feature GHG-PDF-1 and be required to comply with the Culver City Green Building Program and ordinances where the Project would achieve the USGBC LEED Certified performance level or higher or equivalent performance level to improve building energy efficiency, and design features would include energy conservation, water conservation, TDM and mobility measures, and pedestrian- and bicycle-friendly site design. EV parking and charging would be available for residential and

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commercial use. A total of 8 6 parking spaces (8 1 residential + 5 commercial) would be electric vehicle (EV) capable. Forty-four (44) total spaces (41 residential + 3 commercial) would be EV ready.

Forty-four (44) total spaces (41 residential + 3 commercial) would have EV charging stations. The Project would include 92 bicycle spaces, consisting of 11 short-term and 81 long-term bicycle parking spaces. As it relates to energy conservation, the Project would include LED lighting throughout the Project Site and would install ENERGY STAR-rated appliances. As it relates to water conservation, the Project would incorporate efficient water management through low flow faucets and water- efficient landscape design with weather-based controllers and drip irrigation systems. In addition, the Project would include installation of a solar photovoltaic system with 1 kW solar photovoltaic panels per 10,000 sf in order to achieve compliance with the City of Culver City’s solar photovoltaic requirement, per the City’s Green Building Ordinance and CALGreen standards. In addition, as part of Project Design Feature GHG-PDF-1, the Project would directly support building electrification as the Project will utilize only electricity and no natural gas in all land uses except for the retail space.

These features would indirectly reduce air pollutant emissions from the Project.

Based on the above analysis, the Project would not conflict with applicable goals, objectives, and policies of the City of Culver City General Plan and the Culver City Mandatory Green Building Program pertaining to air quality, and impacts would be less than significant.

Mitigation Measures
No mitigation measures are required as impacts would be less than significant.

Level of Significance After Mitigation
Not applicable. Impacts regarding consistency with the applicable air quality plan would be less than significant.

Threshold AIR-2: The Project would result in significant impact if it would result in a cumulatively considerable net increase of any criteria pollutant for which the project region is non- attainment under an applicable federal or state ambient air quality standard.

Impact Analysis
Construction
Construction of the Project has the potential to generate temporary regional criteria pollutant emissions through the use of heavy-duty construction equipment, such as excavators and forklifts, through vehicle trips generated by workers and haul trucks tra veling to and from the Project Site, and through building activities, such as the application of paint and other surface coatings. In addition, fugitive dust emissions would result from demolition and various soil-handling activities.

Construction emissions, primarily NO
X, would result from the use of construction equipment, such as dozers and loaders. Construction emissions can vary substantially from day to day, depending on the level of activity, the specific type of construction activity, and prevailing weather conditions. 70 70 Impacts from asbestos and lead-based paint from Project demolition are expected to be less than significant with compliance with regulations. For additional details please refer to Section 4.7, Hazards and Hazardous Materials, of this Draft EIR.

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The maximum daily construction emissions for the Project were estimated for each construction phase. The maximum daily emissions are predicted values for a representative worst-case day, and do not represent the actual emissions that would occur for every day of construction, which would likely be lower on many days. As stated above, in order to provide a conservative emissions analysis, for modeling purposes, construction emissions were modeled beginning in 2025. Detailed emissions calculations are provided in Appendix C of this Draft EIR.

The results of the criteria pollutant calculations are presented in Table 4.2-6, Estimated Maximum Unmitigated Regional Construction Emissions . As previously stated, within CalEEMod, fugitive dust emissions include the application of water as a control measure consistent with SCAQMD Rule 403. Therefore, emissions include dust control measures as required by SCAQMD Rule 403 (Control of Fugitive Dust) . Emissions also include fugitive VOC control measures to be implemented by architectural coating emission factors required by SCAQMD Rule 1113 (Architectural Coatings). As shown in Table 4.2-6, construction-related daily emissions would not exceed the SCAQMD thresholds of significance. Therefore, the Project’s regional construction emissions impacts would be less than significant.

TABLE 4.2-6

ESTIMATED MAXIMUM UNMITIGATED REGIONAL CONSTRUCTION EMISSIONS (POUNDS PER DAY) Construction Phases VOC NOX CO SO2 PM10b PM2.5b
Demolition - 2025 1 11 15 <1 1 1
Grading - 2025 2 43 37 <1 7 2
Foundations - 2025 2 23 28 <1 3 1
Foundations - 2026 2 15 23 <1 2 1
Building Construction - 2026 2 19 28 <1 3 1
Finishing/Painting - 2026 14 5 15 <1 4 1
Finishing/Painting - 2027 14 5 14 <1 4 1
Paving/Sitework - 2027 1 6 12 <1 2 1
Maximum Daily Construction Emissionsa 14 43 37 <1 7 2
SCAQMD Regional Significance Threshold 75 100 550 150 150 55 Exceeds Threshold? No No No No No No
NOTES:
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix C. b Emissions include fugitive dust control measures consistent with SCAQMD Rule 403.

SOURCE: ESA 2023

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Operation
Operational criteria pollutant emissions were calculated for mobile, area, and energy sources for the Project operational year, 202 7. Operational emission estimates include compliance with SCAQMD Rule 1113 (Architectural Coatings), which limits the VOC content of architectural coatings. Daily vehicle miles traveled were obtained from the Transportation Study.71 Natural gas usage factors are based on recreational and retail data from the C EC, and landscape equipment emissions are based on off-road emission factors from CARB. Emissions from the use of consumer products and the reapplication of architectural coatings are based on data provided in CalEEMod.

As discussed previously, operational emissions are reduced based on the estimated operational emissions of the existing uses on the Project Site.

The results of the regional criteria pollutant emission calculations for VOC, NO X, CO, SOX, PM10,
and PM2.5 for the Project are presented in Table 4.2-7, Estimated Maximum Unmitigated Regional Operational Emissions (pounds per day). The Project’s operational-related daily emissions would not exceed the SCAQMD thresholds of significance. Therefore, the Project’s regional operational emissions impacts would be less than significant.

TABLE 4.2-7

ESTIMATED MAXIMUM UNMITIGATED REGIONAL OPERATIONAL EMISSIONS (POUNDS PER DAY) Source VOC NOX CO SO2 PM10 PM2.5
Area (Consumer Products, Landscaping) 12 <1 28 <1 <1 <1 Energy (Natural Gas) <1 <1 <1 <1 <1 <1
Mobile Vehicles 3 4 27 <1 8 2
Project Maximum Daily Operational Emissions 15 4 55 <1 8 2 Existing Site Emissions Removed 2 1 8 <1 1 <1
Net Maximum Regional Operational Emissionsa 15 4 55 <1 8 2 SCAQMD Significance Threshold 55 55 550 150 150 55
Exceeds Thresholds? No No No No No No
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix C SOURCE: ESA 2023

Mitigation Measures
Construction
No mitigation measures are required as impacts would be less than significant.

Operation
No mitigation measures are required as impacts would be less than significant.

71 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.

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Level of Significance After Mitigation
Not applicable. Project-specific impacts regarding construction and operational regional air quality impacts were determined to be less than significant.

Threshold AIR-3: The Project would expose sensitive receptors to substantial pollutant concentrations.

Impact Analysis
Localized Emissions
Construction
As explained above, the localized construction air quality analysis was conducted using the methodology prescribed in the SCAQMD Final Localized Significance Threshold Methodology.72 The SCAQMD screening criteria provided in the Final Localized Significance Threshold Methodology were used to determine localized construction emissions thresholds for the Project. The maximum daily localized construction emissions for the Project were estimated for each construction phase and analyzed using screening criteria applicable to a 2.23-acre site in the SCAQMD SRA 3 (Southwest Coastal LA County) with sensitive receptors located 25 meters away, which accounts for all adjacent off-site sensitive receptors.
73 The maximum daily localized emissions for each of the construction phases and the localized significance thresholds are presented in Table 4.2-8, Estimated Maximum Unmitigated Localized Construction Emissions (pounds per day). The Project’s maximum localized operational emissions would be below the localized significance thresholds, and localized construction emissions impacts to existing sensitive receptors would be less than significant.

Operation
The localized operational air quality analysis was conducted using the methodology prescribed in the SCAQMD Localized Significance Threshold Methodology. 74 The screening criteria provided
in the Localized Significance Threshold Methodology were used to determine the localized operational emissions numerical indicators of significance for the Project. The Project would comply with the Title 24 (20 22) building energy efficiency standards, CALGreen Building Code, and the Culver City Mandatory Green Building Program. The maximum daily localized emissions and the localized significance thresholds are presented in Table 4.2-9, Estimated Maximum Localized Operational Emissions – Project (pounds per day) . The Project’s maximum localized operational emissions would be below the localized significance thresholds, and localized operational emissions impacts to existing sensitive receptors would be less than significant.

72 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008. Referenced for Source Receptor Area 3 (Northwest Los Angeles County Coastal) for a 2.23-acre site interpolating from LST values from 1-acre and 5-acre sites.
73 SCAQMD, Final Localized Significance Threshold Methodology, “Projects with boundaries located closer than 25 meters to the nearest receptor should use the LSTs for receptors located at 25 meters.”, June 2003 and revised July 2008, p. 33.
74 SCAQMD, Final Localized Significance Threshold Methodology, June 2003 and revised July 2008.

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TABLE 4.2-8

ESTIMATED MAXIMUM UNMITIGATED LOCALIZED CONSTRUCTION EMISSIONS (POUNDS PER DAY)
Construction Phases NOX CO PM10b PM2.5b
Demolition - 2025 9.4 12.9 0.7 0.4
Grading - 2025 13.9 19.3 0.5 0.5
Foundations - 2025 14.1 18.8 0.6 0.5
Foundations - 2026 13.2 18.8 0.5 0.5
Building Construction - 2026 16.0 19.3 0.4 0.4
Finishing/Painting - 2026 1.8 2.5 0.1 0.1
Finishing/Painting - 2027 1.7 2.5 0.1 <0.1
Paving/Sitework - 2027 4.6 6.5 0.2 0.2
Maximum Daily Construction Emissionsa 16.0 19.3 0.7 0.5 SCAQMD Localized Significance Thresholdc 136.1 1,030.6 8.5 5.2 Exceeds Threshold? No No No No
NOTES:
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix C.
b Emissions include fugitive dust control measures consistent with SCAQMD Rule 403. c The SCAQMD LSTs are based on Source Receptor Area 3 (Southwest Los Angeles County Coastal) for a 2.23-acre site with sensitive receptors conservatively assumed to be 25 meters to the construction area.

SOURCE: ESA 2023

TABLE 4.2-9
ESTIMATED MAXIMUM LOCALIZED OPERATIONAL EMISSIONS – PROJECT (POUNDS PER DAY) Source NOX CO PM10 PM2.5
Area 0.3 27.6 <0.1 <0.1
Energy <0.1 <0.1 <0.1 <0.1
Total Localized Project Operational Emissions 0.3 27.6 <0.1 <0.1 Localized Existing Site Emissions Removed 0.2 1.5 <0.1 <0.1 Net Maximum Localized Operational Emissionsa 0.1 26.1 <0.1 <0.1 SCAQMD Significance Thresholdb 136.1 1030.6 2.2 1.1
Exceeds Thresholds? No No No No
a Totals may not add up exactly due to rounding in the modeling calculations. Detailed emissions calculations are provided in Appendix C.
b The SCAQMD LSTs are based on Source Receptor Area 3 (Southwest Los Angeles County Coastal) for a 2.23-acre site with sensitive receptors conservatively assumed to be 25 meters to the Project Site.

