Additionally, its implementation is projected to reduce VMT per capita for the year 2045 by 4.1 percent compared to baseline conditions for the year. Rooted in the 2008 and 2012 RTP/SCS plans, Connect SoCal includes “Core Vision” that centers on maintaining and better managing the transportation network for moving people and goods while expanding mobility choices by location housing, jobs, and transit closer together, and increasing investments in transit and complete streets.
In addition, refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for additional details regarding these requirements.
Local
Culver City Municipal Code
The City participates in an environmental recognition program, California Green Communities.
The program helps cities develop strategies to reduce carbon emissions and increase energy efficiency in their community. In addition, the City has adopted green building ordinances to reduce GHG emissions for new development. Pursuant to the Culver City Municipal Code (CCMC) Chapter 15.02.1005, the City requires 1 kilowatt (kw) of PV power installed per 10,000 square feet (sf) of new development. Under Chapter 17.320.035 of the CCMC, the City goes beyond CALGreen Code standards and requires at least 20 percent EV capable parking spaces, 10 percent EV ready parking spaces, and 10 percent EV charging stations for both new residential and retail developments.
19 Additionally, Sections 4.408.1 and 5.408.1 Construction Waste Management require the recycle and/or salvage for reuse a minimum of 75 percent of nonhazardous construction and demolition waste.
In 2009, the City adopted the Green Building P rogram as CCMC Chapter 15.02.100, which contains a number of GHG reducing features such as enhanced building insulation, low-flow water fixtures, and efficient lighting and heating, ventilation, and air conditioning ( HVAC) systems. An example of the City’s Green Building Program requirements would be all lighting required to be fluorescent, light-emitting diode (LED) or other type of high-efficiency lighting and that parking garages require all new lighting to be motion sensor controlled and the minimum base level lighting would use high-efficiency lighting.
Culver City Bicycle & Pedestrian Action Plan
As discussed in Section 4.7, Land Use and Planning and Section 4.11, Transportation, the City updated the Bicycle & Pedestrian Master Plan with the Culver City Bicycle & Pedestrian Action
19 City of Culver City Zoning Code, Title 17, Sections 17.320, Off-Street Parking and Loading, https://codelibrary.amlegal.com/codes/culvercity/latest/culvercity_ca/0-0-0-52279#JD_17.320.020. Accessed January 18, 2021.
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Plan (Action Plan) which received public input from 2017 through 2019. The Action Plan was adopted by the City Council in June 2020.20 The Action Plan establishes the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network. The Action Plan includes goals to support increased access to neighborhood destinations and transit stations, empowering residents to live a more active lifestyle, and increasing affordability and collaboration for transportation within the community. Hannum Avenue and Buckingham Parkway, adjacent to the Project Site, contain a Class II Bike lane. The approved Action Plan shows that Buckingham Parkway between Hannum Avenue and Green Valley Circle, immediately adjacent to the Project Site, are planned as Class IV Separated Bikeways.
21 Clean Power Alliance
In February 2019 for residential customers and May 2019 for non-residential customers, Clean Power Alliance (CPA) became the new electricity supplier for Culver City. With this change, CPA purchases the renewable energy resources for electricity and Southern California Edison ( SCE) delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent or opt out of the CPA to remain with SCE as their provider.
The Project’s energy analyses conservatively assume the Project will remain with SCE as their electricity provider and does not take additional credit for renewable energy beyond the expected SCE renewable energy percentage for year 2022 based on the required renewables by year 2024 under SB 100.
22 Culver City Reach Code
The Culver City Reach Code, codified under CCMC Section 15.02.1100, establishes building energy efficiency standards that are additional to the standards established by the State’s CALGreen Building Code and Title 24 Energy Code requirements. The Culver City Reach Code includes provisions for all new buildings with separate standards for buildings of 49,999 sf or less (Category 1) and buildings 50,000 sf or more (Category 2). The following requirements do not apply to one- and two-family residences.
For Category 1 buildings, the Reach Code provides a list of 25 items that new buildings can implement in order to meet the standards. A project must comply with at least 80 percent of all items listed. Examples include gas heating units being 93 percent energy efficient, installing radiant
20 City of Culver City, Bicycle & Pedestrian Action Plan, June 2020, https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021-10-cc-bikepedplan- app2020-v10-final.pdf. Accessed September 7, 2023.
21 As defined by Caltrans, a Class IV separated bikeway is an on-street facility that is physically separated from other motor vehicle traffic by a vertical element or barrier, such as a curb, bollards, or vehicle parking aisle. 22 For the purposes of estimating energy demand, the analysis conservatively assumes the Project would not switch electricity providers from SCE to the CPA (i.e., does not take any credit for 36 percent, 50 percent, or 100 percent renewable electricity, depending on the selected CPA plan). Should the Project switch electricity providers from SCE to the CPA, the Project’s electricity-related emissions would be lower than those disclosed in this section.
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barriers on all new roof sheathing, installing high-efficiency lighting in all exterior and interior spaces, and installing 1 kW of solar photovoltaic.
For Category 2 buildings, the Reach Code establishes three mandatory requirements related to Leadership in Energy and Environmental Design ( LEED) certification. The requirements include the following:
(1) Prior to the issuance of a building permit, the applicant shall submit:
a. Evidence that a LEED Accredited Professional (AP) is one of the members of the project team
b. Evidence that the project has been registered with the United States Green Building Council’s (USGBC) LEED Program
c. Complete a LEED Checklist including points allocated to the “Innovation and Design” category, which demonstrates that the project meets the selected LEED® Rating System at the “Certified” level or higher.
d. A signed declaration from the LEED® -AP member of the project team, stating that the plans and plan details have been reviewed and the project meets the intent of the criteria for certification of the selected LEED® Rating System at the “Certified” level or higher. (2) The project shall comply with USGBC’s “3 point margin of error” for LEED Certification. (3) Applicant shall submit to the Building Official copies of all correspondence between the applicant and USGBC regarding the project.
Existing Conditions
Existing Electricity Sales
Electricity, as a consumptive utility, is a man-made resource. The production of electricity requires the consumption or conversion of energy resources , including water, wind, oil, gas, coal, solar, geothermal, and nuclear resources, into energy. The delivery of electricity involves a number of system components for distribution and use. The electricity generated is distributed through a network of transmission and distribution lines commonly called a power grid.
Energy capacity, or electrical power, is generally measured in watts (W), while energy use is measured in watt -hours (Wh). For example, if a light bulb has a capacity rating of 100 W, the energy required to keep the bulb on for 1 hour would be 100 Wh. If t en 100 W bulbs were on for 1 hour, the energy required would be 1,000 Wh or 1 kilowatt-hour (kWh). On a utility scale, the capacity of a generator is typically rated in megawatts (MW), which is 1 million W, while energy usage is measured in megawatt-hours (MWh) or gigawatt-hours (GWh), which is 1 billion Wh.
SCE provides electrical services to approximately 15 million people, 15 counties, 180 incorporated cities including the Culver City and the Project Site, 5,000 large businesses, and 280,000 small businesses throughout its 50,000-square-mile service area, across central, coastal and southern California, an area bounded by Mono County to the North, Ventura County to the West, San
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Bernardino County to the East, and Orange County to the South. 23 SCE produces and purchases energy from a mix of conventional and renewable generating sources.
SCE generates power from a variety of energy sources, including large hydropower (greater than 30 MW), coal, gas, nuclear sources, and renewable resources, such as wind, solar, small hydropower (less than 30 MW), and geothermal sources. The annual electricity sale to customers in 2022 was approximately 84,218,000 MWh.24 See Table 4.4-1, Existing Annual Regional Energy Use, for a summary of energy use for the region, including the SCE service area.
TABLE 4.4-1
EXISTING ANNUAL REGIONAL ENERGY USE
Source Amount
Electricity (SCE service area) a 84,218,000 MWh
Natural Gas (SoCalGas service area) b 1,253,775 cf
Gasoline (Los Angeles County) c 3,070,000,000 gallons
Diesel (Los Angeles County) c 463,800,000 gallons
SOURCES:
a Edison International and Southern California Edison (SCE), 2022 Annual Report, 2022, page 2, https://download.edison.com/406/files/20232/2022-eix-sce-annual- report.pdf?Signature=N0sq4yv8uPjj%2F32CHqD9P67Ydr0%3D&Expires=1696599567&AWSAccessKeyId=AKIA JX7XEOOELCYGIVDQ&versionId=bpeN_aiySep67UMc7RtP511pq9M5I127&response-content- disposition=attachment. Accessed October 2023.
b California Gas and Electric Utilities, 2022 California Gas Report, page 186, https://www.socalgas.com/sites/default/files/Joint_Utility_Biennial_Comprehensive_California_Gas_Report_2022. pdf. Accessed October 2023.
c CEC, California Retail Fuel Outlet Annual Reporting (CEC-A15) Year 2022 Results.
SCE is required to commit to the use of renewable energy sources for compliance with the Renewable Portfolio Standards. As shown in Table 4.4-2, Electric Power Mix Delivered to Retail Customers in 20 21, SCE procures 31.4 percent of its energy portfolio from renewable sources.
Senate Bill (SB) 350 (Chapter 547, Statues of 2015) and SB 100 (Chapter 312, Statutes of 2018) further increased California’s Renewable Portfolio Standards and requires retail sellers and local publicly owned electric utilities to procure eligible renewable electr icity for 44 percent of retail sales by December 31, 2024, 52 percent by December 31, 2027, and 60 percent by December 31, 2030. The legislation also instructed CARB to plan for 100 percent eligible renewable energy resources and zero-carbon resources by December 31, 2045.25 SCE anticipates it will meet its own climate change and renewables objectives that align with SB 100's 2045 renewables requirement.26
23 Southern California Edison (SCE), Who We Are, https://www.sce.com/about-us/who-we-are. Accessed October 2023. 24 Edison International and SCE, 2022 Annual Report, 2022, page 2, https://download.edison.com/406/files/20232/2022-eix-sce-annual- report.pdf?Signature=N0sq4yv8uPjj%2F32CHqD9P67Ydr0%3D&Expires=1696599567&AWSAccessKeyId=AKI AJX7XEOOELCYGIVDQ&versionId=bpeN_aiySep67UMc7RtP511pq9M5I127&response-content- disposition=attachment. Accessed October 2023.
25 California Legislative Information, Senate Bill 100, California Renewable Portfolio Standards Program: Emissions of Greenhouse Gases, Approved by Governor on September 10, 2018, https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=201720180SB100. Accessed October 2023. 26 Edison International and SCE, 2022 Annual Report, 2022, page 159.
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TABLE 4.4-2
ELECTRIC POWER MIX DELIVERED TO RETAIL CUSTOMERS IN 2021 Energy Resource 2021 SCE
2021 CA Power Mix
(for comparison)
Eligible Renewable 31.4% a 33.6% a
Biomass & bio-waste 0.1% 2.3%
Geothermal 5.7% 4.8%
Eligible hydroelectric 0.5% 1.0%
Solar 14.9% 14.2%
Wind 10.2% 11.4%
Coal 0.0% 3.0%
Large Hydroelectric 2.3% 9.2%
Natural Gas 22.3% 37.9%
Nuclear 9.2% 9.3%
Other 0.2% 0.2%
Unspecified sources of power b 34.6% 6.8%
Total 100% 100%
a Percentages are estimated annually by the CEC based on the electricity sold to California consumers during the previous year. b “Unspecified sources of power” means electricity from transactions that are not traceable to specific generation sources.
SOURCES: CEC, 2021 Power Content Label, Southern California Edison, https://www.energy.ca.gov/filebrowser/download/4676, Accessed October 2023.
Existing Natural Gas Supply
Natural gas is a combustible mixture of simple hydrocarbon compounds (primarily methane) that is used as a fuel source. Natural gas consumed in California is obtained from naturally occurring reservoirs and delivered through high-pressure transmission pipelines. Natural gas provides almost one-third of the State’s total energy requirements. Natural gas is mea sured in terms of both cubic feet (cf) or British thermal units (Btu).
Natural gas is used for cooking, space heating, water heating, electricity generation, and as an alternative transportation fuel. The Project Site is served by the Southern California Gas Company (SoCalGas), which is the principal distributor of natural gas in Southern California, serving residential, commercial, and industrial markets. SoCalGas serves approximately 21. 8 million customers in more than 500 communities encompassing approximately 24 ,000 square miles throughout central and southern California, from the City of Visalia to the US/Mexican border. 27 SoCalGas, along with five other California utility providers, released the 2022 California Gas Report, presenting a forecast of natural gas supplies and requirements for California through the year 2035. The 202 2 California Gas Report predicts gas demand for all sectors (residential, commercial, industrial, energy generation and wholesale exports) and presents best estimates, as well as scenarios for hot and cold years. Overall, SoCalGas predicts a decrease in natural gas
27 SoCalGas, Company Profile, https://www.socalgas.com/about-us/company-profile. Accessed October 2023.
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demand in future years due to a decrease in per capita usage, energy efficiency policies, and the State’s transition to renewable energy displacing fossil fuels including natural gas.28 SoCalGas receives gas supplies from several sedimentary basins in the western United States (US) and Canada, including supply basins located in New Mexico (San Juan Basin), west Texas (Permian Basin), the Rocky Mountains, and western Canada as well as local California supplies. 29 Sources of natural gas in the southwestern US will continue to supply most of SoCalGas’ natural gas demand. The Rocky Mountain supply is available but is used as an alternative supplementary supply source, and Canadian sources provide only a small share of SoCalGas supplies due to the high cost of transport.
30 Gas supply available to SoCalGas averaged 3,435 million cf per day in 2022. This equates to an annual average of 1,253,775 million cf per year. 31 See Table 4.4-1 for a summary of energy use for the region, including the SoCalGas service area.
Existing Transportation Energy
The annual transportation fuel consumption of diesel and gasoline in 2022 for California (the most recent year for which S tatewide data is available) is 1, 846 million gallons and 11,495 million gallons respectively. Transportation fuel consumption of diesel and gasoline for Los Angeles County in 2022 is 464 million gallons and 3,070 million gallons, respectively. The estimated Los Angeles County and Statewide transportation fuel consumption is based on retail sale data from the CEC.
32 See Table 4.4-1 for a summary of Los Angeles County fossil fuel consumption in 2022.
The State is now working on developing flexible strategies to reduce petroleum use. Over the last decade, California has implemented several policies, rules, and regulations to improve vehicle efficiency, increase the development and use of alternative fuels, reduce air pollutants and GHGs from the transportation sector, and reduce VMT. Accordingly, gasoline consumption in California has declined. The CEC predicts that the demand for gasoline will continue to decline over the next 10 years, and there will be an increase in the use of alternative fuels. 33 Existing Project Site
The 2.23-acre Project Site is currently developed with a two-story office building in the northern portion of the Project Site and associated surface parking . All existing improvements would be removed. Energy demand (i.e. , electricity, natural gas, and fuel consumption from vehicle trips) from the existing uses is estimated and incorporated into this analysis to determine the Project’s net (Project minus existing) energy consumption. As detailed under Section 4.4.3 under Methodology, annual electricity and natural gas usage is estimated using CalEEMod and is based on the size of the buildings. Existing gasoline and diesel usage are estimated based on existing
28 California Gas and Electric Utilities, 2022 California Gas Report. 29 California Gas and Electric Utilities, 2022 California Gas Report. 30 California Gas and Electric Utilities, 2022 California Gas Report. 31 California Gas and Electric Utilities, 2022 California Gas Report. 32 CEC, California Retail Fuel Outlet Annual Reporting (CEC-A15) Results , 2022, https://www.energy.ca.gov/data- reports/energy-almanac/transportation-energy/california-retail-fuel-outlet-annual-reporting. Accessed October 2023.
33 CEC, 2019 Integrated Energy Policy Report, February 2020, page 228, https://efiling.energy.ca.gov/getdocument.aspx?tn=232922. Accessed October 2023.
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VMT and the estimated fuel economy and fuel consumption factors from CARB EMission FACtors model (EMFAC) model (specifically EMFAC 2021).
Current annual energy demand estimated for the existing land uses located on the Project Site is presented in Table 4.4-3, Existing Site Annual Energy Use.
TABLE 4.4-3
EXISTING SITE ANNUAL ENERGY USE
Source Amount
Electricity 489 MWh
Natural Gas 595,417 cf
Gasoline 27,420 gallons
Diesel 3,722 gallons
SOURCE: ESA, 2023.
4.4.3 Environmental Impacts
Thresholds of Significance
The following thresholds of significance are based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in significant adverse impacts related to Energy if it would:
• ENE-1 Result in potentially significant environmental impact due to wasteful, inefficient, or unnecessary consumption of energy resources, during project construction or operation; or • ENE-2 Conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
For this analysis, the Appendix G Thresholds are relied upon. The analysis utilizes factors and considerations identified in Appendix G and Appendix F of the CEQA Guidelines, as appropriate, to assist in answering the Appendix G questions. The factors to evaluate energy impacts under Threshold ENE-1 include:
1) 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; 2) The effects of the Project on local and regional energy supplies and on requirements for additional capacity;
3) The effects of the Project on peak and base period demands for electricity and other forms of energy;
4) The effects of the Project on energy resources; and
5) The Project’s projected transportation energy use requirements and its overall use of efficient transportation alternatives.
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In accordance with Appendix G and Appendix F of the CEQA Guidelines, the degree to which the Project complies with existing energy standards is considered, as appropriate, to evaluate impacts under Threshold ENE-2.
Methodology
Construction
Project construction is estimated to start in 2025. Anticipated construction activities would vary substantially from day to day, depending on the specific type of construction activity and the number of workers and vendors traveling to the Project Site. This analysis considers these factors and provides the estimated maximum construction energy consumption for the purposes of evaluating the associated impacts on energy resources. This analysis is based on estimated maximum construction activities, meaning that for each phase of construction it was assumed that all of the vehicles and equipment that could be used for that phase are in simultaneous use for all day and every day of the phase.
Electricity
Construction electricity was estimated for a temporary construction office, for construction equipment that would use electricity as an alternative to diesel fuel, and for water usage from dust control. The construction office was assumed to be a 2 ,000-square-foot trailer and was modeled using CalEEMod (version 2022.1.1).
34 In addition, electricity from water conveyance for dust control was also calculated based on the estimated water consumption rate per day and assuming that water used for construction is non -potable and delivered on- site by trucks to cover the area during construction activity. Region-specific water electricity intensity factors for recycled non- potable water generation and conveyance were used to convert the volume of water needed to electricity demand from water conveyance.
35 Natural Gas
Construction activities, including the construction of new buildings and facilities, typically do not involve the consumption of natural gas. Accordingly, natural gas is not expected to be consumed during Project construction. Therefore, natural gas associated with construction activities was not calculated. 36 Transportation Fuels
Fuel consumption from on-site heavy -duty construction equipment was calculated based on the equipment mix and usage factors provided in the CalEEMod construction output files included in Appendix C of this Draft EIR. The total horsepower was then multiplied by fuel usage estimates per horsepower-hour from CARB’s off-road vehicle (OFFROAD) model. Fuel consumption from construction on-road worker, vendor, and delivery/haul trucks was calculated using the trip rates and distances provided in the emissions modeling worksheets and CalEEMod construction output
34 California Air Pollution Control Officers Association, California Emissions Estimator Model, 2022, http://caleemod.com/. Accessed October 2023.
35 Next 10 and Pacific Institute, The Future of California’s Water-Energy-Climate Nexus, Table 4. 36 In general, natural gas would not be expected to be used and this energy analysis assumes heavy-duty construction equipment is diesel-fueled, as is typically the case. However, natural gas-fueled heavy-duty construction equipment could be used to replace some diesel-fueled heavy-duty construction equipment. If this does occur, diesel fuel demand would be slightly reduced and replaced by a small amount of temporary natural gas demand. This would not substantially affect the energy analysis or conclusions provided herein.
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files. Total VMT for these on -road vehicles were then calculated for each type of construction- related trip and divided by the corresponding county-specific miles per gallon factor using CARB’s EMFAC2021 model. EMFAC provides the total annual VMT and fuel consumed for each vehicle type. CalEEMod assumed trip lengths were used for worker commutes while vendor, management visits, concrete, and haul truck trips were taken from emissions modeling worksheets that used EMFAC2021 emission factors.
Consistent with CalEEMod, construction worker trips were assumed to include a mix of light duty gasoline automobiles and light duty gasoline trucks. Construction vendor trucks were assumed to be a mix of medium -heavy-duty and heavy-duty diesel trucks, and concrete and haul trucks were assumed to be heavy-duty diesel trucks. Refer to Appendix E of this Draft EIR for detailed energy calculations.
The energy usage required for Project construction has been estimated based on the number and type of construction equipment that would be used during Project construction by assuming a conservative estimate of construction activities (i.e., maximum daily equipment usage levels).
Energy for construction worker commuting trips has been estimated based on the expected number of workers for the various phases of construction and the estimated VMT based on the conservative values in the CalEEMod and EMFAC2021 m odels. The assessment also includes a discussion of the Project’s compliance with relevant energy-related regulatory requirements that would minimize the amount of energy usage during construction. These measures are also discussed in Chapter 2, Project Description, Section 4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions, of this Draft EIR.
The construction equipment and haul trucks would likely be diesel -fueled, while the construction worker commute vehicles would primarily be gasoline-fueled. For the purposes of this assessment, it is conservatively assumed that all heavy -duty construction equipment and haul trucks would be diesel-fueled. The estimated fuel economy for heavy-duty construction equipment is based on fuel consumption factors from the CARB OFFROAD emissions model, which is a State-approved model for estimating emissions from off-road heavy-duty equipment. The estimated fuel economy for haul trucks and worker commute vehicles is based on fuel consumption factors from the CARB EMFAC 2021 emissions model. Both OFFROAD and EMFAC are incorporated into CalEEMod.
However, fuel consumption for worker, vendor, and concrete/haul trucks were calculated outside of CalEEMod using emission factors from EMFAC2021 to provide a more detailed and accurate account of truck fuel consumption.
Operation
Operation of the Project would require energy in the form of electricity and natural gas for building space and water heating, cooling, cooking, lighting, water demand and wastewater treatment, consumer electronics, and other energy needs, and transportation fuels, primarily gasoline, for on- site landscaping equipment and vehicles traveling to and from the Project Site. Operational energy impacts were assessed based on the increase in energy demand compared to existing conditions.
The net change in operational energy demand is based on the difference between the existing Project Site energy demand and the energy demand of the Project at full buildout.
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Electricity
The Project’s estimated electricity demand was analyzed relative to SCE’s existing and planned energy supplies in 2027 (i.e., the Project buildout year) to determine if the utility would be able to meet the Project’s energy demands. Annual consumption of electricity (including electricity usage associated with the supply and conveyance of water) from Project operation was calculated using demand factors provided in CalEEMod , which are based on the 2019 Title 24 standards, which went into effect on January 1, 2020. The 2022 Title 24 standards are in effect as of January 1, 2023; therefore, the analysis is likely conservative and overestimates Project operational building energy demand. Energy usage from water demand (e.g., electricity used to supply, convey, treat, and distribute) was estimated based on new buildings and facilities. The assessment also includes a discussion of the Project’s compliance with relevant energy-related regulations and its land use transportation characteristics that would minimize t he amount of energy usage during operations.
These features and characteristics are also discussed in Chapter 2, Project Description, Section 4.2, Air Quality, and Section 4.6, Greenhouse Gas Emissions, of this Draft EIR. Electricity generated by the existing site was calculated using demand factors provided in CalEEMod and subtracted from the Project’s electricity demand to obtain the net annual electricity demand.
Natural Gas
The Project’s estimated natural gas demand was analyzed relative to SoCalGas’ existing and planned energy supplies in 2027 (i.e., the Project buildout year)37 to determine if the utility would be able to meet the Project’s energy demands. Natural gas demand for the Project would be generated mainly by building heating and appliances. Natural gas demand generated by the existing site was calculated using demand factors provided in CalEEMod and subtracted from the Project’s natural gas demand to obtain the net annual natural gas demand.
Transportation Fuels
Energy for transportation from Project and existing land use visitors and employees traveling to and from the Project Site is estimated based on the predicted number of trips to and from the Project Site and existing site, based on VMT output from the Culver City VMT Calculator used to estimate trips for the Project.
38 The Project and existing annual VMT is based on the sum of the estimated daily VMT (365 days out of a year). Refer to VMT data in Appendix I of this Draft EIR and energy calculations in Appendix E of this Draft EIR.
Project Design Features
The following project design features (PDFs) would be implemented as part of the Project:
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 highe r 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.
37 California Gas and Electric Utilities, 2020 California Gas Report, 2020, p. 145. 38 City of Culver City, VMT Calculator. Provided in Appendix I of this Draft EIR.
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• 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.
• 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.
In addition to Project Design Feature GHG-PDF -1, the Project would implement Project Design Feature TRAF -PDF-2 (Transportation Demand Management (TDM) Program), which would reduce single occupancy trips, and VMT. These PDFs would also reduce GHG emissions.
Analysis of Project Impacts
Impact ENE-1: The Project could have a potentially significant impact on energy if it would result in wasteful, inefficient, or unnecessary consumption of energy resources, during P roject construction or operation.