SOURCE: ESA 2023

Carbon Monoxide Hotspots
The potential for the Project to cause or contribute to CO hotspots was evaluated by comparing Project intersections (both intersection geometry and traffic volumes) with prior studies conducted by the SCAQMD in support of their AQMPs and considering existing background CO concentrations. As discussed below, this comparison demonstrates that the Project would not cause or contribute considerably to the formation of CO hotspots, that CO concentrations at Project -

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impacted intersections would remain well below the threshold one-hour and eight-hour ambient air quality standards (CAAQS) of 20 or 9.0 parts per million (ppm), respectively within one -quarter mile of a sensitive receptor, and that no further CO analysis is warranted or required.

As shown previously in Table 4.2-3, above, CO levels in the Project area are substantially below the federal and the State standards. Maximum CO levels in recent years (2019-2021) were 1.8 ppm (one-hour average) and 1.3 ppm (eight -hour average) as compared to the criteria of 20 ppm (CAAQS one-hour average) or 35 ppm (NAAQS one -hour average) and 9.0 ppm (eight -hour average). No exceedances of the CO standards have been recorded at monitoring stations in the Air Basin since 2003,75 and the Air Basin is currently designated as a CO attainment area for both the CAAQS and the NAAQS.

As noted above, the 2003 AQMP estimated that the 1-hour concentration for the intersection of Wilshire Boulevard and Veteran Avenue was 4.6 ppm, which indicates that the most stringent 1-hour CO standard (20.0 ppm) would likely not be exceeded until the daily traffic at the intersection exceeded more than 400,000 vehicles per day. The AQMP CO hotspots modeling also took into account worst- case meteorological conditions and background CO concentrations. As an initial screening step, if a project intersection does not exceed 400,000 vehicles per day, then the project does not need to prepare a detailed CO hot spot analysis, and impacts would be considered less than significant. Based on the Project’s Transportation Study,
76 under Future plus Project (2027) conditions, the segment of Slauson Avenue between the Marina Freeway and Bristol Parkway would have a traffic volume of approximately 53,450 average daily trips (ADT),77 which is below the daily traffic volumes of 400,000 vehicles per day that would be expected to generate CO exceedances as evaluated in the 2003 AQMP.

This daily trip estimate is based on the peak hour conditions of the intersection. There is no reason unique to the Air Basin meteorology to conclude that the CO concentrations at the segment of Slauson Avenue between the Marina Freeway and Bristol Parkway would exceed the 1-hour CO standard if modeled in detail, based on the studies undertaken for the 2003 AQMP. In addition, CO background concentrations within the vicinity of the modeled intersection have substantially decreased since preparation of the 2003 AQMP primarily due to ongoing fleet turnover of older on-road light duty vehicles and use of cleaner fuels. In 2003, the 1-hour background CO concentration was 5.0 ppm and as seen in Table 4.2-3 has decreased to 1.7 ppm in 2021. 78 Therefore, the Project does not trigger the
need for a detailed CO hotspots model and would not cause any new or exacerbate any existing CO hotspots. The Project off-site operational activities, including the highest average daily trips, would

75 SCAQMD, 2022 AQMP, 2022, p. 2-42.
76 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
77 The traffic volume of approximately 53,450 ADT was estimated based on the peak hour intersection volumes under Future plus Project conditions and the general assumption that peak hour trips represent approximately 10 percent of daily trip volumes (the Federal Highway Administration considers 10 percent to be a standard assumption; see Travel Model Improvement Program Time-of-Day Modeling Procedures: State-of-the-Practice, State-of-the-Art (2.0 Standard Approaches, http://www.fhwa.dot.gov/planning/tmip/publications/other_reports/ tod_modeling_procedures/ch02.cfm).
78 The monitoring station most representative of the Project Site the Southwest Coastal LA County Monitoring Station. SCAQMD, Historical Data by Year, www.aqmd.gov/home/air-quality/air-quality-data-studies/historical- data-by-year; USEPA, AirData, www.epa.gov/airdata/ad_rep_mon.html. Accessed October 2023.

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not expose sensitive receptors to substantial CO concentrations. As a result, impacts related to localized mobile-source CO emissions are considered less than significant.

Toxic Air Contaminants
Construction
The Project’s health risk calculations were performed using a spreadsheet tool consistent with the OEHHA guidance, which incorporates the algorithms, equations, and a variable described above as well as in the OEHHA guidance, and incorporates the results of the AERMOD dispersion model.

As shown in Table 4.2-10, Maximum Unmitigated Health Risk Impacts for Off-Site Sensitive and Commercial Receptors, unmitigated results of the HRA cancer risk for residential land uses exceed the SCAQMD significance threshold of 10 per million; therefore, this impact is potentially significant, and mitigation would be required. Also, as seen in Table 4.2 -10, the HRA cancer risk for commercial land uses does not exceed the SCAQMD significance threshold of 10 per million Hazard index values for all receptor types were below the SCAQMD significance threshold of 1.0, therefore, chronic impacts would be less than significant.

TABLE 4.2-10

MAXIMUM UNMITIGATED HEALTH RISK IMPACTS FOR OFF-SITE SENSITIVE AND COMMERCIAL RECEPTORS Sensitive Receptor
Maximum Cancer Risk
(# in one million) Hazard Index
Residential Land Use 34.6 0.06
Commercial (Worker) 4.8 0.07
Maximum Health Impact Thresholds 10 1.0
Exceeds Threshold? Yes No
SOURCE: ESA, 2023.

Operations
The SCAQMD recommends that operational health risk assessments be conducted for substantial sources of operational DPM (e.g., truck stops and warehouse distribution facilities that generate more than 100 trucks per day or more than 40 trucks with operating transport refrigeration units) and has provided guidance for analyzing mobile source diesel emissions. 79 The Project does not
consist of any of these land uses. With implementation of the Project, two truck loading and unloading parking spaces would be provided. Thus, t he Project is not anticipated to generate a substantial number of daily truck trips. As previously discussed, trucks would be subject to the five-minute regulatory idling limitation and would project trucks would be required to comply with the applicable provisions of the CARB 13 CCR, Section 2025 (Truck and Bus regulation) to minimize and reduce PM and NO
X emissions from existing diesel trucks. Therefore, Project operations would not be considered a substantial source of diesel particulates.

79 SCAQMD, Health Risk Assessment Guidance for Analyzing Cancer Risks from Mobile Source Diesel Idling Emissions for CEQA Air Quality Analysis, August 2003, http://www.aqmd.gov/docs/default- source/ceqa/handbook/mobile-source-toxics-analysis.doc?sfvrsn=2.

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With respect to the use of consumer products and architectural coatings, the residential and retail uses associated with the Project would be expected to generate minimal TAC emissions from these sources. The Project’s residential and retail land uses would not include installation of industrial- sized paint booths or require extensive use of commercial or household cleaning products. Typical sources of acutely and chronically hazardous TACs include industrial manufacturing processes (e.g., chrome plating, electrical manufacturing, petroleum refinery). The Project would not include these types of potential industrial manufacturing process sources. It is expected that quantities of hazardous TACs generated on -site (e.g., cleaning solvents, paints, landscape pesticides) for the types of proposed land uses would be below thresholds warranting further study under the California Accidental Release Program (CalARP).

Project operations would only result in minimal emissions of TAC from maintenance or other ongoing activities, such as from the maintenance and use of architectural coatings and other products. Based on the uses expected on the Project Site, potential long -term operational impacts associated with the release of TACs would be minimal, regulated, and controlled. Therefore, operation of the Project would not expose sensitive and commercial receptors to substantial TAC concentrations, and operational impacts would be less than significant.

Mitigation Measures
Construction
AQ-1: Construction Equipment . The Applicant shall implement the following requirements for construction equipment operating at each Project site. These requirements shall be included in applicable bid documents and contractor(s) must demonstrate the ability to supply such equipment. Construction equipment shall include the following:
• The Project shall utilize off-road diesel-powered construction equipment that meets or exceeds the California Air Resources Board (CARB) and United States Environmental Protection Agency (USEPA) Tier 4 Final off-road emissions standards or equivalent for equipment rated at 25 horsepower (hp) or greater during Project construction where available within the Air Basin. Such equipment shall be outfitted with Best Available Control Technology (BACT) which means a CARB certified Level 3 Diesel Particulate Filter or equivalent. A copy of each unit’s certified tier specification, BACT documentation, and CARB or Southern California Air Quality Management District (SCAQMD) operating permit at the time of mobilization of each applicable unit of equipment shall be provided.
• Use electrified tower cranes in place of diesel-fueled equipment.

Operations
Impacts regarding localized operational air quality emissions during operation were determined to be less than significant. Therefore, no mitigation measures are required.

Level of Significance After Mitigation Construction
As shown in Table 4.2 -11, Maximum Mitigated Health Risk Impacts for Off -Site Sensitive and Commercial Receptors with implementation of Mitigation Measure AQ-1 (MM-AQ-1) as described below, the maximum cancer risk and hazard index for sensitive receptors would be below the SCAQMD significance thresholds. Therefore, the impact related to health risks would be less than

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significant with mitigation. The calculated cancer risk is estimated for outdoor exposure and assumes that sensitive receptors (residential uses) would not have any mitigation such as mechanical filtration and that residential uses would have continuously open windows. As shown in Table 4.2-10 and 4.2- 11, maximum cancer risk and hazard index for commercial receptors would be below the SCAQMD significance thresholds without mitigation, but would be further reduced with the implementation of Mitigation Measure AQ-1 (MM-AQ-1). As the maximum cancer risk and non-cancer impacts would be less than the SCAQMD significance thresholds, impacts would be less than significant.

TABLE 4.2-11

MAXIMUM MITIGATED HEALTH RISK IMPACTS FOR OFF-SITE SENSITIVE RECEPTORS Sensitive Receptor
Maximum Cancer Risk
(# in one million) Hazard Index
Residential Land Use 7.0 0.01
Worker (offsite) 1.0 0.02
Maximum Health Impact Thresholds 10 1.0
Exceeds Threshold? No No
SOURCE: ESA, 2023.

The process of assessing health risks and impacts includes a degree of uncertainty, which is dependent on the availability of data and the extent to which assumptions are relied upon in cases where the data are incomplete or unknown. All HRAs rely upon scientific studies to reduce the level of uncertainty; however, it is not possible to completely eliminate uncertainty from the analysis. Where assumptions are used to substitute for incomplete or unknown data, it is standard practice in performing HRAs to err on the side of health protection to avoid underestimating or underreporting the risk to the public by assessing risk on the most sensitive populations, such as children and the elderly. As shown in Table 4.2-11, cancer risk for nearby sensitive receptors would remain below significance thresholds with the implementation of Mitigation Measure AQ -1. Furthermore, as described above, the maximum cancer risk and hazard index for commercial receptors would be below the SCAQMD significance thresholds without mitigation, but would be further reduced with the implementation of Mitigation Measure AQ -1 (MM -AQ-1). These short -term emissions would not substantially contribute to a significant construction health risk. No residual emissions and corresponding individual cancer risk are anticipated after Project construction. Thus, construction activities would not expose sensitive and commercial receptors to substantial toxic air contaminant concentrations, and construction- related health impacts would be mitigated to less than significant with Implementation of Mitigation Measure AQ -1. Therefore, no additional mitigati on measures are required or included, and the impact level would remain less than significant with mitigation.

Operations
Impacts regarding the exposure of substantial pollutant concentrations on sensitive and commercial receptors during operation were determined to be less than significant without mitigation.

Therefore, no mitigation measures were required or included, and the impact level remains less than significant.

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Cumulative Impacts
Chapter 3, Environmental Setting, of this Draft EIR, there are 12 related projects identified in the vicinity of the Project Site. The related projects within approximately 1,000 feet of the Project Site are listed in Table 4.2-12, Cumulative Projects within 1,000 feet of the Project Site.

TABLE 4.2-12
RELATED PROJECTS WITHIN 1,000 FEET OF THE PROJECT SITE
No.a Location Jurisdiction Land Use Size (sf)
Distance to
Project Site (ft)
1 5800 Bristol Pkwy /
5801 Hannum Ave
City of Culver City Office 281,400 750
6 5840 Uplander Way City of Culver City Conversion from Office to School
16,128 950
a Related projects list based on information from City of Culver City (January 2023), City of Los Angeles (May 2023), and the County of Los Angeles (May 2023).

SOURCE: Gibson Transportation Consulting, 2023

The SCAQMD recommends using two methodologies to assess the cumulative impact of air quality emissions: (1) a project’s consistency with the current AQMP be used to determine its potential cumulative impacts or (2) that project-specific air quality impacts be used to determine the project’s potential cumulative impacts to regional air quality.80 Consistency with Air Quality Management Plan
The SCAQMD recommends assessing a project’s cumulative impacts based on whether the project is consistent with the current AQMP. CEQA Guidelines Section 15064(h)(3) provides guidance in determining the significance of cumulative impacts. Specifically, CEQA Guidelines Section 15064(h)(3) states in part that:
“A lead agency may determine that a project’s incremental contribution to a cumulative effect is not cumulatively considerable if the project will comply with the requirements in a previously approved plan or mitigation program which provides specific requirements that will avoid or substantially lessen the cumulative problem (e.g., water quality control plan, air quality plan, integrated waste management plan) within the geographic area in which the project is located. Such plans or programs must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency…”

80 SCAQMD, Potential Control Strategies to Address Cumulative Impacts from Air Pollution White Paper, Appendix D, 1993, page D-3 (“As Lead Agency, the AQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR… Projects that exceed the Project-specific significance thresholds are considered by the SCAQMD to be cumulatively considerable.

This is the reason project-specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project-specific thresholds are generally not considered to be cumulatively significant.”).

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For purposes of the cumulative air quality analysis with respect to CEQA Guidelines Section 15064(h)(3), the Project’s cumulative air quality impacts are determined not to be significant based on its consistency with the SCAQMD’s adopted 2022 AQMP, as discussed above. As is also discussed above, the Project’s increase in population, housing and employment would be consistent with Connect SoCal growth projections, upon which the 2022 AQMP is based. Related projects would also be required to assess consistency with the 2022 AQMP transportation control strategies, as well as with population, housing, and employment growth projections in Connect SoCal and provide mitigation measures if significant impacts are identified. As discussed in Threshold AIR- 1, the Project would not increase the frequency or severity of an existing violation or cause or contribute to new violations for ozone. Therefore, the Project would be consistent with and would not conflict with or obstruct implementation of the applicable AQMP. Accordingly, Project air quality impacts are not cumulatively considerable and cumulative impacts are less than significant.

Project-Specific Impacts
The SCAQMD CEQA Air Quality Handbook states that the “Handbook is intended to provide local governments, project proponents, and consultants who prepare environmental documents with guidance for analyzing and mitigating air quality impacts of projects.” 81 The SCAQMD CEQA Air
Quality Handbook also states that “[f]rom an air quality perspective, the impact of a project is determined by examining the types and levels of emissions generated by the project and its impact on factors that affect air quality. As such, projects should be evaluated in terms of air pollution thresholds established by the District.”
82 The SCAQMD has provided guidance on addressing the
cumulative impacts for air quality. as discussed below:83 “As Lead Agency, the AQMD uses the same significance thresholds for project specific and cumulative impacts for all environmental topics analyzed in an Environmental Assessment or EIR… Projects that exceed the Project -specific significance thresholds are considered by the SCAQMD to be cumulatively considerable. This is the reason project-specific and cumulative significance thresholds are the same. Conversely, projects that do not exceed the project - specific thresholds are generally not considered to be cumulatively significant.” The SCAQMD recommends evaluating cumulative impacts for individual projects based on whether the project exceeds the SCAQMD’s recommended daily thresholds for project -specific impacts for those pollutants for which the Air Basin is in non-attainment. Thus, the cumulative analysis of air quality impacts follows SCAQMD’s guidance such that construction or operational Project emissions would be considered cumulatively considerable if Project -specific emissions exceed an applicable SCAQMD recommended significance threshold.

The City relies on thresholds established by the SCAQMD (refer to CEQA Guidelines Section 15064.7) to assess the Project’s cumulative impacts. Regional emissions from a project have the potential to affect the Air Basin as a whole, and, unlike other environmental issues areas, such as aesthetics or noise, it is not possible to establish a geographical radius from a specific project site

81 SCAQMD, CEQA Air Quality Handbook, April 1993, page iii. 82 SCAQMD, CEQA Air Quality Handbook, April 1993, page 6-1. 83 SCAQMD, White Paper on Potential Control Strategies to Address Cumulative Impacts From Air Pollution, 2003, Appendix D.

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where potential cumulative impacts from regional emissions would be limited. Meteorological factors, such as wind, can disperse pollutants, often times tens of miles downwind from a project site. Therefore, consistent with accepted and established SCAQMD cumulative impact evaluation methodologies, the potential for the Project to result in cumulative impacts from regional emissions is assessed based on the SCAQMD thresholds.

For construction, as shown in Table 4.2 -6 and Table 4.2-8 , the Project would not result in an exceedance of regional and localized significance thresholds for construction. For construction health risk impacts, as shown in Table 4.2 -10 and Table 4.2-11, the Project would not result in an exceedance of applicable significance thresholds with implementation of Mitigation Measure AQ-

1. Therefore, cumulative impacts related to regional and localized construction emissions would be less than significant with mitigation.

For operations, as shown in Table 4.2-7 and 4.2-9, the Project would not result in an exceedance of regional or localized significance thresholds. Therefore, cumulative impacts related to regional and localized operational emissions would be less than significant.

Mitigation Measures
Construction
Cumulative impacts regarding regional and localized construction air pollutant emissions were determined to be less than significant. Therefore, no mitigation measures are required.

Refer to Mitigation Measure AQ-1 , which would reduce cumulative health risk impacts during construction. No additional mitigation measures are required.

Operations
Cumulative impacts regarding regional and localized operational air pollutant emissions were determined to be less than significant. Therefore, no mitigation measures are required.

Level of Significance After Mitigation
Construction
Implementation of Mitigation Measure AQ-1 would reduce construction health risk impact s to below applicable significance thresholds. Cumulative air quality impacts would be less than significant with mitigation. Therefore, with implementation of Mitigation Measure AQ -1 no additional mitigation measures are required or included, and the impact level would be less than significant with mitigation.

Operations
Cumulative impacts regarding operational air pollutant emissions were determined to be less than significant without mitigation. Therefore, no mitigation measures were required or included, and the impact level remains less than significant.

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4.3 Cultural Resources – Archaeological Resources

4.3.1 Introduction
This section evaluates potential impacts on archaeological resources. As noted in Chapter 6, Other CEQA Considerations, of this Draft EIR, the City of Culver City (City) determined in the Initial Study, provided in Appendix A -2 of this Draft EIR, that the Project would result in less than significant impacts related to cultural resources, with the exception of archaeological resources.

The analysis is based on the 5700 Hannum Avenue Mixed-Use Residential and Commercial Project – Archaeological Resources Assessment Report (Assessment Report) prepared by ESA,1 provided in Appendix D of this Draft EIR.

4.3.2 Environmental Setting
Regulatory Framework
Federal
National Historic Preservation Act of 1966
The principal federal law addressing historic properties is the National Historic Preservation Act (NHPA), as amended (54 USC 300101 et seq.), and its implementing regulations (36 CFR Part 800). Section 106 of the NHPA requires a federal agency with jurisdiction over a proposed federal action (referred to as an “undertaking”) to take into account the effects of the undertaking on historic properties, and to provide the Advisory Council on Historic Preservation (ACHP) an opportunity to comment on the undertaking.

The term “historic properties” refers to “any prehistoric or historic district, site, building, structure, or object included in, or eligible for inclusion in, the National Register” (36 CFR Part 800.16(l)(1)).

The implementing regulations (36 CFR Part 800) describe the process for identifying and evaluating historic properties, for assessing the potential adverse effects of federal undertakings on historic properties, and seeking to develop measures to avoid, minimize, or mitigate adverse effects.

The Section 106 process does not require the preservation of historic properties; instead, it is a procedural requirement mandating that federal agencies take into account effects to historic properties from an undertaking prior to approval.

The steps of the Section 106 process are accomplished through consultation with the State Historic Preservation Officer (SHPO), federally recognized Indian tribes, local governments, and other interested parties. The goal of consultation is to identify potentially affected historic properties, assess effects to such properties, and seek ways to avoid, minimize, or mitigate any adverse effects on such properties. The agency also must provide an opportunity for public involvement (36 CFR 800.1(a)). Consultation with Indian tribes regarding issues related to Section 106 and other authorities (such as NEPA and Executive Order No. 13007) must recognize the government -to- government relationship between the Federal Government and Indian tribes, as set forth in

1 Environmental Science Associates, 5700 Hannum Mixed-Use Residential and Commercial Project, Culver City, California, Archaeological Resources Assessment Report, prepared for Lincoln Property Company West, LLC, October 2023. Provided in Appendix D of this Draft EIR.

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Executive Order 13175, 65 FR 87249 (November 9, 2000), and Presidential Memorandum of November 5, 2009.

Under NHPA, the Secretary of Interior is responsible for establishing professional standards and for providing guidance on the preservation of the nation’s historic properties. See below discussion of these standards.

National Register of Historic Places
The National Register of Historic Places (National Register) was established by the NHPA of 1966, as “an authoritative guide to be used by federal, state, and local governments, private groups and citizens to identify the Nation’s historic resources and to indicate what properties should be considered for protection from destruction or impairment” (36 CFR 60.2) (U.S. Department of the Interior 2002). The National Register recognizes a broad range of cultural resources that are significant at the national, state, and local levels and can include districts, buildings, structures, objects, prehistoric archaeological sites, historic -period archaeological sites, traditional cultural properties, and cultural landscapes. As noted above, a resource that is listed in or eligible for listing in the National Register is considered “historic property” under Section 106 of the NHPA.

To be eligible for listing in the National Register, a property must be significant in American history, architecture, archaeology, engineering, or culture. Properties of potential significance must meet one or more of the following four established criteria:

A. Are associated with events that have made a significant contribution to the broad patterns of our history
B. Are associated with the lives of persons significant in our past C. Embody the distinctive characteristics of a type, period, or method of construction or that represent the work of a master, or that possess high artistic values, or that represent a significant and distinguishable entity whose components may lack individual distinction D. Have yielded, or may be likely to yield, information important in prehistory or history In addition to meeting one or more of the criteria of significance, a property must have integrity.

Integrity is defined as the ability of a property to convey its significance. The National Register recognizes seven qualities that, in various combinations , define integrity, including location, design, setting, materials, workmanship, feeling, and association. To retain historic integrity, a property must possess several, and usually most, of these seven aspects. Thus, the retention of the specific aspects of integrity is paramount for a property to convey its significance.

Ordinarily, religious properties, moved properties, birthplaces or graves, cemeteries, reconstructed properties, commemorative properties, and properties that have achieved significance within the past 50 years are not considered eligible for the National Register unless they meet one of the Criteria Considerations (A-G), in addition to meeting at least one of the four significance criteria and possessing integrity.

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Archaeological Resources Protection Act of 1979
The Archaeological Resources Protection Act of 1979 (ARPA) (16 USC 470aa-470mm) was enacted to “secure, for the present and future benefit of the American people, the protection of archaeological resources and sites which are on public lands and Indian lands, and to foster increased cooperation and exchange of information between governmental authorities, the professional archaeological community, and private individuals.” Under this Act, archaeological resources are defined as material remains of past human life or activities that are of archaeological interest and are over 100 years old. The primary focus of the Act is to protect archaeological resources on public and Indian lands, and to prevent looting and destruction of archaeological resources. The statute provides for stiff civil and criminal penalties, including fines up to $100,000 and/or 5 years in prison for second-time offenders. The Act also governs archaeological excavation and disposition of collections from sites on public and Indian lands, and requires researchers to obtain a permit prior to excavating or removing any archaeological materials on federal lands. The Act further requires that the nature and location of archaeological resources be kept confidential unless providing the information would further the purposes of the statute and not create a risk of harm to such resources.