Impact Analysis
Factor 1: 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
Construction
During construction of the Project, energy would be consumed in the form of electricity for powering the construction office (lights, electronic equipment, and heating and cooling), water conveyance for dust control, and other construction activities. Natu ral gas would not be used for construction purposes. Project construction would also consume energy in the form of petroleum -based fuels associated with the use of off- road construction vehicles and equipment on the Project Site, construction workers trave ling to and from the Project Site, and delivery and haul truck trips (e.g., hauling of demolition material to off -site reuse and disposal facilities).
The estimated total energy consumed during construction is shown in Table 4.4-4, Summary of Energy Use During Project Construction . Calculation details are provided in Appendix E of this Draft EIR.
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TABLE 4.4-4
SUMMARY OF ENERGY USE DURING PROJECT CONSTRUCTION
Energy Type Total Quantity
Annual Average Quantity
During Construction
Electricity
Construction Office 102,060 kWh 40,936 kWh
Electricity from Water (Dust Control) 7,059 kWh 2,831 kWh Total Electricity 109,119 kWh 43,767 kWh
Gasoline
On-Road Construction Equipment 74,674 gallons 29,952 gallons Off-Road Construction Equipment 0 gallons 0 gallons
Total Gasoline 74,674 gallons 29,952 gallons
Diesel
On-Road Construction Equipment 80,548 gallons 32,308 gallons Off-Road Construction Equipment 84,718 gallons 33,980 gallons Total Diesel 165,266 gallons 66,288 gallons
NOTES: kWh = kilowatt-hours
a Detailed calculations are provided in Appendix E of this Draft EIR.
SOURCE: ESA, 2023.
Electricity
During construction of the Project, electricity would be used for the construction office (lights, electronic equipment, and heating and cooling), water conveyance for dust control, and other construction activities. Electricity would be supplied to the Project Site by SCE and would be obtained from the existing electrical lines that connect to the Project Site.
As shown in Table 4.4 -4, annual average construction electricity usage would be approximately
43.8 MWh. The electricity demand would be within the supply and infrastructure capabilities of SCE (which reported 84,218 GWh of total energy sales in the 2021– 2022 fiscal year). 39 The
electricity demand at any given time would vary throughout the construction period based on the construction activities being performed and would cease upon completion of construction.
Electricity use from construction would be short-term, limited to working hours, used for necessary construction-related activities, and represent a small fraction of the Project’s net annual operational electricity. Therefore, the Project would not result in a wasteful, inefficient, and unnecessary consumption of energy associated with electricity used for construction, and impacts would be less than significant.
Natural Gas
As previously stated above, construction activities, including the construction of new buildings and facilities, typically do not involve the consumption of natural gas. Accordingly, natural gas would
39 SCE, 2022 Annual Report, https://download.edison.com/406/files/20232/2022-eix-sce-annual-report.pdf. Accessed October 2023.
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not be supplied to support Project construction activities; thus, there would be no expected demand generated by construction of the Project. Therefore, the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy associ ated with natural gas used for construction and impacts would be less than significant.
Transportation Energy
Table 4.4-4 reports the estimated amount of petroleum -based transportation energy that could potentially be consumed during Project construction based on the set of assumptions provided in Appendix E of this Draft EIR. During Project construction, on - and off -road vehicles would consume an estimated annual average of approximately 29,952 gallons of gasoline fuel and approximately 66,288 gallons of diesel over the approximately 30 months of construction. For comparison purposes only, and not for the purpose of determining significance, the fuel usage during Project construction would represent approximately 0.001 percent of the 2022 annual on- road gasoline-related energy consumption and 0.14 percent of the 2022 annual diesel-related energy consumption in Los Angeles County, as shown in Appendix E of this Draft EIR. 40 Construction of the Project would utilize fuel-efficient equipment consistent with State and federal regulations, such as fuel efficiency regulations in accordance with the CARB Pavley Phase II standards, the anti -idling regulation in accordance with Section 2485 in 13 CCR, and fuel requirements in accordance with 17 CCR Section 93115. The Project would benefit from fuel and automotive manufacturers’ compliance with CAFE standards, which would result in more efficient use of transportation fuels (lower consumption). As such, the Project would indirectly comply with regulatory measures to reduce the inefficient, wasteful, and unnecessary consumption of energy, such as petroleum -based transportation fuels. While these regulations are intended to reduce construction emissions, compliance with the anti-idling and emissions regulations discussed above would also result in fuel savings from the use of more fuel-efficient engines.
Based on the analysis above, construction would utilize energy only for necessary on-site activities and to transport construction materials, excavated fill, and demolition debris to and from the Project Site. As discussed above, idling restrictions and the use of cleaner, energy -efficient equipment would result in less fuel combustion and energy consumption and, thus, reduce the Project’s construction-related energy use. Therefore, the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy and impacts associated with transportation fuels for construction would be less than significant.
Operation
During operation of the Project, energy would be consumed for multiple purposes, including, but not limited to, on-road mobile sources (i.e., transportation fuel), area sources (i.e., landscape maintenance equipment and natural gas heating), energy (i.e., electricity, natural gas), water conveyance and wastewater treatment, and solid waste. Usage of these energy sources was calculated for the Project buildout year (2027). Table 4.4-5, Summary of Annual Net New Energy
40 CEC, California Retail Fuel Outlet Annual Reporting (CEC-A15) Results , 2022, https://www.energy.ca.gov/data- reports/energy-almanac/transportation-energy/california-retail-fuel-outlet-annual-reporting. Accessed October 2023.
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Use During Project Operation , summarizes the Project’s annual net new operational energy demand for electricity, natural gas, and gasoline and diesel transportation fuels.
TABLE 4.4-5
SUMMARY OF ANNUAL NET NEW ENERGY USE DURING PROJECT OPERATION Energy Typea Annual Quantity
Electricity
Existing Site 526 MWh
Proposed Project – Total 2,320 MWh
Building Energy 2,158 MWh
EV Charging 71 MWh
Water Conveyance 91 MWh
Total Net Electricity 1,794 MWh
Natural Gas
Existing Site 666,201 cf
Proposed Project - Total 394,001 cf
Retail 26,643 cf
Mobile Sources 367,358 cf
Total Net Natural Gas (272,201 cf)
Transportation Fuel
Existing Site
Gasoline 27,420 gallons
Diesel 3,722 gallons
Proposed Project
Gasoline 131,013 gallons
Diesel 20,604 gallons
Total Net Gasoline 103,593 gallons
Total Net Diesel 16,882 gallons
NOTES: kWh = kilowatt-hours; cf = cubic feet
a Detailed calculations are provided in Appendix E of this Draft EIR.
SOURCE: ESA, 2023.
Electricity
Based on the Title 24 standards and applicable CALGreen requirements and associated building energy factors in CalEEMod, at buildout, the Project would result in a projected net increase in the on-site annual demand for electricity totaling 21,239,533 kWh for the Project, as shown in Table 4.4-5.
The Project would include energy-saving measures. These measures include Project Design Feature GHG-PDF-1 (Green Building Features), which include the Project buildings achieving the USGBC LEED Certified performance level or highe r to improve building energy efficiency above regulatory requirements. LEED Certification requires documenting achievement of the rating
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system requirements and the required credits after the completion of construction. Projects may achieve credits in a variety of categories, including categories that are relevant to energy such as Location and Transportation, Water Efficiency, and Energy and Atmosphere. It is not yet known which specific credits in each of the LEED categories the Project will achieve; therefore, it is not possible at this time to accurately quantify specific amounts of energy reduction the Project would achieve from LEED Certification above regulatory requirements. Therefore, LEED Certified performance level or higher is not quantitatively accounted for in this analysis.
These measures include energy conservation, water conservation, TDM and mobility measures, and pedestrian- and bicycle-friendly site design. Also as included in 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 limited natural gas in the retail space.
Accordingly, natural gas would not be supplied to support Project operational activities related to building energy for all Project land uses except for limited use in the retail space. While building electrification would result in higher electricity usage, it would greatly reduce the use of a fossil fuel and the associated GHG emissions (i.e., natural gas combustion) from building energy demand since only the retail space still uses nat ural gas. The Project would also comply with applicable solar installation regulatory requirements.
Further, SCE is required to procure at least 33 percent of its energy portfolio from renewable sources by 2020. With the passage of SB 100 in September 2018, SCE will be required to update its long -term plans to demonstrate compliance including providing 6 0 percent of its energy portfolio from renewable sources by December 31, 2030, and ultimately planning for 100 percent eligible renewable energy resources and zero -carbon resources by December 31, 2045. SCE’s current sources include wind, solar, eligible hydroelectric, biomass/biowaste, and geothermal sources.
Based on the CEC ’s 2021–2035 Energy Demand Forecast, SCE total system sales for 2027 are estimated to be 101 ,171,000 MWh of electricity.
41 A s such , the Project-related net increase in
annual electricity consumption of 1,794 MWh per year would represent approximately 0.002 percent of SCE’s total energy sales. In addition, as previously described, the Project would incorporate a variety of energy conservation measures to reduce energy usage. Therefore, operation of the Project would not result in the wasteful, inefficient, or unnecessary consumption of electricity.
Natural Gas
With compliance with the Title 24 standards and applicable CALGreen Code requirements, buildout of the Project is projected to generate a net decrease in the on-site demand for natural gas of approximately 272,201 cf per year. As discussed above, in addition to complying with applicable regulatory requirements regarding energy conservation (e.g., California Building Energy Efficiency Standards and CALGreen Code), the Project will implement GHG-PDF-1 and other sustainability features to further reduce energy use and will include all-electric development except
41 CEC, The California Energy Demand 2021–2035, Mid-Demand Case. https://www.energy.ca.gov/data- reports/reports/integrated-energy-policy-report/2021-integrated-energy-policy-report/2021-1. Accessed October 2023.
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for the retail space. Consistent with regulatory requirements and the City’s G reen Building Program, the Project would also include building features that would include such items as energy- efficient appliances, water efficient plumbing fixtures and fittings, and water-efficient landscaping.
The Project would not result in an increase in consumption in SoCalGas’ planning area. Therefore, operation of the Project would not result in the wasteful, inefficient, or unnecessary consumption of natural gas.
Transportation Energy
During operation, Project-related traffic would result in the consumption of petroleum-based fuels related to vehicular travel to and from the Project Site. A majority of the vehicle fleet that would be used by Project residents, employees, and visitors wo uld consist of light-duty automobiles and light-duty trucks, which are subject to fuel efficiency standards. Annual trips for the Project were estimated using trip rates provided in the Project’s Transportation Study included in Appendix I of this Draft EIR.
42 As shown in Table 4.4-5, the Project’s estimated annual net increase in petroleum-based fuel usage would be 103,593 gallons of gasoline and 16,882 gallons of diesel. The Project would account for approximately 0.003 percent of the County’s 2022 gasoline consumption and approximately 0.004 percent of the County’s 2022 diesel consumption.
The Project would benefit from fuel and automotive manufacturers’ compliance with CAFE standards, which would result in more efficient use of transportation fuels (lower consumption).
Project-related vehicle trips would also indirectly benefit from Pavley Standards, which are designed to reduce vehicle GHG emissions by mandating increasingly stringent emissions standards on new vehicles but would also result in fuel savings from more efficient engines in addition to compliance with CAFE standards.
The Project would support Statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles for the reasons provided below. As discussed in detail in Section 4.6 , Greenhouse Gas Emissions, the Project would not conflict with the Connect SoCal goals and benefits intended to improve mobility and access to diverse destinations, provide better “placemaking,” provide more transportation choices, and reduce vehicular demand and associated emissions. The Project represents an infill development at a location served by several local and regional bus lines including Culver CityBus 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 Metropolitan Transportation Authority (Metro) Bus Lines 108 and 110, as well as Culver CityBus Line 6. Also, the Project would include 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section
7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PDF-2). The Project would provide residents, visitors, and employees with the ability to access nearby public
42 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
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transit and opportunities for walking and biking, which would facilitate a reduction in VMT and related vehicular fuel consumption.
Based on the above, the Project would minimize operational transportation fuel demand consistent with State, regional, and City goals. Therefore, operation of the Project would not result in the wasteful, inefficient, and unnecessary consumption of energy.
Factor 2: The Effects of the Project on Local and Regional Energy Supplies and on Requirements for Additional Capacity
Construction
Electricity
As discussed above, electricity would be consumed during Project construction activities. The electricity demand at any given time would vary throughout the construction period based on the construction activities being performed and would cease upon completion of construction.
Electricity would be supplied to the Project Site by SCE and would be obtained from the existing electrical lines that connect to the Project Site. While temporary power poles would be installed to provide electricity during Project construction, the existing off -site infrastructure would not have to be expanded or newly developed to provide electrical service to the Project Site during construction or demolition. Electricity demand during Project construction would be 1.9 percent of the Project’s net annual operational electricity consumption and would be 8.3 percent of the existing site’s electricity demand, which would be within the supply and infrastructure capabilities of SCE and, thus, would not result in an increase in demand for electricity that exceeds available supply or distribution infrastructure capabilities that could result in the construction of new facilities or expansion of existing facilities.
Natural Gas
Construction activities, including the construction of new buildings and facilities, typically do not involve the consumption of natural gas. Accordingly, natural gas would not be supplied to support Project construction activities; thus, there would be no demand generated by construction. Since the Project Site is located in an area already served by existing natural gas infrastructure, it is anticipated that the Project would not require extensive off -site infrastructure improvements to serve the Project Site.
Transportation Fuel
As stated above, t ransportation fuel usage during Project construction activities would represent
0.001 percent of gasoline usage and 0.01 percent of diesel usage within Los Angeles County, respectively. Construction transportation energy would be provided by existing retai l service stations and from existing mobile fuel services that are typically needed to deliver fuel to a construction site to refuel the off-road construction equipment at the Project Site, and, as such, no new facilities would be required. Energy consumption during construction be temporary and short- term, and energy supplies of the existing providers would be sufficient to serve the project in addition to existing commitments . As such, the Project would not affect the local and/or regional energy supplies and would not require additional capacity.
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Operation
Electricity
Based on CEC’s 2021-2035 California Energy Demand Forecast, SCE is forecasted to have energy sales of 101,171 GWh in the 2027-2028 fiscal year (the Project’s first full buildout year). 43 The Project-related increase in annual electricity consumption of 1,794 MWh/year at would represent
0.002 percent of SCE’s projected system sales for 2027. Energy consumption would be consistent with SCE anticipated regional demand from population or economic growth. During peak conditions, the Project would represent 0.002 percent of the SCE estimated peak load. Based on these factors, it is anticipated that SCE’s existing and planned electricity capacity and electricity supplies would be sufficient to serve the Project’s electricity demand, and, thus, the Project would not require additional infrastructure (i.e., a substation) beyond the aforementioned proposed utilities installed on-site during construction.
Natural Gas
As stated above, the Project would result in an annual net decrease in demand for natural gas.
Therefore, since SoCalGas’ infrastructure is sufficient to serve existing uses and the Project would use less natural gas, the Project would not require an increase in supplies or infrastructure. As such, SoCalGas’ existing and planned natural gas capacity, supplies and infrastructure would be sufficient to serve the Project’s demand.
Transportation Energy
As stated above, at buildout, the Project would consume a net increase of 103,593 gallons of gasoline and 16,882 gallons of diesel per year. For comparison purposes, the transportation-related fuel usage for the Project would represent 0.003 percent of the 2022 annual on-road gasoline- and
0.004 percent of the 2022 annual on-road diesel-related energy consumption in Los Angeles County (based on the available County fuel sales data). Detailed calculations are shown in Appendix E of this Draft EIR. Operationa l transportation energy would be provided by existing retail service stations, and, as such, no new retail service stations would be required. Transportation fuels (gasoline and diesel) are produced from crude oil, which can be produced from domestic suppl ies or imported from various regions around the world, and based on current proven reserves, crude oil production would be sufficient to meet over 50 years of consumption. 44 As such, existing and
planned transportation fuel supplies would be sufficient to serve the Project’s demand. In addition, the Project would provide EV charging stations, which would serve to incentivize the use of hybrid or full electric vehicles, thereby reducing the reliance on transportation fuels. As energy consumption during operation would be relatively negligible and within existing and planned supplies, the Project would not affect the local and/or regional energy supplies and would not require additional capacity.
43 CEC, The California Energy Demand 2021–2035, Mid-Demand Case. https://www.energy.ca.gov/data- reports/reports/integrated-energy-policy-report/2021-integrated-energy-policy-report/2021-1. Accessed October 2023.
44 BP Global, Oil reserves, 2018, https://www.bp.com/en/global/corporate/energy-economics/statistical-review-of- world-energy/oil.html. Accessed July 11, 2022.
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Factor 3: The Effects of the Project on Peak and Base Period Demands for Electricity and Other Forms of Energy
As discussed above, electricity demand during construction and operation of the Project would have a negligible effect on the overall capacity of SCE’s power grid and base load conditions and would be consistent with expected levels of electricity demand. SCE’s base case peak demand would be 24,531 MW in 2027.
45 Under peak conditions, the Project would consume a net increase of 1,794 MWh on an annual basis which, assuming 12 hours of active electricity demand per day, would be equivalent to 0.41 MW (peak demand assuming 4,380 hours per year of active electricity demand). In comparison to the SCE base peak load of 24,531 MW, the Project would represent
0.002 percent of the SCE base peak load and, therefore, would not create any new peak demand impacts that are inconsistent with SCE demand projections . Therefore, the Project’s electrical consumption during operational activities would have a negligible effect on peak load conditions of the power grid and is within existing and planned demand.
Factor 4: The Effects of the Project on Energy Resources Electricity
As discussed above, SCE’s electricity generation is derived from a mix of non -renewable and renewable sources, such as coal, natural gas, solar, geothermal wind and hydropower. T he CEC’s California Energy Demand 2018-2030 Revised Forecast identify adequate energy resources to support future generation capacity, and, as discussed above, SCE’s existing and planned electricity capacity and supplies would be sufficient to serve the Project’s electricity demand. 46 As discussed
above in the Regulatory Framework, one of the objectives of SB 350 was to increase the procurement of California’s electricity from renewable sources from 33 percent to 50 percent by 2030. Accordingly, SCE is required to procure at least 33 percent to 50 percent of its energy portfolio from renewable sources by 2030. SCE is on track to hit their power goals and interim targets. SCE has committed to providing an increasing percentage of its energy portfolio from renewable sources so as to exceed the RPS requirements. With the passage of SB 100, SCE will be required to update its long -term plans to demonstrate compliance with the updated r equirements including providing 60 percent of its energy portfolio from r enewable sources by December 31, 2030 and ultimately planning for 100 percent eligible renewable energy resources and zero-carbon resources by December 31, 2045. This represents the available off-site renewable sources of energy that would meet the Project’s energy demand.
With regard to on-site renewable energy sources, the Project would meet the applicable requirements of the CALGreen Building Code. The Applicant would also comply with CCMC Chapter 15.02.1005 by either installing a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code or paying an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code.
45 CEC, The California Energy Demand 2021–2035, Mid-Demand Case. https://www.energy.ca.gov/data- reports/reports/integrated-energy-policy-report/2021-integrated-energy-policy-report/2021-1. Accessed October 2023.
46 CEC, The California Energy Demand 2018–2030 Revised Forecast, 2018.
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Natural Gas
As discussed above, natural gas supplied to the Southern California area is mainly sourced from out-of-state with a small portion originating in California. According to the U.S. Energy Information Administration (EIA), the U.S. currently has approximately 90 years of natural gas reserves based on 2016 consumption. 47 Compliance with energy standards is expected to result in more efficient use of natural gas (lower consumption) in future years. 48 Therefore, as the Project would comply with energy efficiency standards for natural gas, Project construction and operation activities would have a negligible effect on natural gas supply.
Transportation Fuel
As stated earlier in the discussion, transportation fuels (gasoline and diesel) are produced from crude oil, which can be provided domestically or imported from various regions around the world.
Based on current proven reserves, crude oil production would be sufficient to meet over 50 years of worldwide consumption.
49 Therefore, Project construction and operation activities would have a negligible effect on the transportation fuel supply.
Based on the above, the Project would minimize construction and operational energy and transportation fuel demand to the extent feasible and would not substantially impact energy resources. Therefore, construction and operation of the Project would not have a significant impact on energy resources.
Factor 5: The Project’s Projected Transportation Energy Use Requirements and its Overall Use of Efficient Transportation Alternatives
As discussed in Section 4.6, Greenhouse Gas Emissions, of this Draft EIR, Connect SoCal ( SCAG 2020–2045 RTP/SCS) presents the transportation vision for the region through the year 2045 and provides a long-term investment framework for addressing the region’s transportation and related challenges. As shown in Exhibit 3.8 of Connect SoCal, the Project Site is located within an HQTA, which SCAG defines as “corridor-focused Priority Growth Areas within one half mile of an existing or planned fixed guideway transit stop or a bus transit corridor where buses pick up passengers at a frequency of every 15 minutes (or less) during peak commuting hours.” 50 Connect
SoCal encourages increasing the density of development within HQTAs and other infill locations, to reduce VMT and trips.51
The Project would not conflict with Connect SoCal goals and benefits intended to improve mobility and access to diverse destinations, provide better “placemaking,” provide more transportation choices, and reduce vehicular demand and associated emissions. The Project represents an infill development at a location served by several local and regional bus lines including Culver CityBus
47 U.S. Energy Information Administration, How much natural gas does the United States have, and how long will it last? Last updated April 9, 2018, https://www.eia.gov/tools/faqs/faq.php?id=58&t=8. Accessed July 11, 2022. 48 California Energy Commission, Tracking Progress – Energy Efficiency. Last updated September 2018. 49 BP Global, Oil reserves, 2018, https://www.bp.com/en/global/corporate/energy-economics/statistical-review-of- world-energy/oil.html. Accessed July 11, 2022.
50 Southern California Association of Governments, 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy, December 2020, pp. 51 and 91.
51 Southern California Association of Governments, 2020–2045 Regional Transportation Plan/Sustainable Communities Strategy, December 2020, pp. 50-51.
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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 Metro Bus Lines 108 and 110, as well as Culver City Bus Line 6. Also, the Project would include 92 bicycle parking spaces (11 short -term and 81 long-term spaces), as required by CMCC Section 7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PD F-2). The Project would provide residents, visitors, and employees with the ability to access nearby public transit and opportunities for walking and biking, which would facilitate a reduction in VMT and related vehicular fuel consumption.
Mitigation Measures
Impacts regarding wasteful, inefficient, or unnecessary consumption of energy resources were determined to be less than significant. Therefore, no mitigation measures are required.
Level of Significance after Mitigation
Impacts regarding wasteful, inefficient, or unnecessary consumption of energy resources 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.
Consistency with Energy Plans
Impact ENE-2: The Project could have a significant impact on energy if it would conflict with or obstruct a state or local plan for renewable energy or energy efficiency.
Impact Analysis
Construction
As discussed below, the Project would not conflict with or obstruct a state or local plan for renewable energy or energy efficiency. With respect to truck fleet operators, USEPA and NHTSA have adopted fuel efficiency standards for medium - and heavy-duty trucks. The Phase 1 heavy - duty truck standards apply to combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles and are phased in 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 type. 52 USEPA and NHTSA also adopted the Phase 2 heavy-duty truck standards, which would be phased in from 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.53 The energy modeling for trucks does not take into account specific fuel reductions from these regulations, since they would apply to fleets as they incorporate newer trucks meeting the regulatory standards; however, these regulations would have an overall beneficial effect on reducing fuel consumption from trucks over time as older trucks are replaced with newer models that meet the standards.
52 U SEPA, Fact Sheet: EPA and NHTSA Adopt First-Ever Program to Reduce Greenhouse Gas Emissions and Improve Fuel Efficiency of Medium- and Heavy-Duty Vehicles, August 2011. 53 U SEPA, Federal Register/Vol. 81, No. 206/Tuesday, Greenhouse Gas Emissions and Fuel Efficiency Standards for Medium- and Heavy-Duty Engines and Vehicles—Phase 2, October 25, 2016.
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In addition, construction equipment and trucks are required to comply with CARB regulations regarding heavy-duty truck idling limits of five minutes at a location and the phase -in of off-road emission standards that result in an increase in energy savings in the form of reduced fuel consumption from more fuel -efficient engines. Although these regulations are intended to reduce criteria pollutant emissions, compliance with the anti- idling and emissions regulations would also result in the efficient use of construction-related energy.
The Project would comply with all relevant Federal and State regulations and energy conservation plans including USEPA and NHTSA fleet fuel efficiency standards and CARB’s anti -idling regulations. Therefore, Project construction activities would not conflict with energy conservation plans and impacts would be less than significant.
Operation
A detailed discussion of the Project’s comparison with the applicable actions and strategies in Culver City’s Green Building Program, is provided in Section 4.6, Greenhouse Gas Emissions. As discussed, the Project is designed in a manner that is consistent with and not in conflict with relevant energy conservation plans that are intended to encourage development that results in the efficient use of energy resources. The Project would comply with applicable regulatory requirements for the design of new buildings, including the provisions set forth in the Title 24 standards and CALGreen Building Code, which have been incorporated into the Culver City’s Green Building Program. In addition, the Project would achieve LEED Certified performance level or highe r (refer to Project Design Feature GHG-PDF -1). The Project would include, but would not be limited to, water - efficient landscape design, rainwater management systems, high-efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; EV charging, EV capable and EV ready spaces; bicycle facilities that would meet or exceed the respective City codes; Energy Star–labeled appliances, where possible; energy-efficient and water conserving HVAC systems; and active circulation.