Native American Graves Protection and Repatriation Act of 1990 Requirements for responding to discoveries of Native American human remains and associated funerary objects on federal land are addressed under the Native American Graves Protection and Repatriation Act of 1990 (NAGPRA) (25 USC 3001– 3013) and its implementing regulations (43 CFR Part 10). If human remains, funerary objects, sacred objects, or objects of cultural patrimony are discovered on federal or tribal lands, the federal agency must determine and consult with the lineal descendants and culturally affiliated Indian tribes, and carry out appropriate treatment and disposition of the discovered remains, including transfer of custody. An Indian tribe is defined as any tribe, band, nation, or other organized group or community of Indians that is recognized as eligible for the special programs and services provided by the U.S. to Indians because of their status as Indians. NAGPRA does not require federal agencies to consult with non-federally recognized tribes. However, there are some cases in which non-federally recognized tribes may be appropriate claimants for cultural items. Federal agencies that wish to return Native American human remains and cultural items to non-federally recognized tribes may do so after review and approval by the NAGPRA Review Committee.

NAGPRA also requires permitting of the intentional removal from, or excavation of, Native American cultural items from federal or tribal lands for purposes of discovery, study, or removal; establishes criminal penalties for trafficking in human remains or cultural objects; and requires agencies and museums that receive federal funding to inventory those items in their possession, identify the descendants of and repatriate those items.

Secretary of the Interior’s Standards
The Secretary of the Interior’s Standards (36 Code of Federal Regulations [CFR] Part 68) were originally designed for use by the National Park Service and intended for application in a federal context. The stated intent of the Standards is to “set forth st andards for the treatment of historic properties containing standards for preservation, rehabilitation, restoration, and reconstruction” (36 CFR 68.1). One set of standards – preservation, rehabilitation, restoration or reconstruction – will

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apply to a property undergoing treatment, depending upon the property’s significance, existing physical condition, the extent of documentation available and interpretive goals, when applicable, and are to be applied in a reasonable manner, taking into cons ideration economic and technical feasibility (36 CFR 68.3). The Standards for Rehabilitation (as defined under 36 CFR 68.3(b)) are most applicable to projects where compatibility with historic building alterations or alterations to a building’s environment is being evaluated and can pertain to historic buildings of all materials, construction types, sizes, and occupancy and encompass the exterior and the interior, related landscape features and the building’s site and environment as well as attached, adjacent, or related new construction.

The Standards were subsequently incorporated into Public Resources Code (PRC) Section 15164.5(b) as a gauge against which lead agencies complying with the California Environmental Quality Act (CEQA) could measure project impacts to historical resources. As stated under the prior CEQA subsection, generally a project that complies with the Standards is considered to have mitigated its impacts to historical resources to a less- than-significant level (CE QA Guidelines Section 15064.5(b)(3); see also League for Protection of Oakland’s Architectural and Historic Resources v. City of Oakland (1997) 52 Cal.App.4th 896. Although not prescriptive and as suggested by the term “generally” as used in the PRC, the appropriate application of the Standards, or a subset thereof, requires careful consideration by a lead agency of the specific significance, characteristics, and condition of the historical resource for which impacts are being evaluated.

State
California Environmental Quality Act
CEQA is the principal statute governing environmental review of projects occurring in the state and is codified at PRC Section 21000 et seq . CEQA requires lead agencies to determine if a proposed project would have a significant effect on the environment, including significant effects on historical or unique archaeological resources.

Under CEQA Guidelines Section 21084.1, a
project that may cause a substantial adverse change in the significance of an historical resource is a project that may have a significant effect on the environment.

The CEQA Guidelines (Title 14 California Code of Regulations [CCR] Section 15064.5) recognize that historical resources include: (1) a resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of His torical Resources (California Register); (2) a resource included in a local register of historical resources, as defined in PRC Section 5020.1(k) or identified as significant in a historical resource survey meeting the requirements of PRC Section 5024.1(g); and (3) any object, building, structure, site, area, place, record, or manuscript which a lead agency determines to be historically significant or significant in the architectural, engineering, scientific, economic, agricultural, educational, social, political, military, or cultural annals of California by the lead agency, provided the lead agency’s determination is supported by substantial evidence in light of the whole record. The fact that a resource does not meet the three criteria outlined above does not preclude the lead agency from determining that the resource may be an historical resource as defined in PRC Sections 5020.1(j) or 5024.1.

If a lead agency determines that an archaeological site is a historical resource, the provisions of CEQA Guidelines Sections 21084.1 and 15064.5 apply. If an archaeological site does not meet the

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criteria for a historical resource contained in the CEQA Guidelines, then the site may be treated in accordance with the provisions of Section 21083, which is as a unique archaeological resource. As defined in CEQA Guidelines Section 21083.2(g), a “unique” archaeological resource is an archaeological artifact, object, or site, about which it can be clearly demonstrated that without merely adding to the current body of knowledge, there is a high probability that it meets any of the following criteria:
• Contains information needed to answer important scientific research questions and there is a demonstrable public interest in that information;
• Has a special and particular quality such as being the oldest of its type or the best available example of its type; or,
• Is directly associated with a scientifically recognized important prehistoric or historic event or person.

If an archaeological site meets the criteria for a unique archaeological resource as defined in Section 21083.2(g), then the site is to be treated in accordance with the provisions of Section 21083.2, which state that if the lead agency determines that a project would have a significant effect on unique archaeological resources, the lead agency may require reasonable efforts be made to permit any or all of these resources to be preserved in place (Section 21083.1(a)). If preservation in place is not feasible, mitigation measures shall be required. CEQA Guidelines Section 15064.5(c)(4) notes that if an archaeological resource is neither a unique archaeological nor a historical resource, the effects of the project on those resources shall not be considered a significant effect on the environment.

A significant effect under CEQA would occur if a project results in a substantial adverse change in the significance of a historical resource as defined in CEQA Guidelines Section 15064.5(a). As defined in CEQA Guidelines Section 15064.5(b)(1)), substantial adverse change is “physical demolition, destruction, relocation, or alteration of the resource or its immediate surroundings such that the significance of a historical resource would be materially impaired.” According to CEQA Guidelines Section 15064.5(b)(2), the significance of a historical resource is materially impaired when a project demolishes or materially alters in an adverse manner those physical characteristics that:

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

In general, pursuant to CEQA Guidelines Section 15064.5(b)(3), a project that complies with the Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for

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Preserving, Rehabilitating, Restoring, and Reconstructing Historic Buildings (Standards)2 is considered to have mitigated its impacts to historical resources to a less-than-significant level.

California Register of Historical Resources
The California Register is “an authoritative listing and guide to be used by State and local agencies, private groups, and citizens in identifying the existing historical resources of the State and to indicate which resources deserve to be protected, to the extent prudent and feasible, from substantial adverse change” (PRC Section 5024.1[a]). The criteria for eligibility for the California Register are based upon National Register criteria (PRC Section 5024.1[b]). Certain resources are determined by the sta tute to be automatically included in the California Register, including California properties formally determined eligible for, or listed in, the National Register.

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

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

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

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

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

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

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

2 Grimmer, E. Anne. 2017. The Secretary of the Interior’s Standards for the Treatment of Historic Properties with Guidelines for Preserving, Rehabilitating, Restoring & Reconstructing Historic Buildings. Washington, D.C.: U.S.

Department of the Interior National Park Services: Technical Preservation Services.

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Other resources that may be nominated to the California Register include:
• Historical resources with a significance rating of Category 3 through 5 (those properties identified as eligible for listing in the National Register, the California Register, and/or a local jurisdiction register);
• Individual historical resources;
• Historical resources contributing to historic districts; and, • Historical resources designated or listed as local landmarks, or designated under any local ordinance, such as an historic preservation overlay zone. (PRC Section 5024.1(d)-(e).) California Government Code Sections 6254(r) and 6254.10 These sections of the California Public Records Act were enacted to protect archaeological sites from unauthorized excavation, looting, or vandalism. Section 6254(r) explicitly authorizes public agencies to withhold information from the public relating to “Native American graves, cemeteries, and sacred places maintained by the Native American Heritage Commission.” Section 6254.10 specifically exempts from disclosure requests for “records that relate to archaeological site information and reports, maintained by, or in the possession of the Department of Parks and Recreation, the State Historical Resources Commission, the State Lands Commission, the Native American Heritage Commission, another state agency, or a local agency, including the records that the agency obtains through a consultation process between a Native American tribe and a state or local agency.”
Local
City of Culver City
The City’s General Plan does not include policies, goals, and objectives for archaeological resources or human remains.

Prehistoric Setting
The chronology of Southern California is typically divided into three general time periods: the Early Holocene (9,600 cal
3 B.C. to 5,600 cal B.C.), the Middle Holocene (5,600 cal B.C. to 1,650 cal B.C.), and the Late Holocene (1,650 cal B.C. to cal A.D. 1769). This chronology is manifested in the archaeological record by particular artifacts and burial practices that indicate specific technologies, economic systems, trade networks, and other aspects of culture.

While it is not certain when humans first came to California, their presence in Southern California by about 9,600 cal B.C. has been well documented. At Daisy Cave, on San Miguel Island, cultural remains have been radiocarbon dated to between 9,150 and 9,0 00 cal B.C. During the Early Holocene (9,600 cal B.C. to 5,600 cal B.C.), the climate of Southern California became warmer and more arid and the human populations, who were represented by small hunter gathers until this

3 The word ‘cal’ is used to signify a calibrated date.

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point and resided mainly in coastal or inland desert areas, began exploiting a wider range of plant and animal resources.4
During the Late Holocene (1,650 cal B.C. to cal A.D. 1769), many aspects of Millingstone culture persisted, but a number of socioeconomic changes occurred . 5,6,7 The native populations of
Southern California were becoming less mobile and populations began to gather in small sedentary villages with satellite resource -gathering camps. Increasing population size necessitated the intensified use of existing terrestrial and marine resources. 8 Evidence indicates that the
overexploitation of larger, high-ranked food resources may have led to a shift in subsistence, towards a focus on acquiring greater amounts of smaller resources, such as shellfish and small - seeded plants.
9 Between about A.D. 800 and A.D. 1350, there was an episode of sustained drought, known as the Medieval Climatic Anomaly (MCA) .10 While this climatic event did not appear to reduce the human population, it did lead to a change in subsistence strategies in order to deal with the substantial stress on resources.

Given the increasing sedentism and growing populations during the Late Holocene, territorial conscription and competition became acute. Primary settlements or village sites were typically established in areas with available freshwater, and where two or more ecological zones intersected.

This strategic placement of living space provided a degree of security in that when subsistence resources associated with one ecological zone failed, the resources of another could be exploited.