Electricity and natural gas usage during Project operations, as presented in Table 4.4-5, would be minimized through incorporation of applicable Title 24 standards, applicable CALGreen Building Code requirements, and Culver City’s Green Building Code. Furthermore, as noted above, the Project incorporates energy -conservation measures that would achieve LEED rating system at a "certified" performance level or higher and would include all-electric development for all land uses except retail (refer to Project Design Feature GHG-PDF-1).
The Project would also be consistent with and not conflict with regional planning strategies that address energy conservation. As discussed above and in Section 4.6, Greenhouse Gas Emissions, of this Draft EIR, SCAG’s Connect SoCal focuses on creating livable communities with an emphasis on sustainability and integrated planning, and identifies mobility, economy, and sustainability as the three principles most critical to the future of the region. As part of the approach, Connect SoCal focus on reducing fossil fuel use by decreasing VMT, encouraging the reduction of building energy use, and increasing use of renewable sources. The Project’s design and its location on an infill site within proximity to transit; its proximity to existing off -site retail, resta urant, entertainment, commercial, and job destinations; and its walkable environment would achieve a reduction in VMT. These land use characteristics are included in the transportation fuel demand
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for the Project’s mobile sources. Additional detailed information regarding these land use characteristics are provided in Section 4.2, Air Quality , and Section 4.6, Greenhouse Gas Emissions, of this Draft EIR. With respect to operational transportation -related fuel usage, the Project would support statewide efforts to improve transportation energy efficiency and reduce transportation energy consumption with respect to private automobiles. The Project would also benefit from fuel and automotive manufacturer s’ compliance with CAFE fuel economy standards and the Pavley Standards, which are designed to result in more efficient use of transportation fuels.
As a result, the Project would implement project design features and incorporate water conservation, energy conservation, landscaping, and other features consistent with applicable actions and strategies in the Culver City Green Building Code. The Project’s design would comply with existing energy standards and incorporate project design features to reduce ener gy consumption. Therefore, the Project would not conflict with energy conservation plans 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. The Project would result in less than significant impacts regarding conflicts with or obstructing a state or local plan for renewable energy or energy efficiency.
Cumulative Impacts
Wasteful, Inefficient, and Unnecessary Use of Energy
Cumulative impacts occur when the incremental effects of a proposed project are significant when combined with similar impacts from other past, present, or reasonably foreseeable projects in a similar geographic area. As presented in Chapter 3, Environmental Setting, of this Draft EIR, Table 3-1, the City of Culver City, as lead agency for the Project, has identified 12 related projects located within the vicinity of the Project Site. Of the 12 related projects, 8 are located within the City of Culver City and 4 are located within the City of Los Angeles. The geographic context for the analysis of cumulative impacts on electricity is SCE’s and Los Angeles Department of Water & Power’s (LADWP) service areas, and the geographic context for the analysis of cumulative impacts on natural gas is SoCalGas’ service area, because the Project and related projects are located within the service boundaries of SCE, LADWP, and SoCalGas. While the geog raphic context for transportation-related energy use is more difficult to define, the Project is considered in the context of County-wide consumption given the tendency for vehicles to travel within and through the County and the availability of County-lev el data. Growth within these geographies is anticipated to increase the demand for electricity, natural gas, and transportation energy, as well as the need for energy infrastructure, such as new or expanded energy facilities.
Electricity
Buildout of the Project, related projects, and additional forecasted growth in SCE’s and LADWP’s service areas would cumulatively increase the demand for electricity supplies and on infrastructure capacity. However, SCE and LADWP, in coordination with the CEC, account for future increases in service area demand based on various economic, population, and efficiency factors. SCE and
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LADWP rely on multiple forms of data from various agencies, including historical sales from the General Accountings Consumption and Earnings report, historical Los Angeles County employment data provided from the State’s Economic Development Division, plug -in electric vehicle (PEV) projections from the CEC account, building permits when determining electricity Load Forecasts, solar rooftop installations from the Solar Energy Development Group, electricity price projections from the Financial Services organi zation, and LADWP program efficiency forecasts.
54,55 As described in LADWP’s 2017 Power Strategic Long -Term Resource Plan, LADWP would continue to expand delivery capacity as needed to meet demand increases within its service area at the lowest cost and risk consistent with LADWP’s environmental priorities and reliability standards.
56 The 2017 Power Strategic Long-Term Resource Plan takes into account future energy demand, advances in renewable energy resources and technology, energy efficiency, conservation, and forecast changes in regulatory requirements. 57 Accordingly, LADWP considers
projected Los Angeles County building permit amounts calculated by the University of California, Los Angeles Anderson School of Management when determining its load forecast and would, therefore, account for the Project’s and the related projects’ electricity demand within its forecasts.
58 SCE has determined that the use of energy resources would be minor compared to existing supply and infrastructure within the SCE service area and would be consistent with growth expectations.59 Thus, SCE and LADWP consider growth from related projects within its service area for the increase in demand for electricity, as well as the need for energy infrastructure, such as new or expanded energy facilities.
Thus, although Project development would result in the use of renewable and non-renewable electricity resources during construction and operation, which could affect future availability, the Project’s use of such resources would be on a relatively small scale and would be reduced by measures rendering the Project more energy efficient. The Project would also incorporate additional energy efficiency measures, including LEED certification equivalent (refer to Project Design Feature GHG-PDF-1). Refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR for more information. Related projects, as with the Project, would be required to evaluate energy impacts during construction and operation related to the wasteful, inefficient or unnecessary use of electricity, incorporate energy conservation features, comply with applicable regulations including the Los Angeles Green Building Code, Los Angeles’ Green New Deal, Culver City’s Green Building Program, the Title 24 standards and CALGreen Building Code, and incorporate mitigation measures, as necessary under CEQA. Related projects, as with the Project, would also be required to evaluate potential impacts related to local and regional supplies or capacity based on regional growth plans, such as SCAG’s Connect SoCal, and SCE and LADWP energy supply projections for long-term planning. Each of the related projects would be reviewed by the local utility provider to identify necessary electricity service connections to meet the needs of their respective projects.
54 Los Angeles Department of Water and Power, 2017 Power Strategic Long-Term Resource Plan, December 2017, p. 70. 55 CEC, The California Energy Demand 2018–2030 Revised Forecast, 2018. 56 Los Angeles Department of Water and Power, 2017 Power Strategic Long-Term Resource Plan, December 2017, p.
ES-2.
57 Los Angeles Department of Water and Power, 2017 Power Strategic Long-Term Resource Plan, December 2017, p.
ES-2.
58 Los Angeles Department of Water and Power, 2017 Power Strategic Long-Term Resource Plan, December 2017, p. 67. 59 CEC, The California Energy Demand 2018–2030 Revised Forecast, 2018.
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In addition, the local utility provider would provide servic e letters (which take into account all current uses and projected future development projects) for each related project confirming availability of adequate electricity supplies and infrastructure as part of the total load growth of the regional power system.
Additionally, as discussed above, SCE and LADWP are required to procure 60 percent renewables by 2030 and 100 percent renewables by 2045 and are on track to hit their RPS targets. This represents the available off -site renewable sources of energy that could meet the Project’s and related projects energy demand. Therefore, the Project and related projects would comply with the energy conservation plans and efficiency standards required to ensure efficient energy use.
As such, the Project’s impact, when considered together with related projects, would not be cumulatively considerab le and would not result in cumulatively significant impacts related to wasteful, inefficient, or unnecessary use of electricity.
Natural Gas
Buildout of the Project, related projects, and additional forecasted growth in SoCalGas’ service area would cumulatively increase the demand for natural gas supplies and on infrastructure capacity. As stated above, based on the 202 2 California Gas Report, the CEC estimates natural gas consumption within SoCalGas’ planning area will be approximately 810,665 million cf in 2027 (the Project’s first full buildout year).
60 The Project would result in a net decrease in natural gas consumption. SoCalGas forecasts consider projected population growth and development based on local and regional plans, and the Project’s growth and development would not conflict with those projections. Additionally, as with the Project, each of the related projects w ould be reviewed by SoCalGas to identify necessary natural gas service connections to meet the needs of their respective projects, and SoCalGas would provide service letters for each related project confirming availability of adequate natural gas supplies as part of the total load growth of the regional natural gas system. Natural gas infrastructure is expanded and improved in response to increasing demand and it is expected that SoCalGas would continue to expand delivery capacity if necessary to meet growth requirements in the service area. Although Project development would result in the use of natural gas resources, which could limit future availability, the use of such resources would be on a relatively small scale, would be reduced by measures rendering the Project more energy -efficient, would be consistent with regional and local growth expectations for SoCalGas’ service area, and would not result in the need to construct new or expand existing natural gas facilities or distribution lines.
Related projects, as with the Project, would be required to evaluate natural gas impacts during construction and operation related to the wasteful, inefficient or unnecessary use of natural gas, incorporate energy conservation features, comply with applicable regulations including the Los Angeles Green Building Code, Los Angeles’ Green New Deal, Culver City’s Green Bu ilding Program, the Title 24 standards and CALGreen Building Code, and incorporate mitigation measures, as necessary under CEQA. As with the Project, related projects would also be required to obtain evidence of service from SoCalGas, or the appropriate utility provider, to ensure that
60 California Gas and Electric Utilities, 2022 California Gas Report, 2022, p. 186.
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natural gas service would be available and provided to meet related project demands. Furthermore, the related projects are generally infill projects in a highly urbanized area already served by existing facilities and are generally residential, mixed -use, and commercial projects and not high-energy demand facilities, such as heavy industrial uses.
As such, the Project’s contribution to cumulative impacts due to wasteful, inefficient and unnecessary use of natural gas would not be cumulatively considerable, and, thus, cumulative impacts would be less than significant.
Transportation Energy
Buildout of the Project, related projects, and additional forecasted growth would cumulatively increase the demand for transportation-related fuel in the state and region. As described above, at buildout, the Project would consume a total net increase of 103,593 gallons of gasoline and 16,882 gallons of diesel per year. For comparison purposes, the transportation-related fuel usage for the Project would represent between 0.0 03 percent of the 2022 annual on-road gasoline - and 0.004 percent of the annual on-road diesel-related energy consumption in Los Angeles County (based on the available County fuel sales data), as shown in Appendix E of this Draft EIR.
Additionally, as described above, petroleum currently accounts for 72 percent of California’s transportation energy sources;
61 however, over the last decade the State has implemented several policies, rules, and regulations to improve vehicle efficiency, increase the development and use of alternative fuels, reduce air pollutants and GHGs from the transportation sector, and reduce VMT, which would reduce reliance on petroleum fuels.
Construction of the Project and related projects would utilize fuel -efficient equipment consistent with State and federal regulations, such as fuel efficiency regulations in accordance with the CARB Pavley Phase II standards, the anti -idling regulation in accordance with Section 2485 in 13 CCR, and fuel requirements in accordance with 17 CCR Section 93115. The Project and related projects would benefit from fuel and automotive manufacturers’ compliance with CAFE standards, which would result in more efficient use of transportation fuels (lower consumption). As such, the Project and related projects would indirectly comply with regulatory measures to reduce the inefficient, wasteful, and unnecessary consumption of energy, such as petroleum-based transportation fuels.
As discussed previously, the Project would be consistent with and not conflict with SCAG’s land use type for the area and would encourage alternative transportation and a reduction in overall VMT. The Project Site is an infill location close to jobs, off-site housing, shopping, and entertainment uses and in close proximity to existing public transit stops, which would result in reduced VMT, as compared to a project of similar size and land uses at a location without close and walkable access to off-site destinations and public transit stops . Therefore, operation of the Project would provide visitors and employees with transportation options that would limit VMT and transportation fuel consumption, and would not result wasteful, and unnecessary consumption of energy, such as petroleum-based transportation fuels.
61 U.S. Energy Information Administration, California Energy Profile Overview, 2021, https://www.eia.gov/state/?sid=CA#tabs-1. Accessed July 11, 2022.
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Connect SoCal is a regional planning tool that addresses cumulative growth and resulting environmental effects and is applicable to the Project and related projects with respect to transportation energy efficiency. Related projects would be required under CEQA to evaluate if their respective developments would conflict with the energy efficiency policies emphasized by Connect SoCal, such as the per capita VMT targets, promotion of alternative forms of transportation, proximity to public transportation options, and provisions for encouraging multi - modal and energy efficient transit, such as by accommodating bicycle parking and EV chargers at or above regulatory requirements. Furthermore, as with the Project, the related projects would similarly be expected to reduce VMT by encouraging the use of alternative modes of transportation and other design features that promote VMT reductions that would not be in conflict with applicable provisions of SCAG’s Connect SoCal for the land use type. For more information on the Project’s consistency with SCAG’s Connect SoCal, refer to Section 4.6, Greenhouse Gas Emissions, of this Draft EIR.
Since the Project would not conflict with Connect SoCal , the Project’s contribution to cumulative impacts due to wasteful, inefficient or unnecessary use of transportation fuel would not be cumulatively considerable, and, thus, cumulative impacts would be less than significant.
Conclusion
Based on the analysis provided above, the Project’s contribution to cumulative impacts related to energy consumption (i.e., electricity, natural gas, and transportation energy) would not result in a cumulatively considerable effect related to potentially significant environmental impacts due to the wasteful, inefficient and unnecessary consumption of energy during construction or operation. As such, cumulative energy impacts under Threshold ENE-1 would be less than significant.
Consistency with State or Local Plan
Electricity
The Project would also incorporate energy and water efficiency measures outlined in Section 4.6, Greenhouse Gas Emissions, which include LEED Certified or equivalent (refer to Project Design Feature GHG-PDF -1). Related projects, as with the Project, would be required to evaluate electricity conservation features, comply with applicable electricity efficiency plans and standards, including Los Angeles’ Green Building Code, Culver City’s Green Building Program, the Title 24 standards and CALGreen Building Code, and incorporate mitigation measures, as necessary under CEQA. Related projects, as with the Project, would also be required to evaluate potential impacts related to consistency with the Los Angeles Green New Deal standards, and local and regional supplies or capacity based on regional growth plans, such as the SCE and LADWP energy supply projections for long-term planning.
As such, the Project’s contribution to cumulative impacts due to conflicting with or obstruction of a state or local plan for renewable energy or energy efficiency would not be cumulatively considerable, and, thus, cumulative impacts would be less than significant.
Natural Gas
Buildout of the Project, related projects, and additional forecasted growth in SoCalGas’ service area would cumulatively increase the demand for natural gas supplies and infrastructure capacity.
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However, as discussed above, SoCalGas forecasts take into account projected population growth and development based on local and regional plans, and the Project’s growth and development would not conflict with those projections.
Related projects, as with the Project, would be required to evaluate natural gas conservation features and compliance with applicable regulations, including the Los Angeles Green Building Code, Culver City’s Green Building Program, the Title 24 standards and CALGreen Building Code, and incorporate mitigation measures, as necessary under CEQA. Related projects, as with the Project, would also be required to evaluate potential impacts related to consistency with the Los Angeles Green New Deal standards, and local and regional supplies or capacity based on regional growth plans, such as the SoCalGas energy supply projections for long-term planning.
As such, the Project’s contribution to cumulative impacts due to conflicting with or obstruction of a state or local plan for renewable energy or energy efficiency would not be cumulatively considerable, and, thus, cumulative impacts would be less than significant.
Transportation Energy
Buildout of the Project, related projects, and additional forecasted growth would cumulatively increase the demand for transportation-related fuel in the state and region. However, as discussed above, the Project would not conflict with the energy efficiency policies emphasized by Connect SoCal. As discussed previously, the Project would be consistent with and not conflict with SCAG’s land use type for the area and would encourage alternative transportation and achieve a reduction in VMT compared to a standard non-infill project and based on its location near a diverse mix of land uses and public transit options.
Connect SoCal is a regional planning tool that addresses cumulative growth and resulting environmental effects and is applicable to the Project, and related projects with respect to transportation energy efficiency. Related projects would be required under CEQA to evaluate if their respective developments would conflict with the energy efficiency policies emphasized by Connect SoCal, such as the per capita VMT targets, promotion of alternative forms of transportation, proximity to public transportation options, and provisions for encouraging multi - modal and energy efficient transit, such as by accommodating bicycle parking and EV chargers at or above regulatory requirements. Furthermore, related projects would be required to implement mitigation measures, as needed, if found to be in conflict with applicable provisions of Connect SoCal for the land use type.
Since the Project would not conflict with Connect SoCal , the Project’s contribution to cumulative impacts related to potentially significant environmental impacts due to conflicting with or obstruction of a state or local plan for transportation energy efficiency would not be cumulatively considerable and, thus, would be less than significant.
Conclusion
Based on the analysis provided above, the Project’s contribution to cumulative impacts related to conflicting with or obstruction of a state or local plan for renewable energy or energy efficiency
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would not be cumulatively considerable; therefore, cumulative energy impacts under Threshold ENE-2 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 during construction and operation of the Project would be less than significant.
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4.5 Geology and Soils – Paleontological Resources
4.5.1 Introduction
This section evaluates potential impacts on paleontological 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 geology and soils, with the exception of paleontological resources.
The analysis provided in this section is based in part on the 5700 Hannum Mixed-Use Residential and Commercial Project, Culver City, California, Paleontological Resources Assessment Report, 1 included as Appendix F of this Draft EIR.
Paleontology is a branch of geology that studies the life forms of the past, especially prehistoric life forms, through plant and animal fossils. Paleontological resources represent a limited, non- renewable, and impact-sensitive scientific and educational resource. Fossil remains such as bones, teeth, shells, and leaves are found in the geologic deposits (rock formations) where they were originally buried. Paleontological resources include not only the actual fossil remains, but also the collecting localities, and the geologic formations containing those localities.
4.5.2 Environmental Setting
Regulatory Framework
State
California Environmental Quality Act
The California Environmental Quality Act (CEQA) Guidelines (Title 14, Chapter 3 of the California Code of Regulations [CCR], Section 15000 et seq .), define the procedures, types of activities, individuals, and public agencies required to comply with CEQA. As part of CEQA’s Initial Study process (CEQA Guidelines Section 15023, Appendix G, Section VII , Part f), one of the questions that the lead agency must answer relates to paleontological resources: “Would the project directly or indirectly destroy a unique paleontological resource or site or unique geologic feature?” If the answer is yes, the project reaches the CEQA threshold of significance for a significant impact to paleontological resources.
The loss of any identifiable fossil that could yield information important to prehistory, or that embodies the distinctive characteristics of a type of organism, environment, period of time, or geographic region, would be a significant environmental impact. Direct impacts to paleontological resources primarily concern the potential destruction of nonrenewable paleontological resources and the loss of information associated with these resources. This includes the unauthorized collection of fossil remains. If potentially fossiliferous bedrock or surficial sediments are disturbed, the disturbance could result in the destruction of paleontological resources and subsequent loss of information, which would be a significant impact.
1 Environmental Science Associates, 5700 Hannum Mixed-Use Residential and Commercial Project, Culver City, California, Paleontological Resources Assessment Report, Culver City, California, October 2023. Provided in Appendix F of this Draft EIR.
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The CEQA threshold of significance for a significant impact to paleontological resources is reached when it is determined that a project would “directly or indirectly destroy a significant paleontological resource or unique geologic feature.” In general, for project sites that are underlain by paleontologically sensitive geologic units
2, the greater the amount of ground disturbance, the
higher the potential for significant impacts to paleontological resources. For project sites that are directly underlain by geologic units with no paleontological sensitivity, there is no potential for impacts on paleontological resources unless sensitive geologic units which underlie the non- sensitive unit are also affected.
Public Resources Code Section 5097.5
Other State requirements for paleontological resource management are included in Public Resources Code (PRC) Section 5097.5. This statute prohibits the removal of any paleontological site or feature from public lands without permission of the jurisdictional agency, define s the removal of paleontological sites or features as a misdemeanor, and requires reasonable mitigation of adverse impacts to paleontological resources from developments on public (State, county, city, district) lands.
California Penal Code Section 622.5
California Penal Code Section 622.5 provides the following: “Every person, not the owner thereof, who willfully injures, disfigures, defaces, or destroys any object or thing of archeological or historical interest or value, whether situated on private land s or within any public park or place, is guilty of a misdemeanor.”
Local
City of Culver City General Plan
The City’s General Plan does not include policies, goals, and objectives for paleontological resources.
Society for Vertebrate Paleontology Standard Guidelines As discussed above, PRC Section 5097.5 and the California Environmental Quality Act Statute require protection of paleontological resources. The Society for Vertebrate Paleontology (SVP) has established standard guidelines that outline professional protocols and practices for conducting paleontological resource assessments and surveys, monitoring and mitigation, data and fossil recovery, sampling procedures, and specimen preparation, identification, analysis, and curation. 3 2 A geologic unit is a term that is used to describe a basic unit of rock measurement in geology. It is comprised of similar rock types created by associated depositional events and environments. 3 Society of Vertebrate Paleontology (SVP), Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010.
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The SVP guidelines are the industry standard. As defined by the SVP, significant nonrenewable paleontological resources are: 4
Fossils and fossiliferous deposits here are restricted to vertebrate fossils and their taphonomic and associated environmental indicators. This definition excludes invertebrate or paleobotanical fossils except when present within a given vertebrate assemblage. Certain invertebrate and plant fossils may be defined as significant by a project paleontologist, local paleontologist, specialists, or special interest groups, or by lead agencies or local governments.
As defined by the SVP, significant fossiliferous deposits are:
5 A rock unit or formation which contains significant nonrenewable paleontologic resources, here defined as comprising one or more identifiable vertebrate fossils, large or small, and any associated invertebrate and plant fossils, traces, and other data that provide taphonomic, taxonomic, phylogenetic, ecologic, and stratigraphic information (ichnites and trace fossils generated by vertebrate animals, e.g., trackways, or nests and middens which provide datable material and climatic information). Palaeontologic resources are considered to be older than recorded history and/or older than 5,000 years BP [before present].
Based on the significance definitions of the SVP, all identifiable vertebrate fossils are considered to have significant scientific value.
6 This standard is used because vertebrate fossils are relatively uncommon, and only rarely will a fossil locality yield a statistically significant number of specimens of the same genus. Therefore, every vertebrate fossil found has the potential to provide significant new information on the taxon it represents, its paleoenvironment, and/or its distribution.
Furthermore, all geologic units in which vertebrate fossils have previously been found are considered to have high sensitivity. Identifiable plant and invertebrate fossils ar e considered significant if found in association with vertebrate fossils or if defined as significant by project paleontologists, specialists, or local government agencies.
Existing Conditions
Regional Geology
The Project Site is situated in the northern portion of the Los Angeles Basin (Basin), a structural depression approximately 50 miles long and 20 miles wide. 7,8 The Basin is located within the
Transverse Ranges, a physiographic-structural province that includes a series of east-west trending mountains and valleys that interrupt the northwest -southeast orientation of other major California ranges, including the Peninsular Ranges, Coast Ranges, and the Sierra Nevada. The Basin is
4 SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines, Society of Vertebrate Paleontology News Bulletin 163:22–27, 1995. 5 SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines, Society of Vertebrate Paleontology News Bulletin 163:22–27, 1995. 6 SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines, Society of Vertebrate Paleontology News Bulletin 163:22–27, 1995. 7 Yerkes, R. F., T. H. McCulloh, J. E. Schollhamer, and J. G. Vedder, Geology of the Los Angeles Basin – an introduction. Geological Survey Professional Paper 420-A, 1965. 8 Ingersoll, R. V. and P. E. Rumelhart, Three-stage basin evolution of the Los Angeles basin, southern California.
Geology 27: 593-596, 1999.
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bounded on the north by the Santa Monica Mountains, the Elysian Hills, Repetto Hills, and Puente Hills and on the east, and by the Santa Ana Mountains and San Joaquin Hills to the southeast. The Basin formed between 3 and 18 million years ago as a result of tectonic subsidence. 9 Continuous sedimentation into the Basin began during the middle Miocene Epoch around 13 million years ago as thousands of feet of sediments were deposited in a marine environment .10 Deposition of terrestrial alluvial sediments commenced during the Pleistocene Epoch approximately 2.6 million years ago and ended 11,700 years ago .
More specifically, t he Project Site lies on the southwest slope of the Baldwin Hills , which are situated near the south edge of the Los Angeles Basin. The area where the Baldwin Hills recently formed was a marine habitat as late as 36,200 and 28,450 radiocarbon years ago. 11 The subsequent
uplift of the Baldwin Hills is the result of tension along the Newport – Inglewood fault. Several smaller uplifts (e.g., Signal Hill, Rosecrans Hills, and Dominguez Hills) also resulted from tension along this fault. Both the San Pedro and Lakewood formations are exposed in the Baldwin Hills.