Villages typically claimed and carefully defended fixed territories that may have averaged 30 - square miles in size encompassing a variety of ecological zones that could be exploited for subsistence resources.
11 The Late Holocene marks a period in which specialization in labor emerged, trading networks became an increasingly important means by which both utilitarian and non-utilitarian materials were acquired, and travel routes were extended. Trade during this period reached its zenith as asphaltum (tar), seashells, and steatite were traded from Catalina Island ( Pimu or Pimugna) and coastal Southern California to the Great Basin. Major technological changes appeared as well,

4 Byrd, Brian F., and Mark L. Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp 215-227.
5 Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast, Plenum Press, New York. 6 Wallace, William J. 1955. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11:214-230.
7 Warren, Claude N. 1968. Cultural Tradition and Ecological Adaptation on the Southern California Coast. In Archaic Prehistory in the Western United States, C. Irwin-Williams, ed, pp. 1-4. Eastern New Mexico University Contributions in Anthropology. Portales.
8 Erlandson, Jon M. 1994. Early Hunter-Gatherers of the California Coast, Plenum Press, New York. 9 Byrd, Brian F., and Mark L. Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp 215-227.
10 Jones, Terry L., Brown, Gary M., Raab, Mark L., Janet L. McVickar. 1999. Environmental Imperatives Reconsidered: Demographic Crises in Western North America during the Medieval Climatic Anomaly, in Current Anthropology, Vol. 40, No. 2 (April 1999), pp. 137-170. 11 McCawley, William.1996. The First Angelinos: The Gabrielino Indians of Los Angeles, Malki Museum Press, Banning, California.

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particularly with the advent of the bow and arrow sometime after cal A.D. 500, which largely replaced the use of the dart and atlatl.12
Ethnographic Setting
The Project Site is located in a region traditionally occupied by the Gabrielino. The term “Gabrielino” is a general term that refers to those Native Americans who were administered by the Spanish at the Mission San Gabriel Arcángel. Prior to European colonization, the Gabrielino occupied a diverse area that included: the watersheds of the Los Angeles, San Gabriel, and Santa Ana rivers; the Los Angeles basin; and the islands of San Clemente, San Nicolas, and Santa Catalina.
13 Their neighbors included the Chumash and Tataviam to the north, the Juañeno to the south, and the Serrano and Cahuilla to the east. The Gabrielino language was part of the Takic branch of the Uto-Aztecan language family.

The Gabrielino Indians were hunter-gatherers and lived in permanent communities located near the presence of a stable food supply. Subsistence consisted of hunting, fishing, and gathering. Small terrestrial game was hunted with deadfalls, rabbit drives, and by burning undergrowth, while larger game such as deer were hunted using bows and arrows. Fish were taken by hook and line, nets, traps, spears, and poison.
14 The primary plant resources were the acorn, gathered in the fall and processed in mortars and pestles, and various seeds that were harvested in late spring and summer and ground with manos and metates. The seeds included chia and other sages, various grasses, and islay or holly-leafed cherry. Community populations generally ranged from 50 to 100 inhabitants, although larger settlements may have existed. The Gabrielino are estimated to have had a population numbering around 5,000 in the pre-contact period. 15 The Late Prehistoric period, spanning from approximately 1,500 years B.P. to the mission era, is the period associated with the florescence of the Gabrielino. 16 Coming ashore near Malibu Lagoon
or Mugu Lagoon in October of 1542, Juan Rodriguez Cabrillo was the first European to make contact with the Gabrielino Indians. The Gabrielino are reported to have been second only to their Chumash neighbors in terms of population size, regional influence, and degree of sedentism. 17 Maps produced by early explorers indicate that at least 26 Gabrielino villages were within proximity to known Los Angeles River courses, while an additional 18 villages were reasonably

12 Byrd, Brian F., and Mark L. Raab. 2007. Prehistory of the Southern Bight: Models for a New Millennium. In California Prehistory: Colonization, Culture, and Complexity, edited by Terry L. Jones and Kathryn A. Klar, pp 215-227.
13 Kroeber, A. L. 1925. Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78.

Smithsonian Institution, Washington, D.C.
14 Bean, Lowell J., and Charles R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538-549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.
15 Kroeber, A. L. 1925. Handbook of the Indians of California. Bureau of American Ethnology, Bulletin 78.

Smithsonian Institution, Washington, D.C.
16 Wallace, William J. 1955. A Suggested Chronology for Southern California Coastal Archaeology. Southwestern Journal of Anthropology 11:214-230.
17 Bean, Lowell J., and Charles R. Smith. 1978. Gabrielino, in California, edited by R.F. Heizer, pp. 538-549 Handbook of North American Indians, Vol. 8, W. C. Sturtevant, general editor, Smithsonian Institution, Washington, D.C.

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close to the river.18 The closest named settlements to the Project Site are Saa’anga and Waachnga.

Review of a map titled Gabrielino Communities Located on the Los Angeles -Santa Ana Plain by William McCawley19 indicates that the settlement of Saa’anga was located approximately 1 mile north of the Project Site, while the settlement of Waachnga was situated approximately 1.25 miles south. Both of these settlements are depicted as located close to Ballona Creek.

Historic Setting
History and Early Development of Culver City
Harry H. Culver (1880 -1946), the founder of Culver City, was born in Milford, Nebraska on January 22, 1880. The middle child of five, Culver was raised on a farm along with three brothers and a sister. His father, Jacob Hazel Culver, was a brigadier general in the National Guard and a strict disciplinarian. Culver followed in his father’s footsteps, enlisting in the military during the Spanish-American War. He studied at Doane College before spending three years at the University of Nebraska. In 1901, Culver traveled to the Philippines where he began working in the mercantile business, worked as a reporter for the Manila Times, and served as a special agent for the customs department. After more than three years in the Philippines, Culver returned to the United States, performing his customs duties in Detroit and Saint Louis. He resigned from the customs department in 1910 when he moved to California and began working for real estate giant I.N. Van Nuys. “As the story goes, after Van Nuys offered to make him a manager because of his exemplary work, Culver decided to venture out on his own. After intense study, Harry Culver pinpointed the area between Los Angeles and Abbot Kinney’s resort of Venice for his city”. 20 At the California Club in 1913, Harry Culver announced his plans to develop a city west of downtown Los Angeles. Culver saw an opportunity to capitalize on the excitement generated by Abbot Kinney’s Venice of America development along the California coast south of Santa Monica.

Between Venice and Los Angeles sat open land, originally part of Rancho La Ballona, and as the relationship between Los Angeles and Venice took shape, Culver saw a spot in between that was ideal for a new town site. “If you draw a line from the Story Building to the Ocean Front at Venice, at the halfway mark you will find three intersection electric lines —the logical center for what we propose to develop a town-site.” Soon after Culver’s speech, the city of Culver City was established. Culver promoted his new community by holding special events like “prettiest baby contests” and an annual marathon race. Newspaper advertisements exclaimed “All Roads Lead to Culver City!”.

Culver City continued to grow and finally incorporated in 1917. 21 The city grew outward from the
downtown commercial area and adjacent film studios. This area saw commercial development along Culver Boulevard in the 1920s and 1930s, and spread to Washington Boulevard in the 1940s and 1950s, and was surrounded by residential neighborhoods. Downtown Culver City was centered on a main street (Washington Boulevard) anchored by a six-story hotel, Fire and Police

18 Gumprecht, Blake. 2001. Los Angeles River: Its Life, and Possible Rebirth, The Johns Hopkins University Press, Baltimore, 1999, Reprinted 2001.
19 McCawley, William.1996. The First Angelinos: The Gabrielino Indians of Los Angeles, Malki Museum Press, Banning, California.
20 Cerra, Julie Lugo. 2013. Culver City Chronicles. Charleston, History Press. 21 Cerra, Julie Lugo. 2013. Culver City Chronicles. Charleston, History Press.

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Departments, a city hall, banks, restaurants, and stores. The early economics of Culver City were supported by movie studios. Industry came in the form of Western Stove in 1922, then the Helms Bakeries in 1930, and then the Hayden Industrial Tract was established in the 1940s. During the 1950s Washington Boulevard would be improved with a number of car dealerships. Over the years, more than forty annexations increased the size of the city from 1.2 square miles to about five square miles.
22 At the heart of Screenland, the economic health of the city has always been strongly tied to the movie industry. Following the closure of MGM Studios, the city was looking for ways to spur economic development. To spur development and create a new flow of money, the city created the Redevelopment Agency. One of the first projects undertaken by the newly formed agency was the Fox Hills redevelopment. This development would open up more than 300 acres of land just southwest of the city to residential, commercial, and industrial growth. 23 Archival Research
SCCIC Records Search
A records search for the Project Site was conducted on July 14, 2023, at the California Historical Resources Information Center -South Central Coastal Information Center (CHRIS -SCCIC). The records search included a review of all recorded cultural resources and previous studies within the Project Site and a 0.50-mile radius. The records search results indicate that seven cultural resources studies have been conducted within a 0.50-mile radius of the Project Site. Approximately 15 percent of the 0.50-mile records search radius has been included in previous cultural resources assessments. Of the eight previous studies, none overlap the Project Site. The records search results indicate that no cultural resources have been recorded within the 0.50-mile radius of P roject Site.

However, a total of six prehistoric archaeological resources have been recorded in the immediate vicinity of the 0.50-mile radius (see Table 4.3-1, Previously Recorded Cultural Resources).

Other Research
Additional archaeological resources (the report for which has not yet been archived at the CHRIS- SCCIC, as it is still in progress) were identified approximately 2.3 miles from the Project Site during ground disturbing activities in connection with a development project in Downtown Culver City.
24 These include two isolated prehistoric metates that were recovered in the upper six feet of disturbed fill sediments in an area of the property that had been previously developed with a large warehouse building. This property had a similar land use history as the Project Site.

22 Cerra, Julie Lugo. 2004. Images of America: Culver City, Arcadia Publishing, Charleston. 23 Culver City Historical Society. n.d. “Culver City Timeline: A Work in progress”, https://www.culvercityhistoricalsociety.org/about/culver-city-timeline/ 24 ESA. 2022. (in progress) Archaeological and Paleontological Monitoring Report for the Culver Studios Innovation Plan Project, City of Culver City, California. Report on file with ESA, Irvine, CA.

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TABLE 4.3-1

PREVIOUSLY RECORDED CULTURAL RESOURCES
P-Number
(P-19-)
Permanent
Trinomial
(CA-LAN-) Other Designation Description
Recordin
g Events
59 59 Malcom Farmer’s Playa
del Rey Site No. 1
Prehistoric archaeological site: village or camp
site, including artifacts (steatite bowl, quartz
crystal point, “arrowpoints”, mortar and steatite
fragments, manos, pestles, shell,
hammerstones, scrapers, etc. Site reportedly
destroyed.
1950
60 60 Malcom Farmer’s Playa
del Rey Site No. 1
Prehistoric archaeological site: shell midden,
“chips”, mortar fragments, hammerstones,
“chopper”, and steatite pieces. Human remains
(cranium pieces) and pieces of burned deer
bone. Site reportedly destroyed.
1950
67 67 Malcom Farmer’s
Baldwin Hills Site No. 1
Prehistoric archaeological site: described as a
possible temporary dwelling on a small wash.

Small amount of shell reported.
1950
213 213 LA-31 Prehistoric archaeological site: metates 1953 216 216 LA-34 Prehistoric archaeological site: mortars 1953 2768 2768 SR 20 Prehistoric archaeological site: subsurface midden deposits 2000
SOURCE: SCCIC 2023

Sacred Lands File Search
The Native American Heritage Commission (NAHC) maintains a confidential Sacred Lands File (SLF) which contains sites of traditional, cultural, or religious value to the Native American community. The NAHC was contacted on July 11, 2023, to request a search of the SLF. The NAHC responded to the request in a letter dated August 11, 2023, indicating that the results were negative.

However, the NAHC noted that the absence of site information does not mean the absence of cultural resources in a project area. The City is conducting consultation with appropriate tribes per AB 52 and the results of this consultation will be summarized in the Tribal Cultural Resources Section of the Draft EIR.

Land Use History
Historic maps and aerial photographs were examined to provide historical information about land uses of the Project Site and to contribute to an assessment of the Project Site’s archaeological sensitivity. By 1896, the Project Site was undeveloped, Centinela Creek was located approximately

0.65 miles south of the Project Site, while Ballona Creek was situated approximately 1.25 miles to the west. The 1923 and 1938 aerials continue showing the Project Site as undeveloped with an intermittent stream crossing the central portion of the Project Site on a northeast to southwest axis.

As observed in the aerial photographs from 1938 through 1970, the Project Site is developed with a golf course. The 1976 aerial shows the Project Site as undeveloped. By 1983, the Pr oject Site

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observed as developed with the current building and parking lot. No changes to the Project Site are observed in the subsequent 1994, 2002, 2012, 2016, and 2023 aerials.25,26,27 Geologic Map and Geotechnical Report Review
There is disagreement over the geologic mapping of the Project Site by geologists. Poland et al. 28 show the Project Site geology as the San Pedro Sand Formation from the lower or early Pleistocene.

This geologic unit is a nearshore marine deposit. Dibblee and Minch 29 map the Project Site as Qop
(Fox Hills paleosol), Qoa (older alluvium), and Qa (Holocene-age alluvium). Qa is surficial alluvium of Holocene age, “derived mostly from Santa Monica Mountains”. Dibblee and Minch 30 assign a late Pleistocene age to the Qoa and the Qop. Geotechnologies, Inc. 31 reproduced the mapping of Poland et al.32, but describe the soils in the northern portion of the Project Site as (marine) terrace deposits. That could be compatible with the San Pedro Sand Formation. Geotechnologies, Inc. (2022) also mention that during geotechnical exploration (consisting of placing two borings within the Project Site; one in the northern portion and another in the southern portion), fill materials were encountered from the surface down to depths of 1 and 3 feet bgs. Under the fill soils, marine terrace deposits (as mentioned above) were found, followed by bedrock (siltstone).

Subsurface Sensitivity
Prehistoric Archaeological Analysis
Results of the records search have indicated that although no resources have been recorded within the Project Site or 0.50-mile radius, a total of six prehistoric archaeological resources (including village sites with human remains and associated artifacts, shell midden deposits, metates, mortars, etc) have been recorded in the immediate vicinity of the 0.50-mile radius. Review of historic maps indicate that Centinela Creek and Ballona Creek are located in the vicinity of the Project Site, which would have attracted prehistoric inhabitants to the area since they would have provided them with fresh water sources, along with floral and faunal resources. Additionally, two Native American villages (Saa’anga and Waachnga) are situated approximately 1.0 to 1.25 miles away from the Project Site. The Geotechnical Report review indicates that fill soils (likely brought in during construction of the golf course and/or the existing building) occur within the Project Site from

25 Bing Maps. 2023. Aerial photograph of 5700 Hannum Avenue Project Site. https://www.bing.com/maps/?cp=33.987088%7E-118.383063&lvl=16.4&style=a, accessed August 2023. 26 Ramboll US Consulting, Inc. 2022. Phase I Environmental Site Assessment, 5700 Hannum Avenue, Culver City.

Prepared on behalf of: LPC West, Inc.
27 TopoView. 2023. Topographic maps including 5700 Hannum Avenue Project Site, including 1896 Redondo15- minute quadrangle and the 1924 Inglewood 7.5-minute quadrangle. https://ngmdb.usgs.gov/topoview/viewer/#15/33.9871/-118.3831, accessed in August 2023. 28 Poland, J.F., A. A. Garrett, and A. Sinnot, 1959, Geology, hydrology, and chemical character of ground waters in the Torrance-Santa Monica area, California: U.S. Geological Survey Water Supply Paper 1461, 425 p. 29 Dibblee and Minch, 2007, Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 30 Dibblee and Minch, 2007, Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 31 Geotechnologies, Inc. 2022. Preliminary Geotechnical Engineering Investigation, Proposed Mixed-Use Development, 5700 Hannum Avenue, Culver City, California. Prepared for: LPC West, Inc., 915 Wilshire Boulevard, Suite 2050, Los Angeles, CA 90017. Prepared by: Geotechnologies, Inc., 439 Western Avenue, Glendale, CA 91201. 47 pp.
32 Poland, J.F., A. A. Garrett, and A. Sinnot, 1959, Geology, hydrology, and chemical character of ground waters in the Torrance-Santa Monica area, California: U.S. Geological Survey Water Supply Paper 1461, 425 p.

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surface down to depths of 1 and 3 feet bgs, followed by older sediments consisting of marine terrace deposits and then bedrock. In cases where later development does disturb native sediments, prehistoric archaeological materials can become intermixed within historic fill such as in the case with the two prehistoric metate artifacts encountered during monitoring (in the upper six feet of disturbed fill sediments) in connection with a development project in Downtown Culver City that had similar existing uses as the Project Site. For these reasons, there is at least a moderate to high potential for prehistoric archaeological materials to exist in the underlying soils.

Historical Archaeological Analysis
Review of historic maps and aerial photographs indicate that the Project Site was undeveloped until a golf course was constructed in the Project Site by at least 1938. The existing building was also developed by at least 1983. Based on the lack of previous historic uses within the Project Site and the fact that no historic-period archaeological resources have been previously recorded within the Project Site or 0.50-mile radius, the potential to encounter historic-period archaeological resources within the Project Site is considered low.

4.3.3 Environmental Impacts
Thresholds of Significance
The following threshold of significance is based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in a significant adverse impact to archaeological resources and human remains if it would:
• ARCH-1: Cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5; or
Potentially significant impacts related to archaeological resources are discussed and analyzed further below.

The City determined in the Initial Study that the following environmental issue area s would result in no impacts or less-than -significant impacts and, therefore, are scoped out of this Draft EIR.

Please refer to Appendix A-2 of this Draft EIR for a copy of the Initial Study and additional information regarding the following issue area:

Would the Project:
• Cause a substantial adverse change in the significance of a historical resource pursuant to Section 15064.5
• Disturb any human remains, including those interred outside of dedicated cemeteries.

As detailed in the Initial Study, a historic resource memorandum was prepared by Architectural Resources Group (ARG) in September 2022 for the Project to determine if the existing building on the Project Site qualifies as a historic resource. As discussed therein, the existing building is not a historic resource and thus, no impacts to historic resources would occur under the Project.

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As further detailed in the Initial Study, a number of regulatory provisions address the handling of human remains inadvertently uncovered during excavation activities. These include State Health and Safety Code Section 7050.5, Public Resources Code (PRC) Section 5097.98, and CEQA Guidelines Section 15064.5(e). Pursuant to these codes, in the event of the discovery of unrecorded human remains during construction, excavations shall be halted and the County Coroner shall be notified. If the human remains are determined to be Native American, the California Native American Heritage Commission (NAHC) would be notified within 24-hours and the guidelines of the NAHC would be adhered to in the treatment and disposition of the remains. Compliance with these regulatory protocols would ensure that impacts on human remains would be less than significant. No further analysis of this issue is therefore included in this Draft EIR.

Methodology
The analysis of archaeological resources is based in part on the Assessment Report, which included a cultural resources records search through the CHRIS-SCCIC, a SLF search through the NAHC, land use history research (including review of historic topographic maps and aerial photographs), geologic map review and review of the geotechnical report prepared for the Project. A subsurface archaeological sensitivity assessment was also conducted to determine the potential to encounter buried archaeological resources (prehistoric and historic -period) and human remains during construction based on the results of the record searches, subsurface geological conditions, on -site disturbances, land use history, and the proposed excavation parameters. Because the Project Site is entirely developed and lacks any visible native ground surface or potential for surface exposure of resources, an archaeological field survey was not undertaken.

Project Design Features
There are no Project Design Features associated with archaeological resources.

Analysis of Project Impacts
Threshold ARCH-1: The Project would have a significant impact if it were to cause a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5.

Impact Analysis
The subsurface archaeological sensitivity assessment indicates that the potential for encountering prehistoric archaeological resources is moderate to high based on the fact that six prehistoric archaeological resources (village sites with human remains and associated artifacts, shell midden deposits, metates, mortars, etc.), water sources (which would have provided fresh water sources to prehistoric inhabitants), and Native American villages (Saa’anga and Waachnga) are situated in the vicinity of the Project Site. Additionally, fill soils occur within the Project Site (from surface down to 3 feet below ground surface) and a previous development project in Downtown Culver City (that had similar existing uses as the Project Site) yielded two prehistoric metat es in disturbed fill sediments. The subsurface archaeological sensitivity assessment for historic archaeology indicates that no previous historic uses have existed within the Project Site and that no historic -period archaeological resources have been previously recorded within the Project Site or 0.50-mile radius.

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Based on these results, the potential to encounter historic -period archaeological resources within the Project Site is considered low.

Based on the above, Project excavations, which are anticipated to reach depths of 27 feet bgs, have potential for encountering buried prehistoric archaeological resources. Therefore, construction activities associated with the Project could potentially ca use a substantial adverse change in the significance of an archaeological resource pursuant to Section 15064.5 and impacts would be potentially significant.

Operation of the new facilities and uses on the Project Site would not result in any further ground disturbing activities such as grading or excavation; therefore, there is no potential to encounter, alter, or disturb archaeological resources. No operational impacts would occur.

Mitigation Measures
ARCH-1: Prior to the issuance of a demolition permit, the Applicant shall retain an archaeologist who meets the Secretary of the Interior’s Professional Qualifications Standards for Archaeology (Qualified Archaeologist) to oversee an archaeological monitor who shall be present during initial Project construction work such as site demolition (e.g., building footings/foundations, subsurface utilities, surface parking lots, sidewalks, etc.), clearing/grubbing, grading, trenching, or related moving of soils wit hin the Project Site (collectively, ground disturbing activities); provided, however, that ground disturbing activities shall not include any moving of soils after they have been initially disturbed or displaced by Project-related construction. The Qualified Archaeologist shall determine the frequency of monitoring based on the rate of excavation and grading activities, proximity to known archaeological resources, the materials being excavated (younger alluvium vs. older alluvium), and the depth of excavation, and if found, the abundance and type of archaeological resources encountered. The frequency of monitoring can be reduced to part- time inspections or ceased entirely if determined appropriate by the Qualified Archaeologist.

Prior to commencement of excavation activities, an Archaeological and Cultural Resources Sensitivity Training shall be given for construction personnel. The training session shall be carried out by the Qualified Archaeologist and shall focus on how to identify archaeological resources that may be encountered during earthmoving activities and the procedures to be followed in such an event.

ARCH-2: In the event that historic or prehistoric archaeological resources (e.g., bottles, foundations, refuse dumps, etc.) are unearthed, ground-disturbing activities shall be halted or diverted away from the vicinity of the find so that the find can be evaluate d. After consulting with the Applicant, the Qualified Archeologist shall establish an appropriate buffer area in accordance with industry standards, reasonable assumptions regarding the potential for additional discoveries in the vicinity, and safet y considerations for those making an evaluation and potential recovery of the discovery. This buffer area shall be established around the find where construction activities shall not be allowed to continue.

Work within the buffer area shall only be allowed to continue after the evaluation and recovery efforts are completed. Work shall be allowed to continue outside of the buffer area.

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“unique archaeological resource” pursuant to Public Resources Code Section 21083.2(g), the Qualified Archaeologist shall coordinate with the Applicant and the City of Culver City (City) to develop a formal treatment plan that would serve to reduce impacts to the resources and that provides for or the adequate recovery of the scientifically consequential information contained in the resources along with subsequent laboratory processing, analysis, evaluation, and reporting . The treatment plan established for the resources shall be in accordance with CEQA Guidelines Section 15064.5(f) for historical resources and Public Resources Code Sections 21083.2(b) for unique archaeological resources. The treatment plan shall include measures regarding the curation of the recovered resources that may include curation at a public, non-profit institution with a research interest in the materials, such as the Natural History Museum of Los Angeles County or the Fowler Museum, if such an institution agrees to accept the material. If no institution accepts the resources, they may be donated to a local school or historical society in the area (such as the Culver City Historical Society) for educational purposes.