Site Geology and Literature Review
There is disagreement between geologists over the geologic conditions at the Project Site . For example, according to a 1959 review from Poland et al.12 the Project Site geology is the San Pedro Sand Formation, a nearshore marine deposit. However, Dibblee and Minch 13 mapped the Project Site in 2007—the most recent g eologic mapping including the Project Site — as Qop (Fox Hills paleosol), Qoa (Late Pleistocene alluvium) and Qa (Holocene- age alluvium ). Qa is surficial alluvium of Holocene age that implies clasts of Santa Monica Slate from the Santa Monica Mountains are present. These clasts would have been transported down the coast before the uplift of the Baldwin Hills more than 28,000 calendar years ago and then reworked into Holocene alluvium. The Qa has a low sensitivity for paleontological r esources due to the young age of the deposits. Qoa and the Qop are likely from the late Pleistocene.14. If the Fox Hills paleosol15 is of late Pleistocene age, it would have been developed between the latest date for marine sediments 28,000 calendar years ago and the end of the Pleistocene Epoch 11,500 calendar years ago. The Qoa has a high sensitivity for paleontological resources given its age. The authors who named the Fox Hills paleosol16 never stated whether they believed it was of Pleistocene or Holocene age.
9 Critelli, S. P. Rumelhart, and R. Ingersoll, Petrofacies and provenance of the Puente Formation (middle to upper Miocene), Los Angeles Basin, southern California: implications for rapid uplift and accumulation rates. Journal of Sedimentary Research A65: 656-667, 1995.
10 Yerkes, R. F., T. H. McCulloh, J. E. Schollhamer, and J. G. Vedder, Geology of the Los Angeles Basin – an introduction. Geological Survey Professional Paper 420-A, 1965. 11 Bandy, O. L., and L. Marincovich, Jr. 1973. Rates of late Cenozoic Uplift, Baldwin Hills, Los Angeles, California.
Science 181:653-655.
12 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. 13 Dibblee and Minch. 2007. Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 14 Dibblee and Minch. 2007. Geologic map of the Venice and Inglewood Quadrangles, Los Angeles County, California. Dibblee Foundation Map DF-322. Scale 1:24000 15 Paleosol is an ancient soil that formed in the past 16 Hsu, E.Y., R. B. Saul, S. S. Tan, J. Treiman, and F. H. Weber, Jr. 1982. Slope Stability and Geology of the Baldwin Hills, Los Angeles County, California. California Department of Conservation Division of Mines and Geology Special Report 152:1-93. Scale 1:48,000.
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Pleistocene sediments in particular have a rich fossil history in Southern California and especially the Los Angeles Basin. The most common terrestrial fossils include the bones of mammoth, bison, horse, wolf, camel, antelope, and giant ground sloth, as well as small animals such as rodents, birds, and lizards.
17,18,19,20 The most common marine fossils are various types of mollusks, with occasional bony fish and shark elements (isolated teeth). Terrestrial organisms are sometimes found in Los Angeles Basin Pleistocene marine sediments, documenting animals that washed out to sea.
In connection with the Project, Geotechnologies, Inc.
21 reproduced the mapping of Poland et al.22,
and describe the soils in the northern portion of the Project Site as marine terrace deposits, which could be compatible with the San Pedro Sand Formation. Geotechnologies, Inc. encountered fill materials down to depths of one and three feet below ground surface (bgs), followed by marine terrace deposits then bedrock (siltstone).
23 Based on a literature review and the Geotechnologies, Inc. study, the northwestern corner of the Project Site might host sediments of the Baldwin Hills paleosol (also known as the Fox Hills paleosol)24, which is thought to be of latest Pleistocene age.
The Baldwin Hills paleosol within the Project Site is here assigned a high sensitivity for paleontological resources as it is a paleosol. Beneath the Baldwin Hills paleosol is the older Quaternary alluvium.
Pleistocene deposits in Culver City west of the Baldwin Hills have produced many Pleistocene vertebrate and invertebrate fossils. For instance, i n 2016, paleontological resources monitoring was conducted for a construction project in the immediate vicinity of the Project Site. There, 78 fossil specimens were collected at this project from sediments at 28 to 29 feet below street level, both in situ and from spoil piles excavated at that level. 25 The taxa represented by the collected
fossils range from mammal (Camelops hesternus) and plant (Pinus sp.) remains, to a large number of mollusks (Bivalvia and Gastropoda). Similarly, from 2017 to 2018, paleontological resources
17 Graham, R.W., and E.L. Lundelius. 1994. FAUNMAP: A database documenting the late Quaternary distributions of mammal species in the United States. Illinois State Museum Scientific Papers XXV(1). 18 Jefferson, G.T. 1991a. A catalogue of Late Quaternary Vertebrates from California: Part One, nonmarine lower vertebrate and avian taxa. Natural History Museum of Los Angeles County Technical Reports No. 5. 19 Jefferson, G.T. 1991b. A catalogue of Late Quaternary Vertebrates from California: Part Two, Mammals. Natural History Museum of Los Angeles County Technical Reports No. 7. 20 Miller, W. E. 1971. Pleistocene Vertebrates of the Los Angeles Basin and Vicinity: exclusive of Rancho La Brea.
Los Angeles County Museum of Natural History, No. 10.
21 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.
22 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. 23 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.
24 Hsu, E.Y., R. B. Saul, S. S. Tan, J. Treiman, and F. H. Weber, Jr. 1982. Slope Stability and Geology of the Baldwin Hills, Los Angeles County, California. California Department of Conservation Division of Mines and Geology Special Report 152:1-93. Scale 1:48,000.
25 SWCA Environmental Consultants. 2016. Final Paleontological Resources Monitoring and Mitigation Report for the Washington National Project, Culver City, Los Angeles County, California. Prepared for: Greystar, 2615 Pacific Coast Highway, Suite 208, Hermosa Beach, CA 90254. Prepared by: SWCA Environmental consultants, 150 South Arroyo Parkway, Second Floor, Pasadena, CA 91105.
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monitoring was conducted for a project located at Ivy Station in Culver City . The monitoring yielded several paleontological specimens (gastropod and bivalve shells) at depths of 25 to 41 feet bgs that extended past the artificial fill throughout the entire property .26 In 2018, paleontological resources monitoring was conducted for another project near the intersection of National Boulevard and Washington Boulevard. The paleontological resource mitigation efforts there produced approximately 100 specimens consisting of marine mammal (otariid, and cetacean), terrestrial vertebrates (Bison, rodents, rabbits, amphibians and snakes), invertebrate, and plant fossils.
27 Finally, in 2019, ESA monitored construction activity for Culver Studios in Culver City.
Fossils of Bison, Camelops, Smilodon (saber-toothed cat), and Paramylodon (ground sloth) were found there.28
National History Museum of Los Angeles County (NHMLAC) Records Search Paleontological records from the NHMLAC also indicate that older Pleistocene-age geologic units in the vicinity of the Project Site, from immediately north of the Project Site to approximately 2.8 miles away at depths up to 40 feet bgs , have produced a variety of paleontological resources from the Pleistocene.
Specifically, NHMLAC records indicate that one group of fossil localities (LACM IP 42395 – 42408) are located in close proximity to the Project Site, which yielded fossil specimens of sponge trace fossils (Entobia), oysters ( Ostrea), scallops (Leptopecten, Chlamys), and other unsorted invertebrates from approximately 2 feet bgs to 10 feet bgs. Additional fossil localities (LACM IP 23224, LACM VP 4942, LACM VP 3789, LACM VP 7332, LACM VP 1170) exist nearby from the same sedimentary deposits that occur in the Project Site, either at the surface or at depth. LACM IP 23224 is located approximately 0.85 miles away from the Project Site and yielded specimens of cerith, dove snail, nutclam, wentletrap, bivalve, slipper shell, top snail, scallop, jewel boxes, horn snail, cardita, hatchet shell, venus clam, and tower shell at unknown depths. LACM 4942 located approximately 1.85 miles away the Project Site produced specimens of mammoth, bison, and hare at 16 feet bgs. LACM 3789 situated approximately 2 miles away from the Project Site yielded a specimen of mammoth at 14 feet bgs. LACM VP 7332 located approximately 2.80 miles away from the Project Site yielded a fossil specimen of mammot h at 40 feet bgs. Finally, LACM VP 1170 located approximately 2.15 miles away from the Project Site produced fossil specimens of sloth, camel, weasel, bison, deer, sabertooth cat, pronghorn antelope, mastodon, peccary, horse, coot, and unidentified birds at unknown depths.
29 26 ESA. 2018. Ivy Station Project, City of Culver City and City of Los Angeles, County of Los Angeles California:
Archaeological and Paleontological Monitoring Report. Prepared for: Culver City Triangle Investor, Inc., c/o Lowe Enterprises Real Estate Group, 8740 Washington Boulevard, Suite A, Culver City, CA 90232. Prepared by: ESA. 27 ESA. 2021. 8777 Washington Project; Culver City, County of Los Angeles, California: Archaeological and Paleontological Monitoring Report. Prepared for: CLPF-8777 Washington, L.P., 3129-B S La Cienega Blvd., Los Angeles, CA 90016. Prepared by: ESA.
28 ESA. In prep. Culver Studios Project: Culver City, County of Los Angeles, California: Paleontological Monitoring Report. Prepared by: ESA.
29 Bell, Alyssa. 2023. Paleontological resources for the 5700 Hannum Project. Prepared for Environmental Science Associates by the Natural History Museum of Los Angeles County. 2 p.
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4.5.3 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 paleontological resources if it would:
• GEO-1: Directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
Potentially significant impacts related to paleontological resources 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:
• Directly or indirectly cause potential substantial adverse effects, including the risk of loss, injury, or death involving:
– Rupture of a known earthquake fault, as delineated on the most recent Alquist -Priolo Earthquake Fault Zoning Map issued by the State Geologist for the area or based on other substantial evidence of a known fault? Refer to Division of Mines and Geology Spec ial Publication 42.
– Strong seismic ground shaking?
– Seismic-related ground failure, including liquefaction? – Landslides?
• Result in substantial soil erosion or the loss of topsoil? • Be located on a geologic unit or soil that is unstable, or that would become unstable as a result of the Project, and potentially result in on or off site landslide, lateral spreading, subsidence, liquefaction or collapse?
• Be located on expansive soil, as defined in Table 18-1-B of the Uniform Building Code (1994), creating substantial direct or indirect risks to life or property? • Have soils incapable of adequately supporting the use of septic tanks or alternative waste water disposal systems where sewers are not available for the disposal of waste water? As detailed in the Initial Study, the Project Site is generally stable from a geologic perspective. The Project would be required to comply with applicable seismic -related regulatory requirements. In addition, a final design-level geotechnical report must ultimately be prepared and approved by the City prior to issuance of building permits, and would be based on the final construction and building plans prepared by the Applicant. Implementation of the site -specific structural and seismic design parameters and recommendations of the final design- level geotechnical report would ensure that geologic hazards impacts would be less than significant.
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Methodology
The paleontological resources analysis is based in part on a review of fossil, soil and rock inventories compiled, synthesized, and evaluated by the staff of the Vertebrate Paleontology Section of the NHMLAC. The objective of the NHMLAC records search was to determine the geological formations underlying the Project Site, whether any paleontological localities have previously been identified within the Project Site or in the same or similar formations near the Project Site, and the potential for excavations associated with the Project Site to encounter paleontological resources. These methods are consistent with the SVP guidelines for assessing the importance of paleontological resources in areas of potential environmental effect.
The potential to encounter paleontological resources during construction at the Project Site was also determined by reviewing the results of the NHMLAC records search, the geotechnical report for the Project, review of geologic maps that encompass the Project Site, pertinent literature of the surrounding vicinity, and the proposed excavation parameters for the Project. Because the Project Site is entirely developed and lacks any visible native ground surface or potential for surface exposure of resources, a paleontological field survey was not undertaken.
Professional Standards and Guidelines
The SVP has established standard guidelines 30,31 that outline professional protocols and practices for conducting paleontological resource assessments and surveys, monitoring and mitigation, data and fossil recovery, sampling procedures, and specimen preparation, identification, analysis, and curation. Most practicing professional vertebrate paleontologists adhere closely to the SVP’s assessment, mitigation, and monitoring requirements as specifically provided in its standard guidelines. Most state regulatory agencies, including California , with paleontological resource- specific laws, ordinances, regulations, and standards accept and use the professional standards set forth by the SVP.
A geologic unit known to contain significant fossils is considered “sensitive” to adverse impacts if there is a high probability that earth -moving or ground-disturbing activities will either directly or indirectly disturb or destroy fossil remains. Paleontological sites indicate that the containing sedimentary rock unit or formation is fossiliferous. The limits of the entire rock formation, both areal and stratigraphic, therefore define the scope of the paleontological potential in each case. 32 Fossils are contained within surficial sediments or bedrock, and are therefore not observable or detectable unless exposed by erosion or human activity. In summary, paleontologists cannot know either the quality or quantity of fossils prior to natural eros ion or human-caused exposure. As a result, even in the absence of surface fossils, it is necessary to assess the sensitivity of rock units based on their known potential to produce significant fossils elsewhere within the same geologic unit (both within and outside of the study area), a similar geologic unit, or based on whether the
30 SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines.
Society of Vertebrate Paleontology News Bulletin 163:22-27, 1995. 31 SVP, Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010, http://vertpaleo.org/Membership/Member-Ethics/SVP_Impact_Mitigation_Guidelines.aspx Accessed October 23, 2020. 32 SVP, Assessment and mitigation of adverse impacts to nonrenewable paleontologic resources: standard guidelines.
Society of Vertebrate Paleontology News Bulletin 163:22-27, 1995.
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unit in question was deposited in a type of environment that is known to be favorable for fossil preservation. Monitoring by experienced paleontologists greatly increases the probability that fossils will be discovered during ground-disturbing activities a nd that, if these remains are significant, successful mitigation and salvage efforts may be undertaken in order to prevent adverse impacts to these resources.
Paleontological Sensitivity
Paleontological sensitivity is defined as the potential for a geologic unit to produce scientifically significant fossils. This is determined by rock type, past history of the geologic unit in producing significant fossils, and fossil localities recorded from that unit. Paleontological sensitivity is derived from the known fossil data collected from the entire geologic unit, not just from a specific survey.
In its “Standard Guidelines for the Assessment and Mitigation of Adverse Impacts to Non - renewable Paleontologic Resources,” the SVP
33 defines four categories of paleontological
sensitivity, or potential, for rock units: high, low, undetermined, and no potential:
• High Potential. Rock units from which vertebrate or significant invertebrate, plant, or trace fossils have been recovered are considered to have a high potential for containing additional significant paleontological resources. Rocks units classified as having high potenti al for producing paleontological resources include, but are not limited to, sedimentary formations and some volcaniclastic formations (e. g., ashes or tephras), and some low-grade metamorphic rocks which contain significant paleontological resources anywhere within their geographical extent, and sedimentary rock units temporally or lithologically suitable for the preservation of fossils (e. g., middle Holocene and older, fine-grained fluvial sandstones, argillaceous and carbonate- rich paleosols, cross-bedded point bar sandstones, fine-grained marine sandstones, etc.). • Low Potential. Reports in the paleontological literature or field surveys by a qualified professional paleontologist may allow determination that some rock units have low potential for yielding significant fossils. Such rock units will be poorly represented by fossil specimens in institutional collections, or based on general scientific consensus only preserve fossils in rare circumstances and the presence of fossils is the exception not the rule, e. g. basalt flows or Recent colluvium. Rock units with low potential typically will not require impact m itigation measures to protect fossils.
• Undetermined Potential. Rock units for which little information is available concerning their paleontological content, geologic age, and depositional environment are considered to have undetermined potential. Further study is necessary to determine if these rock units have high or low potential to contain significant paleontological resources. A field survey by a qualified professional paleontologist to specifically determine the paleontological resource potential of these rock units is required before a paleontological resource impact mitigation program can be developed. In cases where no subsurface data are available, paleontological potential can sometimes be determined by strategically located excavations into subsurface stratigraphy. • No Potential. Some rock units have no potential to contain significant paleontological resources, for instance high -grade metamorphic rocks (such as gneisses and schists) and plutonic igneous rocks (such as granites and diorites). Rock units with no potential require no protection nor impact mitigation measures relative to paleontological resources.
33 SVP, Standard procedures for the assessment and mitigation of adverse impacts to paleontological resources, 2010, http://vertpaleo.org/Membership/Member-Ethics/SVP_Impact_Mitigation_Guidelines.aspx Accessed October 23, 2020.
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In accordance with the SVP guidelines, full-time monitoring of geologic units with high potential is generally recommended during any project -related ground disturbance. For geologic units with low potential, protection or salvage efforts will not generally be required. For geologic units with undetermined potential, field surveys by a qualified vertebrate paleontologist should be conducted to specifically determine the paleontologic potential of the rock units present within the study area.
Paleontological Resources Significance Criteria
Fossils are considered to be significant if one or more of the following criteria apply:34
1. The fossils provide information on the evolutionary relationships and developmental trends among organisms, living or extinct;
2. The fossils provide data useful in determining the age(s) of the rock unit or sedimentary stratum, including data important in determining the depositional history of the region and the timing of geologic events therein;
3. The fossils provide data regarding the development of biological communities or interaction between paleobotanical and paleozoological biotas;
4. The fossils demonstrate unusual or spectacular circumstances in the history of life; or
5. The fossils are in short supply and/or in danger of being depleted or destroyed by the elements, vandalism, or commercial exploitation, and are not found in other geographic locations.
Significant paleontological resources are determined to be fossils or assemblages of fossils that are unique, unusual, rare, uncommon, or diagnostically important. Significant fossils can include remains of large to very small aquatic and terrestrial vertebrates or remains of plants and animals previously not represented in certain portions of the stratigraphy. Assemblages of fossils that might aid stratigraphic correlation, particularly those offering data for the interpretation of tectonic events, geomorphologic evolution, and paleoclimatology are also critically important. 35 Project Design Features
There are no Project Design Features associated with paleontological resources.
Analysis of Project Impacts
Threshold GEO-1: The Project could have a significant impact if it would directly or indirectly destroy a unique paleontological resource or site or unique geologic feature.
Impact Analysis
Given the Project is in an urban developed location, there are no unique geologic features , and unique geologic features are not discussed further. 36 Analysis regarding the potential for unique paleontological resources are discussed further below.
34 Scott, E. and K. Springer, CEQA and Fossil Preservation in California. The Environmental Monitor, 2003. 35 Scott, E. and K. Springer, CEQA and Fossil Preservation in California. The Environmental Monitor, 2003. 36 Unique geologic features are typically topographic features such as hilltops, ridges, hillslopes, canyons, ravines, rock outcrops, water bodies, streambeds, or wetlands.
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As indicated previously, the Project Site is completely developed with surface parking and a two- story office building with no visible soil/sediment or rock outcrops to examine for paleontological resources or fossiliferous geological formations. Although the Project Site has been previously developed, g eologic mapping indicates that the surface of the Project Site is underlain by Pleistocene-age older alluvium (Qoa) , Holocene-age alluvium (Qa), and possibly by the Pleistocene-age Baldwin Hills Paleosol (Qop), also known as the Fox Hills Paleosol . The Pleistocene alluvium , Qoa, has a high potential and produced a significant number of marine invertebrate fossils, and it is probable that these same deposits will produce significant paleontological resources fossils on the Project Site. The Holocene alluvium, Qa, is assigned a low potential to contain paleontological resources given its young age. The Baldwin Hills Paleosol, Qop, has a high potential because the SVP Guidelines (2010) specifically call out paleo sols as sensitive, although no reports were located that address paleontological resources in the paleosol.
Since excavations at the Project Site are estimated to reach depths of up to 27 feet bgs, which is likely deeper than previous excavations on the Project Site, they have the potential to impact older alluvium and possibly the Baldwin Paleosol , which have a high sensitivity for retaining paleontological resources as discussed above. Therefore, impacts on paleontological resources due to grading and excavation during construction are considered potentially significant.
Operation of the new facilities 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 paleontological resources after construction is complete. No operational impacts would thus occur.
Mitigation Measures
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 it relates to paleontological resources, shall attend the Project kick-off meeting, and shall be responsible for 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 remains 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 fr om 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 inspect ions 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 excavation 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 w here construction activities shall not be allowed to
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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.
Level of Significance After Mitigation
With implementation of Mitigation Measures GEO-1 to GEO-4, potentially significant impacts to paleontological resources during construction activities would be reduced to a less-than-significant level.
Cumulative Impacts
The Project is required to comply with Mitigation Measures GEO-1 through GEO-4, thus ensuring proper identification, treatment and preservation of any resources that are encountered during excavation, which would reduce the potential for significant impact s on paleontological resources to less than significant levels. These measures require construction monitoring of excavation activities and treatment and curation of discoveries, if encountered.
Some of the related projects identified in Chapter 3, Environmental Setting, could require excavation at depths that could potentially expose or damage paleontological resources. However, related projects that involve substantial excavation with the potential to encounter buried or subsurface paleontological resources during construction, are expected to be subject to mitigation measures to mitigate impacts on paleontological resources through construction m onitoring programs and treatment and curation requirements for discovered fossils, similar to the Project.
With implementation of such mitigation measures, cumulative impacts from related projects are considered less than significant. Therefore, as impacts on paleontological resources from related projects would be less than significant with implementation of mitigation measures , and as the Project would mitigate its potential impacts to paleontological resources to a less than significant level, cumulative impacts would be less than significant.
Mitigation Measures
Refer to Mitigation Measures GEO-1 to GEO-4. No additional mitigation measures are required.
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Level of Significance After Mitigation
With implementation of Mitigation Measures GEO-1 to GEO -4, cumulative impacts to paleontological resources would be less than significant.
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4.6 Greenhouse Gas Emissions
4.6.1 Introduction
This section compares the Project’s characteristics with applicable regulations, plans, and policies set forth by the State of California, South Coast Air Quality Management District (SCAQMD), the Southern California Association of Governments (SCAG), and the City of Culver City to reduce greenhouse gas (GHG) emissions to determine whether the Project is consistent with and/or would conflict with the provisions of these plans. To assist in analyzing the Project’s potential to conflict with applicable regulations, plans and policies, this section also estimates the Project’s GHG emissions generated by Project construction and operations, takin g into account mandatory and voluntary energy and resource conservation measures that have been incorporated into the Project to reduce GHG emissions. Details regarding the GHG analysis are provided in Appendix C of this Draft EIR.
4.6.2 Environmental Setting
Regulatory Framework
Federal
Federal Clean Air Act
The United States Environmental Protection Agency ( USEPA) is responsible for implementing federal policy to address GHGs. The United States Supreme Court (Supreme Court) ruled in Massachusetts v. Environmental Protection Agency, 127 S.Ct. 1438 (2007), that carbon dioxide (CO
2) and other GHGs are pollutants under the Federal Clean Air Act (CAA), which the USEPA must regulate if it determines they pose an endangerment to public health or welfare. In December 2009, USEPA issued an endangerment finding for GHGs under the CAA, setting the stage for future regulation.
The Federal Government administers a wide array of public-private partnerships to reduce the GHG intensity generated in the United States. These programs focus on energy efficiency, renewable energy, CH
4 and other non-CO2 gases, agricultural practices, and implementation of technologies to achieve GHG reductions. USEPA implements numerous voluntary programs that contribute to the reduction of GHG emissions. These programs (e.g., the ENERGY STAR labeling system for energy-efficient products) play a significant role in encouraging voluntary reductions from large corporations, consumers, industrial and commercial buildings, and many major industrial sectors.
Corporate Average Fuel Economy Standards
In response to the Massachusetts v. Environmental Protection Agency ruling, President George W.
Bush issued Executive Order 13432 in 2007, directing the USEPA, the U.S. Department of Transportation (USDOT), and the U.S. Department of Energy to establish regulations that reduce GHG emissions from motor vehicles, non -road vehicles, and non -road engines by 2008. The National Highway Traffic Safety Administration (NHTSA) subsequently issued multiple final rules regulating fuel efficiency for, and GHG emissions from, cars and light -duty trucks for model year 2011 and later for model years 2012– 2016 and 2017 –2021. In March 2020, the USDOT and the USEPA issued the final Safer Affordable Fuel-Efficient (SAFE) Vehicles Rule, which amends
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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. 1 These standards set a combined fleet wide average of 36.9 to 37 for the model years affected.2 In February 2022, the USEPA issued the Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards. 3 This final rule revises current GHG standards beginning for vehicles in model year 2023 and through model year 2026 and establishes 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.
4 In addition to the regulations applicable to cars and light -duty trucks described above, in 2011 the USEPA and NHTSA announced fuel economy and GHG standards for medium - and heavy-duty trucks for model years 2014– 2018. The standards for CO 2 emissions and fuel consumption are tailored to three main vehicle categories: combination tractors, heavy-duty pickup trucks and vans, and vocational vehicles. According to the 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, the 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.5
Energy Independence and Security Act
The Energy Independence and Security Act of 2007 (EISA) facilitates the reduction of national GHG emissions by requiring the following:
• Increasing the supply of alternative fuel sources by setting a mandatory Renewable Fuel Standard 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 USEPA and NHTSA actions described above, (i) establishing miles per gallon targets for cars and light trucks and (ii) directing the NHTSA to establish a fuel
1 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. 2 National Highway Traffic Safety Administration (NHTSA), Corporate Average Fuel Economy standards. 3 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. 4 USEPA, Revised 2023 and Later Model Year Light-Duty Vehicle Greenhouse Gas Emissions Standards:
Regulatory Update, December 2021.
5 USEPA, EPA and NHTSA Adopt Standards to Reduce GHG and Improve Fuel Efficiency of Medium- and Heavy- Duty Vehicles for Model Year 2018 and Beyond, August 2016.
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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.”
6 State
California Air Resources Board
The California Air Resources Board ( CARB), a part of the California Environmental Protection Agency (CalEPA), is responsible for the coordination and administration of both federal and State air pollution control programs within California. In this capacity, CARB conducts research, sets the California Ambient Air Quality Standards, 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 (such as hairspray, aerosol paints, and barbecue lighter fluid), and various types of commercial equipment. It also sets fuel specifications to further reduce vehicular emissions. CARB has primary responsibility for the development of California’s State Implementation Plan (SIP), for which it works closely with the federal government and the local air districts. The SIP is required for the State to take over implementation of the Federal CAA. CARB also has primary responsibility fo r adopting regulations to meet the State’s goal of reducing GHG emissions. The State has met its goals to reduce GHG emissions to 1990 levels by 2020. Subsequent State goals include reducing GHG emissions to 40 percent below 1990 levels by 2030 and to 80 percent below 1990 levels by 2050.
California Greenhouse Gas Reduction Targets
Executive Order S- 3-05
Governor Arnold Schwarzenegger announced on June 1, 2005, through Executive Order S -3-05, the following GHG emission reduction targets:
• By 2010, California shall reduce GHG emissions to 2000 levels; • By 2020, California shall reduce GHG emissions to 1990 levels; and • By 2050, California shall reduce GHG emissions to 80 percent below 1990 levels.
In accordance with Executive Order S-3-05, the Secretary of CalEPA is required to coordinate efforts of various agencies, which comprise the California Climate Action Team (CAT), in order to collectively and efficiently reduce GHGs. The CAT provides periodic reports to the Governor and Legislature on the state of GHG reductions in the State as well as strategies for mitigating and adapting to climate change.
The CAT stated that smart land use is an umbrella term for strategies that integrate transportation and land-use decisions. Such strategies generally encourage jobs/housing proximity, promote transit-oriented development (TOD), and encourage high -density r esidential/commercial development along transit corridors. These strategies develop more efficient land-use patterns
6 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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within each jurisdiction or region to match population increases, workforce, and socioeconomic needs for the full spectrum of the population.
Executive Order B-30-15
On April 29, 2015, Governor Brown issued Executive Order B -30-15. Therein, the Governor directed the following:
• Established a new interim statewide reduction target to reduce GHG emissions to 40 percent below 1990 levels by 2030.
• Ordered all State agencies with jurisdiction over sources of GHG emissions to implement measures to achieve reductions of GHG emissions to meet the 2030 and 2050 reduction targets. • Directed CARB to update the Climate Change Scoping Plan to express the 2030 target in terms of million metric tons (MMT) of CO
2e.
Executive Order B-55-18
Executive Order B -55-18, issued by Governor Brown in September 2018, establishes a new statewide goal to achieve carbon neutrality as soon as possible, but no later than 2045, and achieve and maintain net negative emissions thereafter. Based on this executive order, CARB would work with relevant State agencies to develop a framework for implementation and accounting that tracks progress towards this goal as well as ensuring future scoping plans identify and recommend measures to achieve the carbon neutrality goal.
In October 2020, CARB released a study, which evaluated three scenarios that achieve carbon neutrality in California by 2045. The scenarios analyzed to achieve carbon neutrality include a High Carbon Dioxide Removal (CDR) scenario, Zero Carbon Energy scenario, and a Balanced scenario.
The High CDR scenario achieves GHG reductions by relying on CO 2 removal strategies. The Zero
Carbon Energy scenario is based on the assumption of zero -fossil fuel emissions by 2045. The Balanced scenario represents a middle po int between the High CDR scenario and Zero Carbon Energy scenario. The scenarios would achieve at least an 80 percent reduction in GHGs by 2045, relative to 1990 levels. Remaining CO 2 would be reduced to zero by applying CO 2 removal strategies, including sinks from natural and working lands and negative emissions technologies, such as direct air capture.
7,8
Under each of these scenarios, CARB proposed reduction strategies for various sectors that contribute GHG emissions throughout the State. Although specific details are not yet available for the GHG reduction measures discussed above, implementation of these measures would require regulations to be enforced by the State.
California Global Warming Solutions Act of 2006 (Assembly Bill 32) In 2006, the California State Legislature adopted Assembly Bill (AB) 32 (codified in the California Health and Safety Code (HSC), Division 25.5 – California Global Warming Solutions Act of 2006),
7 Sinks are defined as natural or artificial reservoirs that accumulate and store a carbon-containing chemical compound for an indefinite period.
8 Energy+Environmental Economics (E3), Achieving Carbon Neutrality in California, PATHWAYS Scenarios Developed for the California Air Resources Board, October 2020, p. 22.
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which focuses on reducing GHG emissions in California to 1990 levels by 2020. HSC Division 25.5 represents the first enforceable statewide program to limit emissions of these GHGs from all major industries, with penalties for noncompliance. The law further requires that reduction measures be technologically feasible and cost effective. Under HSC Division 25.5, CARB has the primary responsibility for reducing GHG emissions. CARB is required to adopt rules and regulations directing State actions that would achieve GHG emissions reductions.
In 2016, the California State Legislature adopted Senate Bill (SB) 32 and its companion bill AB 197, and both were signed by Governor Brown. SB 32 and AB 197 amend HSC Division
25.5, establish a new climate pollution reduction target of 40 percent below 19 90 levels by 2030 and include provisions to ensure that the benefits of State climate policies reach disadvantaged communities. The new goals outlined in SB 32 update the Climate Change Scoping Plan requirement of AB 32 and involve increasing renewable energy use, imposing tighter limits on the carbon content of gasoline and diesel fuel, putting more electric cars on the road, improving energy efficiency, and curbing emissions from key industries.
AB 197, signed September 8, 2016, is a bill linked to SB 32 and prioritizes efforts to cut GHG emissions in low-income or minority communities. AB 197 requires CARB to make available, and update at least annually, on its website the emissions of GHGs, crit eria pollutants, and toxic air contaminants for each facility that reports to CARB and air districts. In addition, AB 197 adds two Members of the Legislature to the CARB board as ex officio, non-voting members and creates the Joint Legislative Committee on Climate Change Policies to ascertain facts and make recommendations to the Legislature and the houses of the Legislature concerning the State’s programs, policies, and investments related to climate change.
Climate Change Scoping Plan
AB 32 required CARB to prepare a Climate Change Scoping Plan for achieving the maximum technologically feasible and cost -effective GHG emission reduction by 2020 (HSC Section 38561(h)). The 2008 Climate Change Scoping Plan proposed a “comprehensive set of actions designed to reduce overall carbon GHG emissions in California, improve our environment, reduce our dependence on oil, diversify our energy sources, save energy, create new jobs, and enhance public health.”
9 The 2008 Climate Change Scoping Plan had a range of GHG reduction actions which included direct regulations, alternative compliance mechanisms, monetary and non- monetary incentives, voluntary actions, market -based mechanisms, such as a Cap -and-Trade Program, and an AB 32 implementation fee to fund the program. 2008 Climate Change Scoping Plan
The 2008 Climate Change Scoping Plan called for a “coordinated set of solutions” to address all major categories of GHG emissions. Transportation emissions were addressed through a combination of higher standards for vehicle fuel economy, implementation of the Low Carbon Fuel Standard (LCFS), and greater consideration to reducing trip length and generation through land use planning and TOD. Buildings, land use, and industrial operations were encouraged and, sometimes,
9 CARB, Climate Change Scoping Plan, December 2008.
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required to use energy more efficiently. Utility energy providers were required to include more renewable energy sources through implementation of the RPS.10 As required by HSC Division 25.5, CARB approved the 1990 GHG emissions inventory, thereby establishing the emissions reduction target for 2020. The 2020 emissions reduction target was originally set at 427 MMT of CO
2e using the GWP values from the Intergovernmental Panel on Climate Change (IPCC) Second Assessment Report (SAR ). Forecasting the amount of emissions that would occur in 2020 if no actions are taken was necessary to assess the scope of the reductions California must make to return to the 1990 emissions level by 2020 as required by AB 32. CARB originally defined the “business-as-usual” (BAU), scenario as emissions in the absence of any GHG emission reduction measures discussed in the 2008 Climate Change Scoping Plan, as approximately 596 MMTCO
2e (using GWP values from the IPCC SAR). For example, in further explaining CARB’s BAU methodology, CARB assumed that all new electricity generation would be supplied by natural gas plants, no further regulatory action would impact vehicle fuel efficiency, and building energy efficiency codes would be held at 2005 standards. Therefore, under these original projections, the State would have had to reduce its 2020 BAU emissions by 28.4 percent to meet the 1990 target of 427 MMTCO
2e.
2014 Climate Change Scoping Plan Update
The First Update to the Climate Change Scoping Plan (2014 Scoping Plan) was approved by CARB in May 2014 and built upon the initial Climate Change Scoping Plan with new strategies and recommendations.
11 In 2014, CARB revised the target using the GWP values from the IPCC Fourth Assessment Report (AR4) and determined the 1990 GHG emissions inventory and 2020 GHG emissions limit to be increased to 431 MMTCO 2e. CARB also updated the State’s 2020 BAU emissions estimate to account for the effect of the 2007– 2009 economic recession, new estimates for future fuel and energy demand, and the reductions required by regulation that had recently been adopted for motor vehicles and renewable energy. CARB’s projected statewide 2020 emissions estimate using the GWP values from the IPCC AR4 was 509.4 MMTCO 2e. Therefore, under the
First Update to the Climate Change Scoping Plan, the emission reductions necessary to achieve the 2020 emissions target of 431 MMTCO
2e would have been 78.4 MMTCO2e, or a reduction of GHG
emissions by approximately 15.4 percent, (down from 28.4 percent).
In conjunction with the First Update, CARB identified “six key focus areas comprising major components of the State’s economy to evaluate and describe the larger transformative actions that will be needed to meet the State’s more expansive emission reduction needs by 2050.” 12 Those six
areas are: (1) energy; (2) transportation (vehicles/ equipment, sustainable communities, housing, fuels, and infrastructure); (3) agriculture; (4) water; (5) waste management; and (6) natural and working lands. The First Update identifies key recommended actions for each sector that will facilitate achievement of the 2050 reduction target.
10 For a discussion of Renewables Portfolio Standard, refer to subsection California Renewables Portfolio Standard. 11 CARB, First Update to the AB 32 Scoping Plan, May 2014. 12 CARB, 2014 Scoping Plan, May 2014, p. 6.
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Based on CARB’s research efforts, it has a “strong sense of the mix of technologies needed to reduce emissions through 2050.” 13 Those technologies include energy demand reduction through efficiency and activity changes; large-scale electrification of on -road vehicles, buildings, and industrial machinery; decarbonizing electricity and fuel supplies; and the rapid market penetration of efficient and clean energy technologies.
The First Update discussed new residential and commercial building energy efficiency improvements, specifically identifying progress towards zero-net -energy buildings as an element of meeting mid -term and long-term GHG reduction goals. The First Updat e expressed CARB’s commitment to working with the California Public Utilities Commission (CPUC) and California Energy Commission (CEC) to facilitate further achievements in building energy efficiency. 2017 Climate Change Scoping Plan Update
In response to the passage of SB 32 and the identification of the 2030 GHG reduction target, CARB adopted the 2017 Climate Change Scoping Plan Update (2017 Scoping Plan) in December 2017.
The 2017 Scoping Plan builds upon the framework established by the 2008 Climate Change Scoping Plan and the First Update while identifying new, technologically feasible, and cost - effective strategies to ensure that California meets its GHG reduction targets in a way that promotes and rewards innovation, continues to foster economic growth, and delivers improvements to the environment and public health. The 2017 Scoping Plan includes policies to require direct GHG reductions at some of the State’s largest stationary sources and mobile sources. These policies include the use of lower GHG fuels, efficiency regulations, and the Cap-and-Trade program, which constrains and reduces emissions at covered sources.
14 CARB’s projected statewide 2030 emissions take into account 2020 GHG reduction policies and programs.
15 The 2017 Scoping Plan also addresses GHG emissions from natural and working lands of California, including the agriculture and forestry sectors. The majority of the reductions would result from the continuation of the Cap-and-Trade regulation. Additional reductions would be achieved from electricity sector standards (i.e., utility providers to supply 50 percent renewable electricity by 2030), doubling the energy efficiency savings at end uses, additional reductions from the LCFS, implementing the short-lived GHG strategy (e.g., HFCs), and implementing the mobile source strategy and sustainable freight action plan.
The alternatives in the Scoping Plan are designed to consider various combinations of these programs, as well as consideration of a carbon tax in the event the Cap-and-Trade regulation is not continued. However, in July 2017, the California Legislature vot ed to extend the Cap -and-Trade regulation to 2030. The 2017 Scoping Plan discusses the role of local governments in meeting the State’s GHG reductions goals because local governments have jurisdiction and land use authority related to: community-scale planning and permitting processes, local codes and actions, outreach
13 CARB, 2014 Scoping Plan, May 2014, p. 32.
14 CARB, 2017 Scoping Plan, November 2017, p. 6
15 CARB, 2017 Scoping Plan, November 2017.
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and education programs, and municipal operations. 16 Furthermore, local governments may have the ability to incentivize renewable energy, energy efficiency, and water efficiency measures.17 For individual projects under the California Environmental Quality Act (CEQA), the 2017 Scoping Plan states that local governments can support climate action when considering discretionary approvals and entitlements. According to the 2017 Scoping Plan, lead agencies have the discretion to develop evidence-based numeric thresholds c onsistent with the 2017 Scoping Plan, the State’s long-term goals, and climate change science.
18 Under the Scoping Plan Scenario, continuation of the Cap-and -Trade regulation (or carbon tax) is expected to cover approximately 34 to 79 MMTCO2 of the 2030 reduction obligation.19 The State’s short-lived climate pollutants strategy, which is for GHGs that remain in the atmosphere for shorter periods of time compared to longer -lived GHGs like CO 2, is expected to cover approximately 17 to 35 MMTCO 2e. The RPS with 50 percent renewable electricity by 2030 is expected to cover approximately 3 MMTCO2. The mobile source strategy and sustainable freight action plan includes maintaining the existing vehicle GHG emissions standards, increasing the number of ZEVs and improving the freight system efficiency, and is expected to cover approximately 11 to 13 MMTCO
2. CARB expects that the reduction in GHGs from doubling of the energy efficiency savings in natural gas and electricity end uses in the CEC 2015 Integrated Energy Policy Report by 2030 would cover approximately 7 to 9 MMTCO
2 of the 2030 reduction obligation. The other strategies would be expected to cover the remaining 2030 reduction obligations. 2022 Climate Change Scoping Plan for Achieving Carbon Neutrality CARB published the Final 2022 Scoping Plan for Achieving Carbon Neutrality (2022 Scoping Plan Update) in November 2022, as the third update to the initial 2008 Climate Change Scoping . The 2022 Scoping Plan Update is the most comprehensive and far-reaching Scoping Plan developed to date. It identifies a technologically feasible, cost-effective, and equity-focused path to achieve new targets for carbon neutrality by 2045 and to reduce a nthropogenic GHG emissions to at least 85 percent below 1990 levels, while also assessing the progress California is making toward reducing its GHG emissions by at least 40 percent below 1990 levels by 2030, as called for in SB 32 The 2030 target is an interim but important stepping stone along the critical path to the broader goal of deep decarbonization by 2045. The relatively longer path assessed in the 2022 Scoping Plan Update incorporates, coordinates, and leverages many existing and ongoing efforts to reduce GHGs and air pollution, while identifying new clean technologies and energy. Given the focus on carbon neutrality, the 2022 Scoping Plan Update also includes discussion for the first time of the natural and working lands sectors as sources for both sequestration and carbon storage, and as sources of emissions as a result of wildfires. A summary of the GHG emissions reductions and targets set forth under the 2022 Scoping Plan Update is provided in Table 4.6-1, Estimated Statewide Greenhouse Gas Emissions Reductions in the 2022 Scoping Plan.
16 CARB, 2017 Scoping Plan, November 2017, p.97.
17 CARB, 2017 Scoping Plan, November 2017, p.97.
18 CARB, 2017 Scoping Plan, November 2017, p.100.
19 CARB, 2017 Scoping Plan, Appendix G, November 2017.
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TABLE 4.6-1
ESTIMATED STATEWIDE GREENHOUSE GAS EMISSIONS REDUCTIONS IN THE 2022 SCOPING PLAN Emissions Scenario GHG Emissions (MMTCO2e)
2019
2019 State GHG Emissions 404
2030
2030 BAU Forecast 312
2030 GHG Emissions without Carbon Removal and Capture 233 2030 GHG Emissions with Carbon Removal and Capture 226
2030 Emissions Target Set by AB 32 (i.e., 1990 level by 2030) 260 Reduction below Business-As-Usual necessary to achieve 1990 levels by 2030 52 (16.7%)a 2045
2045 BAU Forecast 266
2045 GHG Emissions without Carbon Removal and Capture 72 2045 GHG Emissions with Carbon Removal and Capture (3)
MMTCO2e = million metric tons of carbon dioxide equivalents; parenthetical numbers represent negative values. a 312 – 260 = 52 /312 = 16.7%
SOURCE: CARB, Final 2022 Scoping Plan for Achieving Carbon Neutrality, November 2022.
The 2022 Scoping Plan Update reflects existing and recent direction in the Governor’s Executive Orders and State Statutes, which identify policies, strategies, and regulations in support of and implementation of the Scoping Plan. Among these include Executive Order B-55-18 and AB 1279 (The California Climate Crisis Act), which identify the 2045 carbon neutrality and GHG reduction targets required for the Scoping Plan. Table 4.6-2 , Major Climate Legislation and Executive Orders Enacted Since the 2017 Scoping Plan, provides a summary of major climate legislation and executive orders issued since the adoption of the 2017 Scoping Plan.
The 2022 Scoping Plan Update identifies the need to accelerate AB32’s 2030 target, from 40 percent to 48 percent below 1990 levels. Cap-and-Trade regulation continues to play a large factor in the reduction of near-term emissions for meeting the 2030 reduc tion target. Every sector of the economy will need to begin to transition in this decade to meet these GHG reduction goals and achieve carbon neutrality no later than 2045. The 2022 Scoping Plan Update approaches decarbonization from two perspectives, managing a phasedown of existing energy sources and technologies, as well as increasing, developing, and deploying alternative clean energy sources and technology. The Scoping Plan Scenario is summarized in Table 2-1 starting on page 72 of the Scoping Plan. It includes references to relevant statutes and Executive Orders, although it is not comprehensive of all existing new authorities for directing or supporting the actions described.
Table 2-1 identifies actions related to a variety of sectors such as: smart growth and reductions in Vehicle Miles Traveled (VMT); light- duty vehicles (LDV) and zero -emission vehicles (ZEV); truck ZEVs; reduce fossil energy, emissions, and GHGs for aviation ocean -going vessels, port operations, freight and passenger rail, oil and gas extraction; and petroleum refining; improvements in electricity generation; electrical appliances in new and existing residential and commercial
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buildings; electrification and emission reductions across industries such as the for food products, construction equipment, chemicals and allied products, pulp and paper, stone/clay/glass/cement, other industrial manufacturing, and agriculture; retiring of combined heat and power facilities; low carbon fuels for transportation, business, and industry; improvements in non-combustion methane emissions, and introduction of low GWP refrigerants.
TABLE 4.6-2
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
Assembly Bill 1279 (AB 1279)
(Muratsuchi, Chapter 337,
Statutes of 2022)
The California Climate Crisis Act
AB 1279 establishes the policy of the state to achieve carbon neutrality as soon as possible, but no later than 2045; to maintain net negative GHG emissions thereafter; and to ensure that by 2045 statewide anthropogenic GHG emissions are reduced at least 85 percent below 1990 levels. The bill requires CARB to ensure that Scoping Plan updates identify and recommend measures to achieve carbon neutrality, and to identify and implement policies and strategies that enable CO 2 removal solutions and carbon capture, utilization, and storage (CCUS) technologies. This bill is reflected directly in 2022 Scoping Plan Update.
Senate Bill 905 (SB 905)
(Caballero, Chapter 359,
Statutes of 2022)
Carbon Capture, Removal,
Utilization, and Storage Program
SB 905 requires CARB to create the Carbon Capture, Removal, Utilization, and Storage Program to evaluate, demonstrate, and regulate CCUS and carbon dioxide removal (CDR) projects and technology.
The bill requires CARB, on or before January 1, 2025, to adopt regulations creating a unified state permitting application for approval of CCUS and CDR projects. The bill also requires the Secretary of the Natural Resources Agency to publish a framework for governing agreements for two or more tracts of land overlying the same geologic storage reservoir for the purposes of a carbon sequestration project.
The 2022 Scoping Plan Update modeling reflects both CCUS and CDR contributions to achieve carbon neutrality.
Senate Bill 846 (SB 846) (Dodd,
Chapter 239, Statutes of 2022)
Diablo Canyon Powerplant:
Extension of Operations
SB 846 extends the Diablo Canyon Power Plant’s sunset date by up to five additional years for each of its two units and seeks to make the nuclear power plant eligible for federal loans. The bill requires that the CPUC not include and disallow a load-serving entity from including in their adopted resource plan, the energy, capacity, or any attribute from the Diablo Canyon power plant.
The 2022 Scoping Plan Update explains the emissions impact of this legislation.
Senate Bill (SB 1020) (Laird,
Chapter 361, Statutes of 2022)
Clean Energy, Jobs, and
Affordability Act of 2022
SB 1020 adds interim renewable energy and zero carbon energy retail sales of electricity targets to California end-use customers set at 90 percent in 2035 and 95 percent in 2040. It accelerates the timeline required to have 100 percent renewable energy and zero carbon energy procured to serve state agencies from the original target year of 2045 to 2035. This bill requires each state agency to individually achieve the 100 percent goal by 2035 with specified requirements. This bill requires the CPUC, CEC, and CARB, on or before December 1, 2023, and annually thereafter, to issue a joint reliability progress report that reviews system and local reliability.
The bill also modifies the requirement for CARB to hold a portion of its Scoping Plan workshops in regions of the state with the most significant exposure to air pollutants by further specifying that this includes communities with minority populations or low-income communities in areas designated as being in extreme federal non-attainment.
The 2022 Scoping Plan Update describes the implications of this legislation on emissions.
Senate Bill 1137 (SB 1137)
(Gonzales, Chapter 365,
Statutes of 2022)
Oil & Gas Operations: Location
Restrictions: Notice of Intention:
Health protection zone: Sensitive
receptors
SB 1137 prohibits the development of new oil and gas wells or infrastructure in health protection zones, as defined, except for purposes of public health and safety or other limited exceptions. The bill requires operators of existing oil and gas wells or infrastructure within health protection zones to undertake specified monitoring, public notice, and nuisance requirements. The bill requires CARB to consult and concur with the California Geologic Energy Management Division (CalGEM) on leak detection and repair plans for these facilities, adopt regulations as necessary to implement emission detection system standards, and collaborate with CalGEM on public access to emissions detection data.
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TABLE 4.6-2
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
Senate Bill 1075 (SB 1075)
(Skinner, Chapter 363, Statutes
of 2022)
Hydrogen: Green Hydrogen:
Emissions of Greenhouse Gases
SB 1075 requires CARB, by June 1, 2024, to prepare an evaluation that includes:
policy recommendations regarding the use of hydrogen, and specifically the use of green hydrogen, in California; a description of strategies supporting hydrogen infrastructure, including identifying policies that promote the reduction of GHGs and short-lived climate pollutants; a description of other forms of hydrogen to achieve emission reductions; an analysis of curtailed electricity; an estimate of GHG and emission reductions that could be achieved through deployment of green hydrogen through a variety of scenarios; an analysis of the potential for opportunities to integrate hydrogen production and applications with drinking water supply treatment needs; policy recommendations for regulatory and permitting processes associated with transmitting and distributing hydrogen from production sites to end uses; an analysis of the life-cycle GHG emissions from various forms of hydrogen production; and an analysis of air pollution and other environmental impacts from hydrogen distribution and end uses.
This bill would inform the production of hydrogen at the scale called for in the 2022 Scoping Plan Update.
Assembly Bill 1757 (AB 1757)
(Garcia, Chapter 341, Statutes
of 2022)
California Global Warming
Solutions Act of 2006: Climate
Goal: Natural and Working Lands
AB 1757 requires the California Natural Resources Agency (CNRA), in collaboration with CARB, other state agencies, and an expert advisory committee, to determine a range of targets for natural carbon sequestration, and for nature- based climate solutions, that reduce GHG emissions in 2030, 2038, and 2045 by January 1, 2024. These targets must support state goals to achieve carbon neutrality and foster climate adaptation and resilience.