ARCH-3: The Qualified Archaeologist shall prepare a final report and appropriate California Department of Parks and Recreation Site Forms at the conclusion of archaeological monitoring. The report shall include a description of resources unearthed, if any, treatment of the resources, results of the artifact processing, analysis, and research, and evaluation of the resources with respect to the California Register of Historical Resources and CEQA. The report and the Site Forms shall be submitted by the Applicant to the City, the South Central Coastal Information Center, and representatives of other appropriate or concerned agencies to signify the satisfactory completion of the Project and required mitigation measures.

Level of Significance After Mitigation
With implementation of Mitigation Measures ARCH-1 to ARCH-3, potentially significant impacts to archaeological resources during construction activities would be reduced to a less -than- significant level.

Cumulative Impacts
Many of the related projects identified in Chapter 3, Environmental Setting, of this Draft EIR, would require excavation that could potentially expose or damage potential archaeological resources.

However, these related projects are located in developed urban areas with sites that have been previously disturbed, and the potential to encounter and cause a significant impact on surface resources is unlikely. Further, in association with CEQA review, and depending on the depth of excavation and sensitivity of respective sites, mitigation measures would be required for related projects that have the potential to cause significant impacts to undiscovered archaeological resources, including existing regulations for undiscovered human remains. Implementation of such mitigation measures and regulations would avoid significant impacts. State requirements regarding impacts on archaeological resources and CEQA compliance require monitoring of excavation activities and treatment and/or curation of discovered resources where appropriate (Public Resources Code Section 15064.5). Such standard construction practices, particularly over a range of project sites, provide for protection, recovery and curation of discovered resources and preserve their contributions to the knowledge base of past population activity in the area. For those projects not subject to CEQA review, there would be some potential for impacts on archaeological resources and human remains in the event there are excavations that extend into soils conducive to retaining resources, however,

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4.3. Cultural Resources – Archaeological Resources
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regulations contained in the California Health and Safety Code and Penal Code would apply in some instances, and circumstances involving a loss of such resources are expected to be limited. Therefore, the cumulative effects from cumulative projects are considered less than significant.

The Project is required to comply with the Mitigation Measures ARCH-1 through ARCH-3 and regulations cited above in the event resources are found, thus ensuring proper identification, treatment and preservation of any resources, and reducing significant impacts on archaeological resources and human remains to less than significant levels. These regulations require excavation monitoring, and treatment and curation of discoveries. Therefore, to the extent impacts on archaeological resources from cumulative projects may occur, further contribution from the Project would not be cumulatively considerable, and the cumulative impacts of the Project would be less than significant.

Mitigation Measures
Refer to Mitigation Measures ARCH-1 to ARCH-3. No additional mitigation measures are required.

Level of Significance after Mitigation
With implementation of Mitigation Measures ARCH-1 to ARCH-3 , cumulative impacts to archaeological resources would be less than significant.

4. Environmental Impacts Analysis

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4.4 Energy

4.4.1 Introduction
This section analyzes effects on energy resources due to construction and operation of the Project.

The Project’s anticipated energy use is estimated, the potential for impacts due to inefficient or unnecessary consumption, or conflicts with energy related plans are assessed, and conservation measures are considered to address significant impacts if identified. Information found herein, as well as other aspects of the Project’s energy implications, are discussed elsewhere in this Draft EIR, including in Cha pter 2, Project Description, and Sections 4.1, Air Quality; 4.6, Greenhouse Gas Emissions; 4.7, Land Use and Planning; and 4.11, Transportation. Details regarding the energy calculations are provided in energy consumption worksheets provided in Appendix E of this Draft EIR.

4.4.2 Environmental Setting
Regulatory Framework
Federal
Energy Independence and Security Act of 2007
The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national greenhouse gas (GHG) emissions by requiring the following:
• Increasing the supply of alternative fuel sources by setting mandatory Renewable Fuel Standards (RFS) that requires fuel producers to use at least 36 billion gallons of biofuel in 2022; • Prescribing or revising standards affecting regional efficiency for heating and cooling products, procedures for new or amended standards, energy conservation, energy efficiency labeling for consumer electronic products, residential boiler efficiency, electric motor efficiency, and home appliances;
• Requiring approximately 25 percent greater efficiency for light bulbs by phasing out incandescent light bulbs between 2012 and 2014; requiring approximately 200 percent greater efficiency for light bulbs, or similar energy savings, by 2020; and • While superseded by the U. S. Environmental Protection Agency ( USEPA) and the National Highway Traffic Safety Administration (NHTSA) actions described above (refer to Corporate Average Fuel Economy Standards, above) (i) establishing miles per gallon targets for cars and light trucks and (ii) directing NHTSA to establish a fuel economy program for medium - and heavy-duty trucks and create a separate fuel economy standard for trucks.

Additional provisions of EISA address energy savings in government and public institutions, promote research for alternative energy, additional research in carbon capture, international energy programs, and the creation of “green jobs.”
1 1 A “green job,” as defined by the United States Department of Labor, is a job in business that produces goods or provides services that benefit the environment or conserve natural resources.

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4.4. Energy
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Corporate Average Fuel Economy Standards
Established by the U.S. Congress in 1975, the Corporate Average Fuel Economy (CAFE) Standards (49 CFR Parts 531 and 533) reduce energy consumption by increasing the fuel economy of cars and light trucks. NHTSA and USEPA jointly administer the CAFE standard s. The U.S. Congress has specified that CAFE standards must be set at the “maximum feasible level” with consideration given for (1) technological feasibility; (2) economic practicality; (3) effect of other standards on fuel economy; and (4) need for the na tion to conserve energy. When these standards are raised, automakers respond by creating a more fuel -efficient fleet. In 2012, NHTSA established final passenger car and light truck CAFE standards for model years 2017 through 2021, which the agency projects will require in model year 2021, on average, a combined fleet -wide fuel economy of 40.3 to 41.0 miles per gallons (mpg). Fuel efficiency standards for medium - and heavy-duty trucks have been jointly developed by USEPA and NHTSA. The Phase 1 heavy -duty tru ck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles for model years 2014 through 2018, and result in a reduction in fuel consumption from 6 to 23 percent over the 2010 baseline, depending on the vehicle ty pe. 2 USEPA and NHTSA have
also adopted the Phase 2 heavy-duty truck standards, which cover model years 2021 through 2027 and require the phase-in of a 5 to 25 percent reduction in fuel consumption over the 2017 baseline depending on the compliance year and vehicle type.
3 In March 2020, U.S. Department of Transportation ( USDOT) and USEPA issued the final Safer Affordable Fuel -Efficient (SAFE) Vehicles Rule, which amends existing CAFE standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establishes new standards covering model years 2021 through 2026.
4 These standards set a combined fleet wide
average of 36.9 to 37 miles per gallon (mpg) for the model years affected. 5 On January 20, 2021, President Biden issued Executive Order 13990 ‘‘Protecting Public Health and the Environment and Restoring Science To Tackle the Climate Crisis’’ directing USEPA to consider whether to propose suspending, revising, or rescinding the standards previously revised under the SAFE Vehicles Rule for Model Years 2021–2026. In February 2022, USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 6 This final rule revises current
GHG standards beginning for vehicles in model year 2023 and through model year 2026 and establish the most stringent GHG standards ever set for the light -duty vehicle sector that are expected to result in average fuel economy label values of 40 mpg, while the standards they replace (the SAFE rule standards) would achieve only 32 mpg in model year 2026 vehicles. 7 2 U. S. Environmental Protection Agency (USEPA), Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, 2011. 3 USEPA, Federal Register/Vol. 81, No. 206/Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, 2018. 4 USEPA, Final Rule for Model Year 2021 - 2026 Light-Duty Vehicle Greenhouse Gas Emission Standards and Corporate Average Fuel Economy Standards, published April 30, 2020. 5 National Highway Traffic Safety Administration (NHTSA), Corporate Average Fuel Economy standards. 6 USEPA, Federal Register / Vol. 86, No. 248 / Thursday, December 30, 2021 / Rules and Regulations, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 7 USEPA, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards:

Regulatory Update, December 2021.

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In addition to the regulations applicable to cars and light -duty trucks described above, in 2011 USEPA and NHTSA announced fuel economy and GHG standards for medium - and heavy-duty trucks for model years 2014– 2018. The standards for carbon dioxide (CO2) emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to USEPA , this regulatory program would reduce GHG emissions and fuel consumption for the affected vehicles by 6 to 23 percent over the 2010 baselines. Building on the first phase of standards, in August 2016, USEPA and NHTSA finalized Phase 2 standards for medium and heavy-duty vehicles through model year 2027 that will improve fuel efficiency and cut carbon pollution. The Phase 2 standards are expected to lower CO 2 emissions by approximately 1.1 billion metric tons.

Federal Energy Policy and Conservation Act
The Energy Policy and Conservation Act of 1975 (EPCA) is a United States Act of Congress that responded to the 1973 oil crisis by creating a comprehensive approach to federal energy policy. The primary goals of EPCA are to increase energy production and supply, reduce energy demand, provide energy efficiency, and give the executive branch additional powers to respond to disruptions in energy supply. Most notably, EPCA established the Strategic Petroleum Reserve, the Energy Conservation Program for Consumer Products, and Corporate Average Fuel Economy regulations.

State
Senate Bill 1389
Senate Bill (SB) 1389 (Public Resources Code [PRC] Sections 25300– 25323; SB 1389) requires the California Energy Commission (CEC) to prepare a biennial integrated energy policy report that assesses major energy trends and issues facing the state’s electricity, natural gas, and transportation fuel sectors and provides policy recommendations to conserve resources; protect the environment; ensure reliable, secure, and diverse energy supplies; enhance the state’s economy; and protect public health and safety (P RC Section 25301[a]). The 2019 Integrated Energy Policy Report provides the results of the CEC’s assessments related to energy sector trends, building decarbonization and energy efficiency, zero -emission vehicles (ZEV), energy equity, climate change adaptation, electricity reliability in Southern California, natural gas assessment, and electricity, natural gas, and transportation energy demand forecasts.

California’s Renewable Portfolio Standard
First established in 2002 under SB 1078, California’s Renewable Portfolio Standards (RPS) requires retail sellers of electric services to increase procurement from eligible renewable energy resources to 33 percent by 2020 and 50 percent by 2030. 8 On September 10, 2018, Governor Jerry Brown signed SB 100, which further increased California’s RPS and requires retail sellers and local publicly owned electric utilities to procure eligible renewable electricity for 44 percent of retail sales by December 31, 2024, 52 percent by December 31, 2027, and 60 percent by December 31, 2030. It also requires the California Air Resources Board (CARB) to plan for 100 percent eligible renewable energy resources and zero -

8 California Public Utilities Commission (CPUC), California Renewable Portfolio Standards (RPS), https://www.cpuc.ca.gov/rps/. Accessed October 2023.

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4.4. Energy
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carbon resources by December 31, 2045. The California Public Utilities Commission (CPUC) and the CEC jointly implement the RPS program. The CPUC and the CEC jointly implement the RPS program. The CPUC’s responsibilities include (1) determining annual procurement targets and enforcing compliance; (2) reviewing and approving each investor-owned utility’s renewable energy procurement plan; (3) reviewing contracts for RPS-eligible energy; and (4) establishing the standard terms and conditions used in contracts for eligible renewable energy. 9 Refer to
Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for details regarding this regulation.