This bill also requires CARB to develop standard methods for state agencies to consistently track GHG emissions and reductions, carbon sequestration, and additional benefits from natural and working lands over time. These methods will account for GHG emissions reductions of CO
2, methane, and nitrous oxide related
to natural and working lands and the potential impacts of climate change on the ability to reduce GHG emissions and sequester carbon from natural and working lands, where feasible.
This 2022 Scoping Plan Update describes the next steps and implications of this legislation for the natural and working lands sector.
Senate Bill 1206 (SB 1206)
(Skinner, Chapter 884, Statutes
of 2022)
Hydrofluorocarbon gases: sale or
distribution
SB 1206 mandates a stepped sales prohibition on newly produced high- global warming potential (GWP) hydrofluorocarbons (HFCs) to transition California’s economy toward recycled and reclaimed HFCs for servicing existing HFC-based equipment. Additionally, SB 1206 also requires CARB to develop regulations to increase the adoption of very low-, i.e., GWP < 10, and no-GWP technologies in sectors that currently rely on higher-GWP HFCs.
Senate Bill 27 (SB 27) (Skinner,
Chapter 237, Statutes of 2021)
Carbon Sequestration: State
Goals: Natural and Working
Lands: Registry of Projects
SB 27 requires CNRA, in coordination with other state agencies, to establish the Natural and Working Lands Climate Smart Strategy by July 1, 2023. This bill also requires CARB to establish specified CO
2 removal targets for 2030 and beyond as
part of its Scoping Plan. Under SB 27, CNRA is to establish and maintain a registry to identify projects in the state that drive climate action on natural and working lands and are seeking funding.
CNRA also must track carbon removal and GHG emission reduction benefits derived from projects funded through the registry.
This bill is reflected directly in 2022 Scoping Plan Update as CO2 removal targets for 2030 and 2045 in support of carbon neutrality.
Senate Bill 596 (SB 596)
(Becker, Chapter 246, Statutes
of 2021)
Greenhouse Gases: Cement
Sector: Net-Zero Emissions
Strategy
SB 596 requires CARB, by July 1, 2023, to develop a comprehensive strategy for the state’s cement sector to achieve net-zero emissions of GHGs associated with cement used within the state as soon as possible, but no later than December 31, 2045. The bill establishes an interim target of 40 percent below the 2019 average GHG intensity of cement by December 31, 2035. Under SB 596, CARB must:
Define a metric for GHG intensity and establish a baseline from which to measure GHG intensity reductions.
• Evaluate the feasibility of the 2035 interim target (40 percent reduction in GHG intensity) by July 1, 2028.
• Coordinate and consult with other state agencies.
• Prioritize actions that leverage state and federal incentives.
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TABLE 4.6-2
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
• Evaluate measures to support market demand and financial incentives to encourage the production and use of cement with low GHG intensity.
The 2022 Scoping Plan Update modeling is designed to achieve these outcomes.
Executive Order N-82-20 Governor Newsom signed Executive Order N-82-20 in October 2020 to combat the climate and biodiversity crises by setting a statewide goal to conserve at least 30 percent of California’s land and coastal waters by 2030. The Executive Order also instructed the CNRA, in consultation with other state agencies, to develop a Natural and Working Lands Climate Smart Strategy that serves as a framework to advance the state’s carbon neutrality goal and build climate resilience. In addition to setting a statewide conservation goal, the Executive Order directed CARB to update the target for natural and working lands in support of carbon neutrality as part of this Scoping Plan, and to take into consideration the NWL Climate Smart Strategy.
CO
2 Executive Order N-82-20 also calls on the CNRA, in consultation with other state agencies, to establish the California Biodiversity Collaborative (Collaborative).
The Collaborative shall be made up of governmental partners, California Native American tribes, experts, business and community leaders, and other stakeholders from across the state. State agencies will consult the Collaborative on efforts to:
• Establish a baseline assessment of California’s biodiversity that builds upon existing data and can be updated over time.
• Analyze and project the impact of climate change and other stressors in California’s biodiversity.
• Inventory current biodiversity efforts across all sectors and highlight opportunities for additional action to preserve and enhance biodiversity.
CNRA also is tasked with advancing efforts to conserve biodiversity through various actions, such as streamlining the state’s process to approve and facilitate projects related to environmental restoration and land management. The California Department of Food and Agriculture (CDFA) is directed to advance efforts to conserve biodiversity through measures such as reinvigorating populations of pollinator insects, which restore biodiversity and improve agricultural production.
The Natural and Working Lands Climate Smart Strategy informs 2022 Scoping Plan Update.
Executive Order N-79-20 Governor Newsom signed Executive Order N-79-20 in September 2020 to establish targets for the transportation sector to support the state in its goal to achieve carbon neutrality by 2045. The targets established in this Executive Order are:
• 100 percent of in-state sales of new passenger cars and trucks will be zero- emission by 2035.
• 100 percent of medium- and heavy-duty vehicles will be zero-emission by 2045 for all operations where feasible, and by 2035 for drayage trucks. • 100 percent of off-road vehicles and equipment will be zero-emission by 2035 where feasible.
The Executive Order also tasked CARB to develop and propose regulations that require increasing volumes of zero- electric passenger vehicles, medium- and heavy-duty vehicles, drayage trucks, and off-road vehicles toward their corresponding targets of 100 percent zero-emission by 2035 or 2045, as listed above.
The 2022 Scoping Plan Update modeling reflects achieving these targets.
Executive Order N-19-19 Governor Newsom signed Executive Order N-19-19 in September 2019 to direct state government to redouble its efforts to reduce GHG emissions and mitigate the impacts of climate change while building a sustainable, inclusive economy. This Executive Order instructs the Department of Finance to create a Climate Investment Framework that:
• Includes a proactive strategy for the state’s pension funds that reflects the increased risks to the economy and physical environment due to climate change.
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TABLE 4.6-2
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
• Provides a timeline and criteria to shift investments to companies and industry sectors with greater growth potential based on their focus of reducing carbon emissions and adapting to the impacts of climate change. • Aligns with the fiduciary responsibilities of the California Public Employees’ Retirement System, California State Teachers’ Retirement System, and the University of California Retirement Program.
Executive Order N-19-19 directs the State Transportation Agency to leverage more than $5 billion in annual state transportation spending to help reverse the trend of increased fuel consumption and reduce GHG emissions associated with the transportation sector. It also calls on the Department of General Services to leverage its management and ownership of the state’s 19 million square feet in managed buildings, 51,000 vehicles, and other physical assets and goods to minimize state government’s carbon footprint. Finally, it tasks CARB with accelerating progress toward California’s goal of five million ZEV sales by 2030 by:
• Developing new criteria for clean vehicle incentive programs to encourage manufacturers to produce clean, affordable cars.
• Proposing new strategies to increase demand in the primary and secondary markets for ZEVs.
• Considering strengthening existing regulations or adopting new ones to achieve the necessary GHG reductions from within the transportation sector.
The 2022 Scoping Plan Update modeling reflects efforts to accelerate ZEV deployment.
Senate Bill 576 (SB 576)
(Umberg, Chapter 374, Statutes
of 2019)
Coastal Resources: Climate
Ready Program and Coastal
Climate Change Adaptation,
Infrastructure and Readiness
Program
Sea level rise, combined with storm-driven waves, poses a direct risk to the state’s coastal resources, including public and private real property and infrastructure.
Rising marine waters threaten sensitive coastal areas, habitats, the survival of threatened and endangered species, beaches, other recreation areas, and urban waterfronts. SB 576 mandates that the Ocean Protection Council develop and implement a coastal climate adaptation, infrastructure, and readiness program to improve the climate change resiliency of California’s coastal communities, infrastructure, and habitat. This bill also instructs the State Coastal Conservancy to administer the Climate Ready Program, which addresses the impacts and potential impacts of climate change on resources within the conservancy’s jurisdiction.
Assembly Bill 65 (AB 65)
(Petrie- Norris, Chapter 347,
Statutes of 2019)
Coastal Protection: Climate
Adaption: Project Prioritization:
Natural Infrastructure: Local
General Plans
This bill requires the State Coastal Conservancy, when it allocates any funding appropriated pursuant to the California Drought, Water, Parks, Climate, Coastal Protection, and Outdoor Access For All Act of 2018, to prioritize projects that use natural infrastructure in coastal communities to help adapt to climate change. The bill requires the conservancy to provide information to the Office of Planning and Research on any projects funded pursuant to the above provision to be considered for inclusion into the clearinghouse for climate adaption information. The bill authorizes the conservancy to provide technical assistance to coastal communities to better assist them with their projects that use natural infrastructure.
Executive Order B-55-18 Governor Brown signed Executive Order B-55-18 in September 2018 to establish a statewide goal to achieve carbon neutrality as soon as possible, and no later than 2045, and to achieve and maintain net negative emissions thereafter. Policies and programs undertaken to achieve this goal shall:
• Seek to improve air quality and support the health and economic resiliency of urban and rural communities, particularly low-income and disadvantaged communities.
• Be implemented in a manner that supports climate adaptation and biodiversity, including protection of the state’s water supply, water quality, and native plants and animals.
This Executive Order also calls for CARB to:
• Develop a framework for implementation and accounting that tracks progress toward this goal.
• Ensure future Scoping Plans identify and recommend measures to achieve the carbon neutrality goal.
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TABLE 4.6-2
MAJOR CLIMATE LEGISLATION AND EXECUTIVE ORDERS ENACTED SINCE THE 2017 SCOPING PLAN Bill/Executive Order Summary
The 2022 Scoping Plan Update is designed to achieve carbon neutrality no later than 2045 and the modeling includes technology and fuel transitions to achieve that outcome.
Senate Bill 100 (SB 100)
(De León, Chapter 312, Statutes
of 2018)
California Renewables Portfolio
Standard Program: emissions of
greenhouse gases
Under SB 100, the CPUC, CEC, and CARB shall use programs under existing laws to achieve 100 percent clean electricity. The statute requires these agencies to issue a joint policy report on SB 100 every four years. The first of these reports was issued in 2021.
The 2022 Scoping Plan Update reflects the SB 100 Core Scenario resource mix with a few minor updates.
Assembly Bill 2127 (AB 2127)
(Ting, Chapter 365, Statutes of
2018)
Electric Vehicle Charging
Infrastructure: Assessment
This bill requires the CEC, working with CARB and the CPUC, to prepare and biennially update a statewide assessment of the electric vehicle charging infrastructure needed to support the levels of electric vehicle adoption required for the state to meet its goals of putting at least 5 million zero-emission vehicles on California roads by 2030 and of reducing emissions of GHGs to 40 percent below 1990 levels by 2030. The bill requires the CEC to regularly seek data and input from stakeholders relating to electric vehicle charging infrastructure.
This bill supports the deployment of ZEVs as modeled in 2022 Scoping Plan Update.
Senate Bill 30 (SB 30) (Lara,
Chapter 614, Statutes of 2018)
Insurance: Climate Change
This bill requires the Insurance Commissioner to convene a working group to identify, assess, and recommend risk transfer market mechanisms that, among other things, promote investment in natural infrastructure to reduce the risks of climate change related to catastrophic events, create incentives for investment in natural infrastructure to reduce risks to communities, and provide mitigation incentives for private investment in natural lands to lessen exposure and reduce climate risks to public safety, property, utilities, and infrastructure. The bill requires the policies recommended to address specified questions.
Assembly Bill 2061 (AB 2061)
(Frazier, Chapter 580, Statutes
of 2018)
Near-Zero-Emission and Zero-
Emission Vehicles
Existing state and federal law sets specified limits on the total gross weight imposed on the highway by a vehicle with any group of two or more consecutive axles. Under existing federal law, the maximum gross vehicle weight of that vehicle may not exceed 82,000 pounds. AB 2061 authorizes a near-zero- emission vehicle or a zero-emission vehicle to exceed the weight limits on the power unit by up to 2,000 pounds. This bill supports the deployment of cleaner trucks as modeled in this 2022 Scoping Plan Update.
Achieving the targets described in the 2022 Scoping Plan Update will require continued commitment to and successful implementation of existing policies and programs, and identification of new policy tools and technical solutions to go further, faster. Cali fornia’s Legislature and state agencies will continue to collaborate to achieve the state’s climate, clean air, equity, and broader economic and environmental protection goals. It will be necessary to maintain and strengthen this collaborative effort, and to draw upon the assistance of the federal government, regional and local governments, tribes, communities, academic institutions, and the private sector to achieve the state’s near-term and longer -term emission reduction goals and a more equitable future for all Californians. The Scoping Plan acknowledges that the path forward is not dependent on one agency, one state, or even one country. However, the State can lead by engaging Californians and demonstrating how actions at the state, regional, and local levels of governments, as well as action at community and individual levels, can contribute to addressing the challenge.
Appendix D, Local Actions, of the 2022 Scoping Plan Update includes “recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and
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approval of new land use development projects, including through environmental review under the California Environmental Quality Act (CEQA).” Appendix D is intended to provide clarification on challenges local jurisdictions face when implementing GHG reduction strategies or approving much-needed housing projects.
20 Aligning local jurisdiction action with state -level priorities to tackle climate change and the outcomes called for in the 2022 Scoping Plan Update is critical to achieving the statutory targets for 2030 and 2045. The 2022 Scoping Plan Update discusses the role of local governments in meeting the State’s GHG reductions goals. Local governments have the primary authority to plan, zone, approve, and permit how and where land is developed to accommodate population growth, economic growth, and the changing needs of their jurisdictions. They also make critical decisions on how and when to deploy transportation infrastructure, and can choose to support transit, walking, bicycling, and neighborhoods that do not force people into cars. Local governments also have the option to adopt building ordinances that exceed statewide building code requirements and play a critical role in facilitating the rollout of ZEV infrastructure. As a result, local government decisions play a critical role in supporting state -level measures to contain the growth of GHG emissions associated with the transportation system and the built environment —the two largest GHG emissions sectors over which local governments have authority. The City has taken the initiative in combating climate change b y addressing it in the Culver City General Plan and developing programs and regulations such as the Culver City Green Building Ordinance, Culver City Bicycle & Pedestrian Action Plan, Culver City's Electric Vehicle (EV) Infrastructure Plan, and Culver City Clean Power Alliance. Each of these is discussed further below.
Cap-and-Trade Program
The Climate Change Scoping Plan identifies a Cap -and-Trade Program as one of the strategies California would employ to reduce GHG emissions. CARB asserts that this program will help put California on the path to meet its goal of ultimately achieving an 80 percent reduction from 1990 levels by 2050. Under the Cap-and-Trade Program, an overall limit on GHG emissions from capped sectors is established and facilities subject to the cap will be able to trade permits to emit GHGs.
CARB designed and adopted a California Cap-and-Trade Program 21 pursuant to its authority under
AB 32. The Cap-and-Trade Program is designed to reduce GHG emissions from public and private major sources (deemed “covered entities”) by setting a firm cap on statewide GHG emissions and employing market mechanisms to achieve the State’s emission-reduction mandates. The statewide cap for GHG emissions from the capped sectors
22 (e.g., electricity generation, petroleum refining,
and cement production) commenced in 2013 and will decline over time, achieving GHG emission reductions throughout the Program’s duration.
Under the Cap-and-Trade Program, CARB issues allowances equal to the total amount of allowable emissions over a given compliance period and distributes these to regulated entities. Covered entities that emit more than 25,000 MTCO
2e per year must comply with the Cap -and-Trade
20 CARB, Final 2022 Climate Change Scoping Plan – Appendix D: Local Actions, November 2022. 21 California Code of Regulations (CCR) 17, Section 95800 to 96023. 22 CCR 17, Section 95811, 95812.
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Program.23 Triggering of the 25,000 MTCO2e per year “inclusion threshold” is measured against a subset of emissions reported and verified under the California Regulation for the Mandatory Reporting of Greenhouse Gas Emissions (Mandatory Reporting Rule).24 Each covered entity with a compliance obligation is required to surrender “compliance instruments”
25 for each MTCO2e of GHG they emit. Covered entities are allocated free allowances in whole or part (if eligible), and can buy allowances at auction, purchase allowances from others, or purchase offset credits.
The Cap-and-Trade Regulation provides a firm cap, ensuring that the statewide emission limits will not be exceeded. In sum, the Cap -and-Trade Program will achieve aggregate, rather than site- specific or project-level, GHG emissions reductions. Also, due to the regulatory framework adopted by CARB in AB 32, the reductions attributed to the Cap-and-Trade Program can change over time depending on the State’s emissions forecasts and the effectiveness of direct regulatory measures.
The Cap-and-Trade Program covers the GHG emissions associated with electricity consumed in California, whether generated in -state or imported.
26 Accordingly, for projects that are subject to
the CEQA, GHG emissions from electricity consumption are covered by the Cap -and-Trade Program. The Cap -and-Trade Program also covers fuel suppliers (natural gas and propane fuel providers and transportation fuel providers) to address emissions from such fuels and from combustion of other fossil fuels not directly covered at large sources in the Program’s first compliance period.
27 The Program applies to emissions that cover approximately 80 percent of the State’s GHG emissions. Demonstrating the efficacy of AB 32 policies, California achieved its 2020 GHG Reduction Target four years earlier than mandated. The largest reductions were the result of increased renewable electricity in the electricity sector, which is a covered sector in the Cap -and- Trade Program.
AB 398 was enacted in 2017 to extend and clarify the role of the State’s Cap-and-Trade Program through December 31, 2030. As part of AB 398, refinements were made to the Cap-and -Trade program to establish updated protocols and allocation of proceeds to reduce GHG emissions.
Energy-Related (Stationary) Sources
Emission Performance Standards
SB 1368, signed September 29, 2006, is a companion bill to AB 32, which requires the CPUC and the CEC to establish GHG emission performance standards for the generation of electricity. These standards also generally apply to power that is generated outside of California and imported into
23 CCR 17, Section 95812.
24 CCR 17, Section 95100-95158.
25 Compliance instruments are permits to emit, the majority of which will be “allowances,” but entities also are allowed to use CARB-approved offset credits to meet up to 8% of their compliance obligations. 26 CCR 17, Section 95811(b).
27 CCR 17, Section 95811, 95812(d).
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the State. SB 1368 provides a mechanism for reducing the emissions of electricity providers, thereby assisting CARB to meet its mandate under AB 32.
Renewables Portfolio Standard
SB 1078 (Chapter 516, Statutes of 2002) required retail sellers of electricity, including investor - owned utilities and community choice aggregators, to provide at least 20 percent of their supply from renewable sources by 2017 as an RPS. Subsequent amendments provided additional targets throughout the years. Most recently, on October 7, 2015, SB 350 (Chapter 547, Statues of 2015), also known as the Clean Energy and Pollution Reduction Act, further increased the RPS to 50 percent by 2030. The legislation also included interim targets of 40 percent by 2024 and 45 percent by 2027. SB 350 also requires the State to double statewide energy efficiency savings in electricity and natural gas end uses by 2030. On September 10, 2018, SB 100, provided additional RPS targets of 44 percent by 2024, 52 percent by 2027, and 60 percent by 2030, and that CARB should plan for 100 percent eligible renewable energy resources and zero-carbon resources by 2045. 28 Assembly Bill 1279 (The California Climate Crisis Act) The Legislature enacted AB 1279 29, The California Climate Crisis Act, on September 16, 2022.
AB 1279 establishes the policy of the State to achieve net zero GHG emissions, carbon neutrality30, as soon as possible, but no later than 2045 and achieve and maintain net negative GHG emissions thereafter. Additionally, AB 1279 ensures that by 2045 Statewide anthropogenic GHG emissions are reduced at least 85 percent below 1990 levels. SB 1279 also requires CARB to ensure that the 2022 Scoping Plan Update identifies and recommends measures to achieve carbon neutrality, and to identify and implement policies and strategies for carbon dioxide removal solutions and carbon capture, utilization, and storage technologies. It also requires CARB to submit an annual report on progress in achieving the 2022 Scoping Plan’s goals.
Mobile Sources
Pavley Standards
AB 1493 (Chapter 200, Statutes of 2002), enacted on July 22, 2002, required CARB to set GHG emission standards for passenger vehicles, light duty trucks, and other vehicles whose primary use is non-commercial personal transportation manufactured in and after 2009. In 2018, the USEPA proposed the SAFE Vehicles Rule, which would roll back fuel economy standards and revoke California’s waiver. The rule amended certain average fuel economy and GHG standards for passenger cars covering model years 2021 through 2026. On March 30, 2020, the SAFE Rule was finalized and published in the Federal Register, commencing a review period. Subsequent legal challenges from a coalition of states, including California, and private industry groups were issued.
28 California Legislative Information, SB-100 California Renewables Portfolio Standard Program: Emissions of Greenhouse Gases.
29 California Legislative Information, 2022. AB-1279 The California Climate Crisis Act. https://leginfo.legislature.ca.gov/faces/billNavClient.xhtml?bill_id=202120220AB1279. Accessed January 2023. 30 Carbon neutrality means “net zero” emissions of GHGs. In other words, it means that GHG emissions generated by sources such as transportation, power plants, and industrial processes must be less than or equal to the amount of carbon dioxide that is stored, both in natural sinks and through mechanical sequestration. AB 1279 uses the terminology net zero and the 2022 Scoping Plan Update uses the terminology carbon neutrality or carbon neutral.
These terms mean the same thing and are used interchangeably.
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In August 2021, USEPA proposed to revise and strengthen the emissions standards for passenger cars and light trucks for model years 2023 through 2026.
On September 27, 2019, the USEPA withdrew the waiver it had previously provided to California for the State’s GHG and ZEV programs under Section 209 of the CAA. 31 The withdrawal of the
waiver was effective November 26, 2019. In response, several states including California filed a lawsuit challenging the withdrawal of the USEPA waiver. 32 In April 2021, the USEPA announced
it will move to reconsider its previous withdrawal and grant California permission to set more stringent climate requirements for cars and SUVs.
33 On March 14, 2022, the USEPA published its
Notice of Decision to continue California’s waiver for its Advanced Clean Cars program, which allows the state to set and enforce more stringent standards than the federal government, including California’s GHG standards and zero emission vehicle mandate, thereby ending the SAFE rule (87 Fed. Reg. 14,332).
California Low-Carbon Fuel Standard
Executive Order S-01-07 was enacted on January 18, 2007. The order mandates the following:
(1) that a Statewide goal be established to reduce the carbon intensity of California’s transportation fuels by at least 10 percent by 2020 and (2) that a LCFS for t ransportation fuels be established in California. The final regulation was approved by the Office of Administrative Law and filed with the Secretary of State on January 12, 2010; the LCFS became effective on the same day. In September 2015, CARB approved t he re -adoption of the LCFS, which became effective on January 1, 2016, to address procedural deficiencies in the way the original regulation was adopted.
34 The development of the 2022 Scoping Plan has identified LCFS as a regulatory measure to reduce GHG emission to meet the 2030 emissions target. In September 2018, the standards were amended by CARB to require a 20 percent reduction in carbon intensity by 2030, aligning with California’s 2030 targets set by SB 32.
35 Advanced Clean Car Regulations
In 2012, CARB approved the ACC program, an emissions-control program for model years 2015– 2025.36 The components of the ACC program include the low-emissions vehicle (LEV) regulations that reduce criteria pollutants and GHG emissions from light- and medium-duty vehicles, and the ZEV regulation, which requires manufacturers to produce an increasing number of pure ZEVs
31 84 FR 51310.
32 United States District Court for the District Court of Columbia, State of California vs. Chao, Case 1:19-cv-02826, 2019.
33 United States Federal Register, California State Motor Vehicle Pollution Control Standards; Advanced Clean Car Program; Reconsideration of a Previous Withdrawal of a Waiver of Preemption; Opportunity for Public Hearing and Public Comment (Document Number: 2021-08826), April 28, 2021. 34 CARB, Low-Carbon Fuel Standard – About, https://ww2.arb.ca.gov/our-work/programs/low-carbon-fuel- standard/about. Accessed September 25, 20232.
35 CARB, CARB amends Low-Carbon Fuel Standard for wider impact, 2018, https://ww2.arb.ca.gov/index.php/news/carb-amends-low-carbon-fuel-standard-wider-impact. Accessed September 25, 2023.
36 CARB, Advanced Clean Cars Program – About, https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars- program/about. Accessed September 25, 2023.
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(meaning battery electric and fuel cell electric vehicles), with provisions to also produce plug -in- hybrid electric vehicles (PHEV) in the 2018 through 2025 model years. 37 During the March 2017 Midterm Review, CARB voted unanimously to continue with the vehicle GHG emission standards and the ZEV program for cars and light trucks sold in California through 2025. 38 Effective November 26, 2019, the federal SAFE Vehicles Rule Part One: One National Program withdrew 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 C lean Cars and ZEV mandates.
In response, several states including California filed a lawsuit challenging the withdrawal of the EPA waiver.
39 On March 14, 2022, the USEPA issued a notice of decision to continue California’s Clean Air Act waiver for its Advanced Clean Car regulations.40 In addition, Governor Gavin Newsom signed an executive order (Executive Order No. N -79-20) on September 23, 2020, which 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.
The primary mechanism for achieving the ZEV target for passenger cars and light trucks is CARB’s 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 vehicles through th e 2025 model year. A rulemaking package was presented to the Board in June 2022 and was adopted on November 30, 2022.
Sustainable Communities and Climate Protection Act (SB 375) The Sustainable Communities and Climate Protection Act of 2008, or SB 375 (Chapter 728, Statutes of 2008), establishes mechanisms for the development of regional targets for reducing passenger vehicle GHG emissions, was adopted by the State on September 30, 2008. SB 375 finds that the “transportation sector is the single largest contributor of GHGs of any sector.” 41 Under
SB 375, CARB is required, in consultation with the metropolitan planning organizations (MPOs), to set regional GHG reduction targets for the passenger vehicle and light-duty truck sector for 2020 and 2035. SCAG is the MPO in which the City of Culver City is located. CARB set targets for 2020 and 2035 for each of the 18 MPO regions in 2010, and updated them in 2018. 42 In March 2018, the CARB updated the SB 375 targets for the SCAG region to require an eight percent
37 CARB, Advanced Clean Cars Program – About, https://ww2.arb.ca.gov/our-work/programs/advanced-clean-cars- program/about. Accessed September 25, 2023.
38 CARB, News Release: CARB finds vehicle standards are achievable and cost -effective, ww2.arb.ca.gov/news/ carb-finds-vehicle-standards-are-achievable-and-cost-effective, accessed September 1, 2022. 39 United States District Court for the District Court of Columbia, State of California vs. Chao, Case 1:19-cv-02826, 2019.
40 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). 41 State of California, SB No. 375, September 30, 2008. 42 CARB, Sustainable Communities & Climate Protection Program – About, https://ww2.arb.ca.gov/our- work/programs/sustainable-communities-climate-protection-program/about. Accessed September 25, 2023.
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reduction by 2020 and a 19 percent reduction by 2035 in per capita passenger vehicle GHG emissions.43 As discussed further below, SCAG has adopted an updated Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS) subsequent to the update of the emission targets. The 2020–2045 RTP/SCS, referred to as Connect SoCal, is expected to reduce per capita transportation emissions by 19 percent by 2035, which is consistent with SB 375 compliance with respect to meeting the State’s GHG emission reduction goals. 44 Under SB 375, the target must be incorporated within that region’s RTP, which is used for long- term transportation planning, in an SCS. Certain transportation planning and programming activities would then need to be consistent with the SCS; however, SB 375 expressly provides that the SCS does not regulate the use of land, and further provides that local land use plans and policies (e.g., general plans) are not required to be consistent with either the RTP or SCS.
As required under SB 375, CARB is required to update regional GHG emissions targets every 8 years with the last update formally adopted in March 2018. As part of the 2018 updates, CARB has adopted a passenger vehicle related GHG reduction of 19 percent for 2035 for the SCAG region which is reflected in Connect SoCal.
45 Senate Bill 743
Former Governor Brown signed SB 743 in 2013, which creates a process to change the way that transportation impacts are analyzed under CEQA. Specifically, SB 743 requires the Office of Planning and Research (OPR) to amend the CEQA Guidelines to provide an alternative to level of service (LOS) methodology for evaluating transportation impacts. Particularly within areas served by transit, the required alternative criteria must “promote the reduction of GHG emissions, the development of multimodal transportation networks, and a diversity of land uses.” Measurements of transportation impacts may include “vehicle miles traveled, vehicle miles traveled per capita, automobile trip generation rates, or automobile trips generated.” Building Standards and Other Regulations
California Appliance Efficiency Regulations
The Appliance Efficiency Regulations (Title 20, Sections 1601 through 1608), adopted by the CEC, include standards for new appliances (e.g., refrigerators) and lighting, if they are sold or offered for sale in California. These standards include minimum levels of operating efficiency, and other cost- effective measures, to promote the use of energy- and water-efficient appliances.
Title 24, Building Standards Code and California Green Building Standards Code The CEC first adopted the Energy Efficiency Standards for Residential and Nonresidential Buildings (California Code of Regulations [CCR] Title 24, Part 6) in 1978 in response to a legislative mandate to reduce energy consumption in the State. Although not originally intended to reduce GHG emissions, increased energy efficiency, and reduced consumption of electricity, natural gas, and other fuels would result in fewer GHG emissions from residential and
43 CARB, SB 375 Regional Greenhouse Gas Emissions Reduction Targets. 44 SCAG, Connect SoCal, Chapter 0: Making Connections, May 7, 2020, p. 5. 45 CARB, SB 375 Regional Greenhouse Gas Emissions Reduction Targets (2018).
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nonresidential buildings subject to the standard. The standards are updated periodically to allow for the consideration and inclusion of new energy efficiency technologies and methods.
The California Green Building Standards Code (California Code of Regulations, Title 24, Part 11) are commonly referred to as the CALGreen Building Code and was developed to help the State achieve its GHG reduction goals under HSC Division 25.5 (e.g., AB 32) by codifying standards for reducing building-related energy, water, and resource demand, which in turn reduces GHG emissions from energy, water, and resource demand. The purpose of the CALGreen Building Code is to “improve public health, safety and general welfare by enhancing the design and construction of buildings through the use of building concepts having a positive environmental impact and encouraging sustainable construction practices in the following categories: (1) Planning and design; (2) Energy efficiency; (3) Water efficiency and conservation; (4) Material conservation and resource efficiency; and (5) Environmental air quality.” 46 The CALGreen Building Code is not
intended to substitute for or be identified as meeting the certification requirements of any green building program that is not established and adopted by the California Building Standards Commission. The CALGreen Buildin g Code establishes mandatory measures for new residential and non-residential buildings. Such mandatory measures include energy efficiency, water conservation, material conservation, planning and design and overall environmental quality. 47 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. 48 California Environmental Quality Act Guidelines
In August 2007, the California State Legislature adopted SB 97 (Chapter 185, Statutes of 2007), requiring the Governor’s OPR to prepare and transmit new CEQA Guidelines for the mitigation of GHG emissions or the effects of GHG emissions to the Resources Ag ency by July 1, 2009. In response to SB 97, the OPR adopted the CEQA Guidelines that became effective on March 18, 2010.
However, neither a threshold of significance nor any specific mitigation measures are included or provided in the CEQA Guidelines.
49 The CEQA Guidelines require a lead agency to make a good- faith effort, based on the extent possible on scientific and factual data, to describe, calculate, or estimate the amount of GHG emissions resulting from a project. Discretion is given to the lead agency whether to (1) use a model or methodology to quantify GHG emissions resulting from a project, and which model or methodology to use, or (2) rely on a qualitative analysis or
46 California Building Standards Commission, 2010 California Green Building Standards Code, 2010. 47 California Building Standards Commission, 2010 California Green Building Standards Code, 2010. 48 California Energy Commission, 2022 Building Energy Efficiency Standards. 49 See 14 California Code of Regulations Sections 15064.7 (generally giving discretion to lead agencies to develop and publish thresholds of significance for use in the determination of the significance of environmental effects), 15064.4 (giving discretion to lead agencies to determine the significance of impacts from GHGs).
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performance-based standards. Furthermore, three factors are identified that should be considered in the evaluation of the significance of GHG emissions:
1. The extent to which a project may increase or reduce GHG emissions as compared to the existing environmental setting;
2. Whether the project emissions exceed a threshold of significance that the lead agency determines applies to the project; and
3. The extent to which the project complies with regulations or requirements adopted to implement a statewide, regional, or local plan for the reduction or mitigation of GHG emissions.
50 On December 28, 2018, OPR adopted amendments to the CEQA Guidelines to clarify several points such as cumulative nature of GHG emissions, modeling methodology, and significance evaluation. The administrative record for the CEQA Guidelines amendments also clarifies “that the effects of GHG emissions are cumulative and should be analyzed in the context of California Environmental Quality Act’s requirements for cumulative impact analysis.” 51 Regional
South Coast Air Quality Management District
The Project Site is located in the South Coast Air Quality Management District (SCAQMD) South Coast Air Basin (Air Basin), which consists of Orange County, Los Angeles County (excluding the Antelope Valley portion), and the western, non- desert portions of San Bernardino and Riverside Counties, in addition to the San Gorgonio Pass area in Riverside County. SCAQMD is responsible for air quality planning in the Air Basin and developing rules and regulations to bring the area into attainment of the ambient air quality standards. This is accomplished through air quality monitoring, evaluation, education, implementation of control measures to reduce emissions from stationary sources, permitting and inspection of pollution sources, enforcement of air quality regulations, and by supporting and implementing measures to reduce emissions from motor vehicles.
In 2008, SCAQMD released draft guidance regarding interim CEQA GHG significance thresholds.
52 A GHG Significance Threshold Working Group was formed to further evaluate potential GHG significance thresholds. 53 The SCAQMD proposed the use of a percent emission reduction target to determine significance for commercial/residential projects that emit greater than 3,000 MTCO
2e per year. Under this proposal, commercial/residential projects that emit fewer than 3,000 MTCO2e per year would be assumed to have a less than significant impact on climate change.
On December 5, 2008, the SCAQMD Governing Board adopted the staff proposal for an interim GHG significance threshold of 10,000 MTCO
2e per year for stationary source/industrial projects
where the SCAQMD is the lead agency. However, the SCAQMD has yet to adopt a GHG significance threshold for land use development projects (e.g., residential/commercial projects).
50 14 California Code of Regulations Section 15064.4(b). 51 Letter from Cynthia Bryant, Director of the Governor’s Office of Planning and Research (OPR) to Mike Chrisman, California Secretary for Natural Resources, dated April 13, 2009. 52 South Coast Air Quality Management District (SCAQMD), Board Meeting, December 5, 2008, Agenda No. 31, http://www3.aqmd.gov/hb/2008/December/0812ag.html. Accessed September 25, 2023. 53 SCAQMD, Greenhouse Gases CEQA Significance Thresholds, http://www.aqmd.gov/home/regulations/ceqa/air- quality-analysis-handbook/ghg-significance-thresholds. Accessed September 25, 2023.
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The Working Group has been inactive since 2011, and SCAQMD has not formally adopted any GHG significance threshold for other jurisdictions.
Southern California Association of Governments Regional Transportation Plan/Sustainable Communities Strategy
On September 3, 2020, the SCAG’s Regional Council formally adopted the 2020–2045 RTP/SCS also known as the Connect SoCal, which is an update to the previous 2016–2040 RTP/SCS.54 Using growth forecasts and economic trends, Connect SoCal provides a vision for transportation throughout the region for the next several decades by considering the role of transportation in the broader context of economic, environmental, and quality-of -life goals for the future, identifying regional transportation strategies to address mobility needs. Connect SoCal describes how the region can attain the GHG emission -reduction targets set by CARB by achieving an 8 percent reduction in per capita transportation GHG emissions by 2020 and a 19 percent reduction in per capita transportation emissions by 2035 compared to the 2005 level on a per capita basis. 55 Compliance with and implementation of Connect SoCal policies and strategies would have co - benefits of reducing per capita criteria air pollutant emissions ( e.g., nitrogen dioxide, carbon monoxide) associated with reduced per capita vehicle miles traveled (VMT).
Connect SoCal states that the SCAG region was home to approximately 18.8 million people in 2016 and included approximately 6.0 million homes and 8.4 million jobs.56 By 2045, the integrated growth forecast estimates that these figures will increase by 3.7 million people, with approximately
1.6 million more homes and 1.7 million more jobs. High-quality transit areas (HQTAs), which are defined by Connect SoCal as generally walkable transit villages or corridors that are within 0.5 miles of a well-serviced transit stop or a transit corridor with 15 -minute or less service frequency during peak commute hours, will account for 2.4 percent of regional total land, but are projected to accommodate 51 percent and 60 percent of future household growth respectively between 2016 and 2045.
57 Connect SoCal overall land use pattern reinforces the trend of focusing new housing and employment in the region’s HQTAs. HQTAs are a cornerstone of land use planning best practice in the SCAG region because they concentrate roadway repair investments, leverage transit and active transportation investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potential to improve public health and housing affordability. Transit Priority Areas
58 (TPAs) will account for less than one percent of regional total land but are projected to accommodate 30 percent of future household growth between 2016 and 2045. Connect SoCal overall land use pattern reinforces the trend of focusing new housing and employment in the region’s TPAs. TPAs are a cornerstone of land use planning best practice in the SCAG region because they concentrate roadway repair investments, leverage transit and active transportation investments, reduce regional life cycle infrastructure costs, improve accessibility, create local jobs, and have the potential to improve public health and housing affordability.
54 SCAG, 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020-2045 RTP/SCS), May 2020.
55 SCAG, Connect SoCal, May 2020.
56 SCAG, Connect SoCal, Demographics and Growth Forecast Technical Report, May 2020. 57 SCAG, Connect SoCal, May 2020, p. 51.
58 Defined by Connect SoCal as generally walkable transit villages or corridors that are within 0.5 mile of a major transit stop (rail or bus rapid transit station) with 15‑minute or less service frequency during peak commute hours
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SCAG’s Connect SoCal provides specific strategies for implementation. These strategies include supporting projects that encourage diverse job opportunities for a variety of skills and education, recreation and cultures and a full-range of shopping, entertainment and services all within a relatively short distance; encouraging employment development around current and planned transit stations and neighborhood commercial centers; encouraging the implementation of a “Complete Streets” policy that meets the needs of all users of the streets, roads and highways including bicyclists, children, persons with disabilities, motorists, electric vehicles, movers of commercial goods, pedestrians, users of public transportation, and seniors; and supporting alternative fueled vehicles. 59 In addition, Connect SoCal include strategies to promote active transportation, support local planning and projects that serve short trips, promote transportation investments, investments in active transportation, more walkable and bikeable communities, that will result in improved air quality and public health, and reduced GHG emissions, and supports building physical infrastructure, regional greenways and first-last mile connections to transit, including to light rail and bus stations. Connect SoCal aligns active transportation investments with land use and transportation strategies, increase competitiveness of local agencies for federal and state funding, and to expand the potential for all people to use active transportation. CARB has accepted the SCAG GH G quantification determinations in Connect SoCal and demonstrates achievement of the GHG emission reduction targets established by CARB.
60,61 To implement SB 375 and reduce GHG emissions by correlating land use and transportation planning, SCAG adopted Connect SoCal in October 2020. The vision for the region incorporates a range of best practices for increasing transportation choices, reducing dependence on personal automobiles, further improving air quality, and encouraging growth in walkable, mixed-use communities with ready access to transit infrastructure and employment. More and varied housing types and employment opportunities would be located in and near job centers, transit stations and walkable neighborhoods where goods and services are easily accessible via shorter trips. To support shorter trips, people would have the choice of using neighborhood bike networks, car share or micro-mobility services like shared bicycles or scooters. For longer commutes, people would have expanded regional transit services and more employer incentives to carpool or vanpool.
Other longer trips would be supported by on- demand services such as microtransit, carshare, and citywide partnerships with ride hailing services. For those that choose to drive, hotspots of congestion would be less difficult to navigate due to cordon pricing and using an electric vehicle will be easier thanks to an expanded regional charging network.
Although there are GHG emission reduction targets for passenger vehicles set by CARB for 2045, Connect SoCal GHG emission reduction trajectory shows that more aggressive GHG emission reductions are projected for 2045. By meeting and exceeding the SB 375 targets for 2020 and 2035, as well as achieving an additional 4.1 percent reduction in GHG from transportation-related sources in the ten years between 2035 and 2045, Connect SoCal is expected to fulfill and exceed its portion of SB 375 compliance with respect to meeting the State’s GHG emission reduction goals. 62 59 SCAG, Connect SoCal, May 2020, pp. 48-86.
60 SCAG, Connect SoCal, May 2020, pp. 48-86.
61 CARB, Southern California Association of Governments’ (SCAG) 2016 Sustainable Communities Strategy (SCS) ARB Acceptance of GHG Quantification Determination, June 2016. 62 SCAG, 2020-2045 RTP/SCS Public Health Technical Report, May 2020, p. 53.
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Local
City of Culver City
The City of Culver City has not adopted a GHG significance threshold; however, the City of Culver City participates in an environmental recognition program, California Green Communities. The program helps cities develop strategies to reduce carbon emissions and increase energy efficiency in their community.
Culver City General Plan
The Circulation Element provides an overview of regulatory policies, transportation agencies, and local conditions; presents a vision for mobility in the Culver City area; presents a Street System Classification; discusses the Culver CityBus system; presen ts Bikeway Classifications; and provides goals, objectives, and policies to improve the local and regional transportation system.
The City of Culver City has also adopted the concept of Complete Streets, which emphasizes a balanced transportation system that considers all users of the road (cyclists, pedestrians, transit riders, and vehicles) while planning development and transportation projects. 63 The goal of this
concept is to transform the City of Culver City into a place with an extensive bicycle and pedestrian network that allows travelers of all levels and abilities to feel comfortable walking and biking to their destinations.
64 Culver City Green Building Ordinance and Program
The City of Culver City has adopted green building ordinances to reduce GHG emissions for new development. The City of Culver City has adopted a Photovoltaic Requirement that requires 1 kilowatt (kw) of photovoltaic power installed per 10,000 square feet (sf) of new development or payment of an in-lieu fee.
65 The developer would comply with CCMC Chapter 15.02.1005 by installing a solar photovoltaic system with 1 kW solar photovoltaic panels per 10,000 sf.
In 2009, the City of Culver City adopted the Green Building Program that requires new developments totaling more than 50,000 sf to achieve Leadership in Energy and Environmental Design (LEED) equivalent certification.
66 An example of the City of Culver City’s Green Building Program requirements is that all lighting has to be either fluorescent, LED or other type of high - efficiency lighting. As stated below in subsection Project Design Features, the Project buildings will be designed to meet the United States Green Building Council (USGBC) LEED Certified performance level or higher and will be designed and operated to meet or exceed the applicable requirements of Culver City’s Green Building Program Requirements.
Culver City's Electric Vehicle (EV) Infrastructure Plan The Culver City EV Infrastructure Plan was developed as a result of Culver City’s participation as one of 18 cities in the SCAG 2020 charging station study where SCAG assisted in developing a citywide EV infrastructure plan.
67 As noted in the City’s Electric Vehicle (EV) Infrastructure Plan,
63 City of Culver City, Culver City Bicycle & Pedestrian Master Plan (BPMP), adopted by City Council, November 8, 2010, p. 8.
64 City of Culver City, BPMP, p. 136.
65 City of Culver City, Municipal Code Chapter 15.02.1005, Solar Photovoltaic Systems. 66 City of Culver City, Municipal Code Chapter 15.02.1100, Green Building Program and Requirements. 67 SCAG, SCAG EV Charging Station Study- Electric Vehicle (EV) Infrastructure Plan – Culver City, February 2023.
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depending on the mix of EV charging station types, Culver City may need between 380 and 1,154 charging stations by 2030 to support statewide goals. The EV Infrastructure Plan aims to assist Culver City to expand its EV charging network as it determines the most suitable sites in Culver City to install EV charging stations and identifies hurdles to installing EV charging stations and develop solutions. Culver’s City’s EV Infrastructure Plan also highlights that while the City will increase EV charging statio ns at publicly owned locations, the majority of EV charging stations will be owned and operated by the private sector. The City with assistance from the City's EV Infrastructure Plan looks to foster private EV development by increasing education and awareness about EVs and EV charging stations; create policies and initiatives that encourage and streamline EV charging stations development, installation, and use; and connect EV and EV charging stations stakeholders to funding resources to reduce upfront costs. 68 Culver City Bicycle & Pedestrian Action Plan
The City of Culver City updated the Bicycle & Pedestrian Master Plan with the Bicycle & Pedestrian Action Plan (Action Plan), which received public input throughout 2017 through 2019.
The Action Plan was adopted by Culver City Council in June 2020. 69 The Action Plan establishes
the visions and values that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network.
Culver City Clean Power Alliance
Clean Power Alliance (CPA) became the new electricity supplier for Culver City in February 2019 for residential customers and in May 2019 for non -residential customers. With this change, CPA purchases the renewable energy resources for electricity, and Southern California Edison (SCE) delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and Ventura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs.
Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent or opt out of the CPA and remain with SCE as their provider.
Greenhouse Gas Background
Global climate change refers to changes in average climatic conditions on Earth as a whole, including changes in temperature, wind patterns, precipitation, and severe weather events. Global warming, a related concept, is the observed increase in average temperature of Earth’s surface and atmosphere. One identified cause of global warming is an increase of GHGs in the atmosphere.
GHGs are those compounds in Earth’s atmosphere that play a critical role in determining Earth’s surface temperature.
Earth’s natural warming process is known as the “greenhouse effect.” It is called the greenhouse effect because Earth and the atmosphere surrounding it are similar to a greenhouse with glass panes in that the glass allows solar radiation (sunlight) into Earth’s atmosphere but prevents radiative heat
68 SCAG, SCAG EV Charging Station Study- Electric Vehicle (EV) Infrastructure Plan – Culver City, February 2023. 69 City of Culver City, Bicycle & Pedestrian Action Plan, June 2020.
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from escaping, thus warming Earth’s atmosphere. Some levels of GHGs keep the average surface temperature of Earth close to a hospitable 60 degrees Fahrenheit. However, as GHG from human activities increase, they build up in the atmosphere and warm the clim ate, leading to many other changes around the world - in the atmosphere, on land, and in the oceans, with associated adverse climatic and ecological consequences.
70 Scientists studying the particularly rapid rise in global temperatures have determined that human activity has resulted in increased emissions of GHGs, primarily from the burning of fossil fuels (from motor vehicle travel, electricity generation, consumption of natural gas, industrial activity, manufacturing, etc.), deforestation, agricultural activity, and the decomposition of solid waste.
Scientists refer to the global warming context of the past century as the “enhanced greenhouse effect” to distinguish it from the natural greenhouse effect. 71 Global GHG emissions due to human activities have grown since pre-industrial times. As reported by the USEPA, global carbon emissions from fossil fuels increased by over 16 times between 1900 and 2008 and by about 43 percent between 1990 and 2015. In addition, in the Global Carbon Budget 2022 report, published in November 2022, atmospheric CO 2 concentrations in 2022 were found to
be more than 50 percent above the concentration at the start of the Industrial Revolution, and the present concentration is the highest during at least the last 800,000 years.72 Global increases in CO2 concentrations are due primarily to fossil fuel use, with land use change providing another significant but smaller contribution. Regarding emissions of non-CO 2 GHGs, these have also
increased significantly since 1990.73 In particular, studies have concluded that it is very likely that the observed increase in methane (CH4) concentration is predominantly due to agriculture and fossil fuel use.74
In August 2007, international climate talks held under the auspices of the United Nations Framework Convention on Climate Change led to the official recognition by the participating nations that global emissions of GHG must be reduced. According to the “Ad Hoc Working Group on Further Commitments of Annex I Parties under the Kyoto Protocol,” avoiding the most catastrophic events forecast by the United Nations IPCC would entail emissions reductions by industrialized countries in the range of 25 to 40 percent below 1990 levels. Because of the Kyoto Protocol’s Clean Development Mechanism, which gives industrialized countries credit for financing emission-reducing projects in developing countries, such an emissions goal in industrialized countries could ultimately spur efforts to cut emissions in developing countries as well.
75 70 United States Environmental Protection Agency (USEPA), Climate Change Indicators: Greenhouse Gases, https://www.epa.gov/climate-indicators/greenhouse-gases. Accessed September 25, 2023. 71 Pew Center on Global Climate Change, Climate Change 101: Understanding and Responding to Global Climate Change.
72 P. Friedlingstein et al.: Global Carbon Budget 2020, 2020. 73 USEPA, Global Greenhouse Gas Emissions Data, www.epa.gov/ghgemissions/global-greenhouse-gas-emissions- data. Accessed September 25, 2023.
74 USEPA, Climate Change Indicators: Atmospheric Concentrations of Greenhouse Gas, updated April 2021. 75 United Nations Framework Convention on Climate Change, Press Release—Vienna UN Conference Shows Consensus on Key Building Blocks for Effective International Response to Climate Change, August 31, 2007.
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In December 2015, the US entered into the Paris Agreement which has a goal of keeping a global temperature rise this century below 2 degrees Celsius above pre-industrial levels and limit the temperature increase further to 1.5 degrees Celsius. This agreement requires that all parties report regularly on emissions and implementation efforts to achieve these goals.
Regarding the adverse effects of global warming, as reported by SCAG:
Global warming poses a serious threat to the economic well-being, public health and natural environment in southern California and beyond. The potential adverse impacts of global warming include, among others, a reduction in the quantity and quality of water supply, a rise in sea level, damage to marine and other ecosystems, and an increase in the incidences of infectious diseases. Over the past few decades, energy intensity of the national and state economy has been declining due to the shift to a more service-oriented economy. California ranked fifth lowest among the states in CO
2 e missions from fossil fuel consumption per unit of Gross State Product. However, in terms of total CO 2 emissions, California is second only to Texas in the nation and is the 12th largest source of climate change emissions in the world, exceeding most nations. The SCAG region, with close to half of the state’s population and economic activities, is also a major contributor to the global warming problem.