California Building Standards Code (Title 24)
California Building Energy Efficiency Standards (Title 24, Part 6) The California Building Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations, Title 24, Part 6) were adopted to ensure that building construction and system design and installation achieve energy efficien cy and preserve outdoor and indoor environmental quality. T he 2019 Title 24 standards became effective on January 1, 2020. 10 The
2019 Title 24 standards continue to improve upon the 2016 Title 24 standards for new construction of, and additions and alterations to, residential and nonresidential buildings which include efficiency improvements to the residential standards for attics, walls, water heating, and lighting, and efficiency improvements to the non-residential standards include alignment with the American Society of Heating and Air-Conditioning Engineers (ASHRAE) 90.1 2017 national standards. 11 California Green Building Standards (Title 24, Part 11) On August 11, 2021, the CEC adopted the 2022 Title 24 Standards, which were approved by the California Building Standards Commission for inclusion into the California Building Standards Code in December 2021. The 2022 standards encourage efficient electric heat pumps, establish electric-ready requirements for new homes, expands solar photovoltaic and battery storage standards, strengthens ventilation standards, and more. Buildings whose permit applications are applied for on or after January 1, 2023, must comply with the 2022 standards. 12 Refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for additional details regarding these standards.

Assembly Bill 1493 (AB 1493)/Pavley Regulations
In response to the transportation sector accounting for more than half of California’s CO 2 emissions, Assembly Bill (AB) 1493 (commonly referred to as California Air Resources Board (CARB)’s Pavley regulations), enacted on July 22, 2002, requires CARB to set GHG emission standards for new passenger vehicles, light -duty trucks, and other vehicles manufactured in and after 2009 whose primary use is non-commercial personal transportation. Phase I of the legislation established standards for model years 2009 –2016 and Phase II established standards for model

9 CPUC, RPS Program Overview, http://www.cpuc.ca.gov/RPS_Overview/. Accessed October 2023. 10 California Energy Commission, 2022 Building Energy Efficiency Standards, 2022. 11 California Energy Commission, 2019 Building Energy Efficiency Standards for Residential and Nonresidential Buildings, 2018.
12 California Energy Commission, 2022 Building Energy Efficiency Standards.

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4.4. Energy
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years 2017–2025.13,14 In September 2019, USEPA published the SAFE Vehicles Rule in the federal register (Federal Register, Vol. 84, No. 188, Friday, September 27, 2019, Rules and Regulations, 51310–51363) that maintains the vehicle mpg standards applicable in model year 2020 for model years 2021 through 2026. In November 2019, California and 23 other states and environmental groups filed a petition in the U.S. District Court in Washington, DC , for USEPA to reconsider the published rule. The Court has not yet ruled on these petitions. However, c onsistent with President Biden’s executive order on Protecting Public Health and the Environment and Restoring Science to Tackle the Climate Crisis, in February 2022, USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 15 This final rule revises current
GHG standards beginning for vehicles in model year 2023 and through model year 2026 and establish the most stringent GHG standards ever set for the light -duty vehicle sector that are expected to result in average fuel economy label values of 40 mpg, while the standards they replace (the SAFE rule standards) would achieve only 32 mpg in model year 2026 vehicles. 16 As discussed under the Federal section, above, in March 2020, USDOT and USEPA issued the SAFE Vehicles Rule, which amends existing CAFE standards and tailpipe carbon dioxide emissions standards for passenger cars and light trucks and establishes new standards covering model years 2021 through 2026. Refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for additional details regarding this regulation.

California Health and Safety Code (HSC), Division 25.5, California Global Warming Solutions Act of 2006
In 2006, the California State Legislature adopted AB 32 (codified in the California Health and Safety Code [HSC], Division 25.5 – California Global Warming Solutions Act of 2006), which focuses on reducing GHG emissions in California to 1990 levels by 2020. Under HSC Division

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

In 2016, the California State Legislature adopted SB 32 and its companion bill, AB 197, which amended HSC Division 25.5 and established a new climate pollution reduction target of 40 percent below 1990 levels by 2030 and include d provisions to ensure that the benefits of state climate policies reach into disadvantaged communities. Refer to Section 4. 6, Greenhouse Gas Emissions, of this Draft EIR for details regarding these regulations.

Senate Bill 350
SB 350, signed October 7, 2015, is the Clean Energy and Pollution Reduction Act of 2015. SB 350 is the implementation of some of the goals of Executive Order B-30-15. Building off of AB 32, SB 350 established California’s 2030 GHG reduction target of 40 percent below 1990 levels. To

13 CARB, Clean Car Standards—Pavley, AB 1493.
14 United States Environmental Protection Agency, USEPA and NHTSA Set Standards to Reduce Greenhouse Gases and Improve Fuel Economy for Model Years 2017–2025 Cars and Light Trucks, 2012. 15 U.S. Environmental Protection Agency, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards, https://www.govinfo.gov/content/pkg/FR-2021-12-30/pdf/2021-27854.pdf. 16 U.S. Environmental Protection Agency, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards: Regulatory Update, https://nepis.epa.gov/Exe/ZyPDF.cgi?Dockey=P1013NR8.pdf.

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4.4. Energy
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achieve this goal, SB 350 set ambitious 2030 targets for energy efficiency and renewable electricity, among other actions aimed at reducing GHG emissions. SB 350 increased California’s renewable electricity procurement goal from 33 percent by 2020 to 50 percent by 2030 prior to the current goals set by SB 100. In addition, SB 350 requires the S tate to double statewide energy efficiency savings in electricity and natural gas end uses by 2030.

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

California Air Resources Board
CARB’s Advanced Clean Car Program
The Advanced Clean Cars emissions-control program was approved by CARB in 2012 and is closely associated with the Pavley regulations.
17 The program requires a greater number of zero-
emission vehicle models for years 2015 through 2025 to control smog, soot and GHG emissions.

This program includes the Low-Emissions Vehicle (LEV) regulations to reduce criteria pollutants and GHG emissions fr om light- and medium-duty vehicles; and the ZEV regulations to require manufacturers to produce an increasing number of pure ZEVs (meaning battery and fuel cell electric vehicles) with the provision to produce plug -in hybrid electric vehicles (PHEV) between 2018 and 2025. In particular, implementation of the ZEV and PHEV regulations reduce transportation fuel consumption by increasing the number of vehicles that are partially or fully electric-powered. Effective November 26, 2019, the federal SAFE Vehicles Rule Part One: One National Program withdraws the California waiver for the GHG and ZEV programs under section 209 of the Clean Air Act, which revokes California's authority to implement the Advanced Clean Cars and ZEV mandates. On March 9, 2022, USEPA issued a notice of decision to reinstate California’s Clean Air Act waiver for its Advanced Clean Car regulations. 18 In addition, Governor Gavin Newsom signed an executive order (Executive Order No. N -79-20) on September 23, 2020, that would phase out sales of new gas-powered passenger cars by 2035 in California with an additional 10 -year transition period for heavy vehicles. The State would not restrict used car sales, nor forbid residents from owning gas-powered vehicles. In accordance with the Executive Order, CARB is developing a 2020 Mobile Source Strategy, a comprehensive analysis that presents scenarios for possible strategies to reduce the carbon, toxic and unhealthy pollution from cars, trucks, equipment, and ships. The strategies will provide important information for numerous regulations and incentive programs going forward by conveying what is necessary to address the aggressive emission reduction requirements.

17 CARB, Clean Car Standards – Pavley, AB 1493, https://ww2.arb.ca.gov/californias-greenhouse-gas-vehicle-emission- standards-under-assembly-bill-1493-2002-pavley, last reviewed January 11, 2017. Accessed January 31, 2022. 18 California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Notice of Decision, 87 Fed. Reg. 14,332 (Mar. 14, 2022).

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

Airborne Toxic Control Measure to Limit Diesel-Fueled Commercial Motor Vehicle Idling In 2004, the CARB adopted an Airborne Toxic Control Measure to Limit Diesel -Fueled Commercial Motor Vehicle Idling in order to reduce public exposure to diesel particulate matter emissions (CCR Title 13, Section 2485). The measure applies to diesel -fueled commercial vehicles with gross vehicle weight ratings greater than 10,000 pounds that are licensed to operate on highways, regardless of where they are registered. This measure does not allow diesel -fueled commercial vehicles to idle for more than five min utes at any given location. While the goal of this measure is primarily to reduce public health impacts from diesel emissions, compliance with the regulation also results in energy savings in the form of reduced fuel consumption from unnecessary idling.

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

Large fleets have compliance deadlines each year from 2014 through 2023, medium fleets each year from 2017 through 2023, and small fleets each year from 2019 through 2028. While the goal of this regulation is primarily to reduce public health impacts from diesel emissions, compliance with the regulation also results in energy savings in the form of reduced fuel consumption from the use of more fuel-efficient engines.

Sustainable Communities Strategy
Adopted by the State on September 30, 2008, the Sustainable Communities and Climate Protection Act of 2008, or SB 375, establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions. Pursuant to SB 375, on April 7, 2016, the Southern California Association of Governments (SCAG) adopted the 2016 –2040 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), which achieves and exceeds the GHG emission-reduction targets set by CARB by demonstrating an 8 percent reduction in vehicular emissions by 2020, an 18 percent reduction by 2035, and a 21 percent reduction by 2040 as compared to the 2005 level on a per capita basis.

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In addition, in September 2020, SCAG adopted the 20 20–2045 RTP/SCS, referred to as Connect SoCal, which is an update to the previous 2016 –2040 RTP/SCS. Using growth forecasts and economic trends, Connect SoCal provides a vision for transportation throughout the region for the next 25 years. Connect SoCal successfully achieves and exceeds the GHG emission -reduction targets set by CARB. Compliance with and implementation of Connect SoCal policies and strategies would have the co -benefits of reducing per capita vehicle miles travelled (VMT ) and corresponding decreases in per capita transportation-related fuel consumption.

Refer to Section 4. 6, Greenhouse Gas Emissions, of this Draft EIR for details regarding these applicable policies and strategies.

California Environmental Quality Act
In accordance with CEQA and Appendix F, Energy Conservation , of the CEQA Guidelines, in order to assure that energy implications are considered in project decisions, EIRs are required to include a discussion of the potential significant energy impacts of proposed projects, with particular emphasis on avoiding or reducing inefficient, wasteful, and unnecessary consumption of energy.

Appendix F of the CEQA Guidelines provides a list of energy-related topics that should be analyzed in the EIR. In addition, while not described or required as significance thresholds for determining the significance of impacts related to energy, Appendix F provides the following topics that the lead agency may consider in the discussion of energy use in an EIR, where topics are applicable or relevant to project:
• The project’s energy requirements and its energy use efficiencies by amount and fuel type for each stage of the project including construction, operation, maintenance, and/or removal. If appropriate, the energy intensiveness of materials may be discussed; • The effects of the project on local and regional energy supplies and on requirements for additional capacity;
• The effects of the project on peak and base period demands for electricity and other forms of energy;
• The degree to which the project complies with existing energy standards; • The effects of the project on energy resources;
• The project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.
• The degree to which the project design and/or operations incorporate energy-conservation measures, particularly those that go beyond City requirements. • Whether the Project conflicts with adopted energy conservation plans.

Regional
Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) SB 375 requires each Metropolitan Planning Organization ( MPO) to prepare a Sustainable Communities Strategy (SCS) in their regional transportation plan. In general, the SCS outlines a development pattern for the region, which, when integrated with the transportation network and other transportation measures and policies, would reduce vehicle miles traveled from automobiles

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and light duty trucks and thereby reduce GHG emissions from these sources. For the SCAG region, Connect SoCal (the 2020–2045 RTP/SCS), adopted on September 3, 2020, is the current RTP/SCS and is an update to the 2016–2040 RTP/SCS.

Connect SoCal focuses on the continued efforts of the previous RTP/SCS plans for an integrated approach in transportation and land use strategies in development of the SCAG region through horizon year 2045. Connect SoCal projects that the SCAG region will meet the GHG per capita reduction targets established for the SCAG region of eight percent by 2020 and 19 percent by 2035.

City Council Meeting AgendaNovember 11, 2024

City Council Meeting Agenda
November 11, 2024