76 Greenhouse Gas Fundamentals
GHGs are those compounds in the Earth’s atmosphere that play a critical role in determining temperature near the Earth’s surface. GHGs include CO 2, CH 4, nitrous oxide (N 2O), hydrofluorocarbons (HFCs), perfluorocarbons (PFCs), sulfur hexafluoride (SF 6), and nitrogen trifluoride (NF3).77 More specifically, these gases allow high -frequency shortwave solar radiation to enter the Earth’s atmosphere, but retain some of the low frequency infrared energy, which is radiated back from the Earth towards space, resulting in a warming of the atmosphere. Compounds that are regulated as GHGs are discussed in Table 4.6-3, Description of Identified GHGs. 78,79
Not all GHGs possess the same ability to induce climate change. CO 2 is the most abundant GHG in Earth's atmosphere. Other GHGs are less abundant but have higher global warming potential (GWP) than CO
2. Thus, emissions of other GHGs are commonly quantified in the units of equivalent mass of CO2 (CO2e). GWP is based on several factors, including the radiative efficiency (heat-absorbing ability) of each gas relative to that of CO 2, as well as the decay rate of each gas (the amount removed from the atmosphere over a given number of years otherwise referred to as atmospheric lifetime) relative to that of CO
2. 76 Southern California Associated of Governments (SCAG), The State of the Region—Measuring Regional Progress , December 2006, p. 121.
77 As defined by California Assembly Bill (AB) 32 and Senate Bill (SB) 104. 78 Intergovernmental Panel on Climate Change (IPCC), Second Assessment Report, Working Group I: The Science of Climate Change, 1995.
79 IPCC, Fourth Assessment Report, Working Group I Report: The Physical Science Basis, Table 2.14, 2007.
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TABLE 4.6-3
DESCRIPTION OF IDENTIFIED GHGS
GHG General Description
Carbon Dioxide (CO2) An odorless, colorless GHG, which has both natural and anthropocentric sources. Natural sources include the following: decomposition of dead organic matter; respiration of bacteria, plants, animals, and fungus; evaporation from oceans; and volcanic outgassing.
Anthropogenic (human-caused) sources of CO
2 are burning coal, oil, natural gas, and wood.
Methane (CH4) A flammable gas and the main component of natural gas. When one molecule of CH4 is burned in the presence of oxygen, one molecule of CO2 and two molecules of water are released. A natural source of CH4 is the anaerobic decay of organic matter. Geological deposits, known as natural gas fields, also contain CH4, which is extracted for fuel. Other sources are from landfills, fermentation of manure, and cattle.
Nitrous Oxide (N2O) A colorless GHG. High concentrations can cause dizziness, euphoria, and sometimes slight hallucinations. N2O is produced by microbial processes in soil and water, including those reactions which occur in fertilizer containing nitrogen. In addition to agricultural sources, some industrial processes (fossil fuel-fired power plants, nylon production, nitric acid production, and vehicle emissions) also contribute to its atmospheric load. It is used in rocket engines, race cars, and as an aerosol spray propellant.
Hydrofluorocarbons
(HFCs)
Chlorofluorocarbons (CFCs) are gases formed synthetically by replacing all hydrogen atoms in CH
4 or ethane (C2H6) with chlorine and/or fluorine atoms. CFCs are non-toxic, non-flammable, insoluble, and chemically unreactive in the troposphere (the level of air at Earth’s surface).
CFCs were first synthesized in 1928 for use as refrigerants, aerosol propellants, and cleaning solvents. Because they destroy stratospheric ozone, the production of CFCs was stopped as required by the Montreal Protocol in 1987. HFCs are synthetic man-made chemicals that are used as a substitute for CFCs as refrigerants. HFCs deplete stratospheric ozone, but to a much lesser extent than CFCs.
Perfluorocarbons
(PFCs)
PFCs have stable molecular structures and do not break down through the chemical processes in the lower atmosphere. High-energy ultraviolet rays about 60 kilometers above Earth’s surface are able to destroy the compounds. PFCs have very long lifetimes, between 10,000 and 50,000 years. Two common PFCs are tetrafluoromethane and hexafluoroethane. The two main sources of PFCs are primary aluminum production and semi-conductor manufacturing.
Sulfur Hexafluoride
(SF
6)
An inorganic, odorless, colorless, non-toxic, and non-flammable gas. SF6 is used for insulation in electric power transmission and distribution equipment, in the magnesium industry, in semi- conductor manufacturing, and as a tracer gas for leak detection.
Nitrogen Trifluoride
(NF
3)
An inorganic, non-toxic, odorless, non-flammable gas. NF3 is used in the manufacture of semi- conductors, as an oxidizer of high energy fuels, for the preparation of tetrafluorohydrazine, as an etchant gas in the electronic industry, and as a fluorine source in high power chemical lasers.
NOTE: GHGs identified in this table are ones identified in the Kyoto Protocol and other synthetic gases recently added to the IPCC’s Fifth Assessment Report.
SOURCES: Association of Environmental Professionals, Alternative Approaches to Analyze Greenhouse Gas Emissions and Global Climate Change in CEQA Documents, Final, June 29, 2007; U.S. Environmental Protection Agency, Acute Exposure Guideline Levels (AEGLs) for Nitrogen Trifluoride; January 2009.
The larger the GWP, the more that a given gas warms the Earth compared to CO2 over that time.80 These GWP ratios are available from IPCC. Historically, GHG emission inventories have been calculated using the GWPs from the IPCC’s SAR. The IPCC updated the GWP values in its AR4.
The GWPs in the IPCC AR4 are used by CARB for reporting statewide GHG emi ssions inventories, consistent with international reporting standards. By applying the GWP ratios, Project-
80 GWPs and associated CO2e values were developed by IPCC and published in its Second Assessment Report (SAR) in 1996. Historically, GHG emission inventories have been calculated using the GWPs from the IPCC’s SAR. The IPCC updated the GWP values based on the latest science in its Fourth Assessment Report (AR4). CARB has begun reporting GHG emission inventories for California using the GWP values from the IPCC AR4.
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related CO 2e emissions can be tabulated in metric tons per year. Typically, the GWP ratio corresponding to the warming potential of CO2 over a 100-year period is used as a baseline.
The IPCC has issued an updated Fifth Assessment Report (AR5), which has reduced down the majority of the GWP for key regulated pollutants. As CARB still uses AR4 values and the modeling software California Emissions Estimator Model (CalEEMod) is built on these assumptions, AR4 GWP values are used for the Project. Generally, the changes from AR4 to AR5 are reductions in warming potential for the GHG most associated with construction and operation of typical development projects. The GWP from AR4 and AR5 and atmospheric lifetimes for key regulated GHGs are provided in Table 4.6-4, Atmospheric Lifetimes and GWPs.
TABLE 4.6-4
ATMOSPHERIC LIFETIMES AND GWPS
Gas
Atmospheric
Lifetime
(Years)
GWP
(100-Year
Time Horizon)
(AR4 Assessment)
GWP
(100-Year
Time Horizon)
(AR5 Assessment)
Carbon Dioxide (CO2) 50-200 1 1
Methane (CH4) 12 (+/-3) 25 28
Nitrous Oxide (N2O) 114 298 265
HFC-23: Fluoroform (CHF3) 270 14,800 12,400
HFC-134a: 1,1,1,2-Tetrafluoroethane (CH2FCF3) 14 1,430 1,300 HFC-152a: 1,1-Difluoroethane (C2H4F2) 1.4 124 138
PFC-14: Tetrafluoromethane (CF4) 50,000 7,390 6,630
PFC-116: Hexafluoroethane (C2F6) 10,000 12,200 11,100
Sulfur Hexafluoride (SF6) 3,200 22,800 23,500
Nitrogen Trifluoride (NF3) 740 17,200 16,100
SOURCE: IPCC, Climate Change 2007: Working Group I: The Physical Science Basis, Direct Global Warming Potentials.
Projected Impacts of Global Warming in California
In 2009, California adopted a statewide Climate Adaptation Strategy (CAS) that summarizes climate change impacts and recommends adaptation strategies across seven sectors: Public Health, Biodiversity and Habitat, Oceans and Coastal Resources, Water, Agricu lture, Forestry, and Transportation and Energy. The CNRA updated the CAS in 2018 in a strategy called Safeguarding California and again in 2021. The 2021 CAS’s goal is to drive collective action moving forward through six main priorities: Strengthen Protections for Climate Vulnerable Communities, Bolster Public Health and Safety to Protect Against Increasing Climate Risks, Building a Climate Resilient Economy, Accelerate Nature-Based Climate Solutions and Strengthen Climate Resilience of Natural Systems, Make Decisions Based on the Best Available Climate Science, Partner and Collaborate to Leverage Resources.
81 81 California Natural Resources Agency, California Climate Adaptation Strategy, https://resources.ca.gov/Initiatives/Building-Climate-Resilience/2021-State-Adaptation-Strategy-Update. Accessed September 25, 2023.
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The Natural Resources Agency has also produced climate change assessments which detail impacts of global warming in California.82 These include:
• Sea level rise, coastal flooding and erosion of California’s coastlines would increase, as well as sea water intrusion.
• The Sierra snowpack would decline between 70 and 90 percent, threatening California’s water supply.
• Higher risk of forest fires resulting from increasing temperatures and making forests and brush drier. Climate change will affect tree survival and growth. • Attainment of air quality standards would be impeded by increasing emissions, accelerating chemical processes, and raising inversion temperatures during stagnation episodes resulting in public health impacts.
• Habitat destruction and loss of ecosystems due to climate change affecting plant and wildlife habitats.
• Global warming can cause drought, warmer temperatures and saltwater contamination resulting in impacts to California’s agricultural industry.
With regard to public health, as reported by the Center for Health and the Global Environment at the Harvard Medical School, the following are examples of how climate change can affect cardio- respiratory disease: (1) pollen is increased by higher levels of atmospheric CO 2; (2) heat waves can
result in temperature inversions, leading to trapped masses or unhealthy air contaminants by smog, particulates, and other pollutants; and (3) the incidence of forest fires is increased by drought secondary to climate change and to the lack of spring runoff from reduced winter snows. These fires can create smoke and haze, which can settle over urban populations causing acute and exacerbating chronic respiratory illness.
83 Effects of Global Climate Change
The scientific community’s understanding of the fundamental processes responsible for global climate change has improved over the past decade, and its predictive capabilities are advancing.
However, there remain significant scientific uncertainties in, for example, predictions of local effects of climate change, occurrence, frequency, and magnitude of extreme weather events, effects of aerosols, changes in clouds, shifts in the intensity and distribution of precipitation, and changes in oceanic circulation. Due to the complexity of the Earth’s climate system and inability to accurately model it, the uncertainty surrounding climate change may never be completely eliminated. Nonetheless, the IPCC’s Fifth Assessment Report, Summary for Policy Makers states that, “it is extremely likely that more than half of the observed increase in global average surface temperature from 1951 to 2010 was caused by the anthropogenic increase in GHG concentrations and other anthropogenic forces [sic] together.”
84 A report from the National Academy of Sciences
82 State of California, Department of Justice, Office of the Attorney General, Climate Change Impacts in California, https://oag.ca.gov/environment/impact. Accessed September 25, 2023. 83 Paul R. Epstein, et al., Urban Indicators of Climate Change, Report from the Center for Health and the Global Environment, (Harvard Medical School and the Boston Public Health Commission, August 2003), unpaginated. 84 IPCC, Climate Change 2014: Synthesis Report, Contribution of Working Groups I, II and III to the Fifth Assessment Report of the Intergovernmental Panel on Climate Change, Summary for Policy Makers, 2014, p. 5, http://ipcc.ch/report/ar5/syr/. Accessed September 25, 2023.
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concluded that 97 to 98 percent of the climate researchers most actively publishing in the field support the tenets of the IPCC in that climate change is very likely caused by human (i.e., anthropogenic) activity.
85 According to the CalEPA, the potential impacts in California due to global climate change may include: loss in snow pack; sea level rise; more extreme heat days per year; more high ozone days; more large forest fires; more drought years; increased erosion of California’s coastlines and sea water intrusion into the Sacramento and San Joaquin Deltas and associated levee systems; and increased pest infestation.
86 Data regarding potential future climate change impacts are available from CNRA, which in 2009 published the California Climate Adaptation Strategy 87 as a response to Executive Order S-13-2008. The CNRA report lists specific recommendations for state and local agencies to best adapt to the anticipated risks posed by a changing climate. In accordance with the California Climate Adaptation Strategy, the California Energy Commission (CEC) was directed to develop a website on climate change scenarios and impacts that would be beneficial for local decision makers.
88 The website, known as Cal -Adapt, became operational in 2011. 89 The information provided by the Cal -Adapt website represents a projection of potential future climate scenarios. The data are comprised of the average values from a variety of scenarios and models and are meant to illustrate how the climate may change based on a variety of different potential social and economic factors. Below is a summary of some of the potential climate change effects and relevant Cal-Adapt data, reported by an array of studies that could be experienced in California as a result of global warming and climate change.
Air Quality
Higher temperatures, conducive to air pollution formation, could worsen air quality in California.
Climate change may increase the concentration of ground-level ozone, but the magnitude of the effect, and therefore, its indirect effects, are uncertain. If higher temperatures are accompanied by drier conditions, the potential for large wildfires could increase, which, in turn, would further worsen air quality. However, if higher temperatures are accompanied by wetter, rather than drier conditions, the rains would tend to temporarily clear the air of particulate pollution and reduce the incidence of large wildfires, thus ameliorating the pollution associated with wildfires. Additionally, severe heat accompanied by drier conditions and poor air quality could increase the number of heat- related deaths, illnesses, and asthma attacks throughout the State. 90 According to the Cal -Adapt website’s “Local Climate Change Snapshot” database, the Project location could see an average annual increase in maximum temperature to 73.9 to 74.7°F in the mid-century (2035–2064) and 74.9 to 77.8°F at the end of the century (2070– 2099) compared to
85 Anderegg, William R. L., J.W. Prall, J. Harold, S.H., Schneider, Expert Credibility in Climate Change, Proceedings of the National Academy of Sciences of the United States of America, 2010, 107:12107-12109. 86 California Environmental Protection Agency (CalEPA), Climate Action Team (CAT), Climate Action Team Report to Governor Schwarzenegger and the Legislature, 2006.
87 California Natural Resources Agency (CNRA), CAT, 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008, 2009. 88 CNRA, CAT, 2009 California Climate Adaptation Strategy: A Report to the Governor of the State of California in Response to Executive Order S-13-2008.
89 The Cal-Adapt website: http://cal-adapt.org. Accessed September 25, 2023. 90 California Energy Commission (CEC), Scenarios of Climate Change in California: An Overview, February 2006.
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71.0°F for the baseline period (1961–1990). The average annual number of extreme heat days also could increase to 4 to 5 days in the mid-century (2035–2064) and 6 to 14 days at the end of the century (2070–2099) compared to 2 days for the baseline period (1961–1990).91 Water Supply
Uncertainty remains with respect to the overall impact of global climate change on future water supplies in California. Studies have found that, “Considerable uncertainty about precise impacts of climate change on California hydrology and water resources will remain until we have more precise and consistent information about how precipitation patterns, timing, and intensity will change.” 92 For example, some studies identify little change in total annual precipitation in projections for California while others show significantly more precipitation. 93 Warmer, wetter winters would
increase the amount of runoff available for groundwater recharge; however, this additional runoff would occur at a time when some basins are either being recharged at their maximum capacity or are already full.
94 Conversely, reductions in spring runoff and higher evapotranspiration because of higher temperatures could reduce the amount of water available for recharge.95 According to the Cal -Adapt website’s “Local Climate Change Snapshot” database, the Project location could see an average annual length of dry spells of 170 to 172 days in the mid -century (2035–2064) and 171 to 178 days at the end of the century (2070– 2099), compared to 163 days for the baseline period (1961 –1990). The average annual precipitation could decrease to 13.7 to
13.8 inches in the mid -century (2035– 2064) and potentially increase or decrease to 14.1 to
13.9 inches at the end of the century (2070–2099), compared to 14.0 inches for the baseline period (1961–1990).
The California Department of Water Resources report on climate change and effects on the State Water Project (SWP), the Central Valley Project, and the Sacramento-San Joaquin Delta, concludes that “climate change will likely have a significant effect on California’s future water resources…[and] future water demand.” It also reports that “much uncertainty about future water demand [remains], especially [for] those aspects of future demand that will be directly affected by climate change and warming. While climate change is expected to continue through at least the end of this century, the magnitude and, in some cases, the nature of future changes is uncertain.” It also reports that the relationship between climate change and its potential effect on water demand is not well understood, but “[i]t is unlikely that this level of uncertainty will diminish significantly in the foreseeable future.” Still, changes in water supply are expected to occur, and many regional studies have shown that large changes in the reliability of water yields from reservoirs could result from only small changes in inflows.
96 In its AR5, the IPCC states “Changes in the global water cycle in
91 The Cal-Adapt website: http://cal-adapt.org. Accessed September 25, 2023. 92 Pacific Institute for Studies in Development, Environment and Security, Climate Change and California Water Resources: A Survey and Summary of the Literature, July 2003. 93 Pacific Institute for Studies in Development, Environment and Security, Climate Change and California Water Resources: A Survey and Summary of the Literature, July 2003. 94 Pacific Institute for Studies in Development, Environment and Security, Climate Change and California Water Resources: A Survey and Summary of the Literature, July 2003. 95 Pacific Institute for Studies in Development, Environment and Security, Climate Change and California Water Resources: A Survey and Summary of the Literature, July 2003. 96 California Department of Water Resources, Climate Change Report, Progress on Incorporating Climate Change into Planning and Management of California’s Water Resources, July 2006.
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response to the warming over the 21st century will not be uniform. The contrast in precipitation between wet and dry regions and between wet and dry seasons will increase, although there may be regional exceptions.”
97 Hydrology and Sea Level Rise
As discussed above, climate changes could potentially affect: the amount of snowfall, rainfall and snowpack; the intensity and frequency of storms; flood hydrographs (flash floods, rain or snow events, coincidental high tide and high runoff events); sea level rise and coastal flooding; coastal erosion; and the potential for saltwater intrusion. Sea level rise can be a product of global warming through two main processes: expansion of seawater as the oceans warm and melting of ice over land.
Absent planning and preparation, a rise in sea levels could result in coastal flooding and erosion and could jeopardize California’s water supply, and increased storm intensity and frequency could affect the ability of flood-control facilities, including levees, to handle storm events.
Agriculture
California has a $30 billion agricultural industry that produces one half of the country’s fruits and vegetables. Higher CO
2 levels can stimulate plant production and increase plant water -use efficiency. However, if temperatures rise and drier conditions prevail, water demand could increase; without planning and preparations. Crop yield could be threatened by a less reliable water supply. Also, greater ozone pollution could render plants more susceptible to pest and disease outbreaks. In addition, temperature increases could change the time of year certain crops, such as wine grapes, bloom or ripen, and thus affect their quality. 98 Ecosystems and Wildlife
Increases in global temperatures and the potential resulting changes in weather patterns could have ecological effects on a global and local scale. Increasing concentrations of GHGs are likely to accelerate the rate of climate change. Scientists expect that the average global surface temperature could rise by 2 to 11.5°F (1.1 to 6.4°C) by 2100, with significant regional variation. 99 Soil moisture
is likely to decline in many regions, and intense rainstorms are likely to become more frequent. Sea level could rise as much as 2 feet along most of the U.S. coast. Rising temperatures could have four major impacts on plants and animals: (1 ) timing of ecological events; (2) geographic range; (3) species’ composition within communities; and (4) ecosystem processes such as carbon cycling and storage.
100,101
97 IPCC, Fifth Assessment Report, Summary for Policy Makers, p. 20. 98 California Climate Change Center, Our Changing Climate: Assessing the Risks to California, 2006. 99 National Research Council, Advancing the Science of Climate Change, 2010. 100 Parmesan, C., Ecological and Evolutionary Response to Recent Climate Change, first published on August 24, 2006. 101 Parmesan, C. and Galbraith, H., Observed Ecological Impacts of Climate Change in North America. Arlington, VA: Pew. Cent. Glob. Clim. Change, 2004.
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Existing Conditions
GHG Emissions Inventory
CARB is responsible for the coordination and administration of both federal and State air pollution control programs within California. CARB compiles GHG inventories for the State of California.
The most updated inventory reports the State’s GHG emissions inventory from calendar year 2020.
Based on the 2020 GHG inventory data (i.e., the latest year for which data are available from CARB), California emitted 369.2 MMTCO
2e including emissions resulting from imported
electrical power.102 Between April 2010 and July 2020, the population of California grew by an annualized rate of 0.64 percent to a total of 39.78 million.103 In addition, the carbon intensity of California’s economy (the amount of carbon pollution per million dollars of gross domestic product (GDP)) is declining. The California economy, measured as gross state product, grew from $773 billion in 1990 to $3.4 trillion in 2021 representing an increase of over three times the 1990 gross state product.
104 California’s economy, as with most of the country, experienced a decline in gross state product in 2020 ($3.0 trillion) due to the COVID -19 pandemic. Despite the population and economic growth experienced in 2021, California’s net GHG emissions were reduced to below 1990 levels in 2020.
105 According to CARB, as of 2016, statewide GHG emissions dropped below the 2020 GHG Limit (431 MMTCO2e) and have remained below this limit since that time.
Table 4.6-5, State of California GHG Emissions, identifies and quantifies statewide anthropogenic GHG emissions and sinks (e.g., carbon sequestration due to forest growth) in 1990 and 20 20. As shown in the table, the transportation sector is the largest contributor to statewide GHG emissions at approximately 37 percent in 2020.
Existing Site GHG 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. GHG emissions are currently associated with vehicle trips to and from the existing Project Site, landscaping equipment, on-site combustion of natural gas for heating, off- site combustion of fossil fuels for electricity, and off-site emissions from solid waste decomposition, water conveyance, and wastewater treatment. GHG emissions are estimated using CalEEMod (Version 2022.1.1), which is a Statewide land use emissions computer model designed to provide a uniform platform for government agencies, land use planners, and environmental professional s to quantify potential criteria pollutant and GHG emissions from a variety of land use projects.
102 CARB, California Greenhouse Gas Emissions for 2000–2020 – by Category as Defined in the 2008 Scoping Plan, October 26, 2022.
https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/ghg_inventory_scopingplan_sum_2000-20.pdf.
Accessed October 2022.
103 California Department of Finance, "E-6. Population estimates and components of change by county 2010–2020," 2020, December. http://www.dof.ca.gov/Forecasting/Demographics/Estimates/E-6/. Accessed October 2022. 104 California Department of Finance, Gross State Product, 2021, https://dof.ca.gov/Forecasting/Economics/economic- indicators/gross-state-product/. Accessed December2022. Amounts are based on current dollars as of May 2022. 105 California Department of Finance, Gross State Product, 2021, https://dof.ca.gov/Forecasting/Economics/economic- indicators/gross-state-product/. Accessed January 2023. Amounts are based on current dollars as of May 2022.
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TABLE 4.6-5
STATE OF CALIFORNIA GHG EMISSIONS
Category
Total 1990
Emissions
(MMTCO2e)
Percent of
Total 1990
Emissions
Total 2020
Emissions
(MMTCO2e)
Percent of
Total 2020
Emissions
Transportation 150.7 35% 135.8 36.8%
Electric Power 110.6 26% 59.5 16.1%
Commercial 14.4 3% 11.6 3.6%
Residential 29.7 7% 25.3 6.8%
Industrial 103.0 24% 73.3 19.9%
Recycling and Wastea – – 8.9 2.4%
High GWP/Non-Specifiedb 1.3 <1% 21.3 5.8%
Agriculture/Forestry 23.6 6% 31.6 8.6%
Forestry Sinksc -6.7 – – –
Net Total (IPCC SAR)d 426.6 100% 369.2 100%
Net Total (IPCC AR4)e 431 100% 135.8 36.8%
NOTES:
a Included in other categories for the 1990 emissions inventory. b High Global Warm Potential (GWP) gases are not specifically called out in the 1990 emissions inventory. c Forestry sinks were not calculated for 2020 pending a revised methodology under development. Forestry sinks are ecosystem carbon stored in plants and soils.
d IPCC = Intergovernmental Panel on Climate Change
e CARB revised the State’s 1990 level GHG emissions using GWPs from the IPCC AR4.
SOURCE: CARB, California Air Resources Board, California Greenhouse Gas Emissions for 2000 to 2020. Trends of Emissions and Other Indicators. October 26, 2022. https://ww2.arb.ca.gov/sites/default/files/classic/cc/inventory/2000-2020_ghg_inventory_trends.pdf.
Accessed January 2023.
CalEEMod was developed in collaboration with the air districts of California. Regional data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California air districts to account for local requirem ents and conditions. The model is considered to be an accurate and comprehensive tool for quantifying air quality and GHG impacts from land use projects throughout California.
106 CalEEMod was used to estimate existing site GHG
emissions from energy, refrigerants solid waste, water and wastewater, and landscaping equipment.
Mobile source emissions estimates were calculated outside of CalEEMod and were based on CARB’s 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. 107 Existing operational emissions
for the Project Site are presented in Table 4.6-6, Estimated Existing Project Site GHG Emissions.
Details regarding the calculation of the existing Project Site emissions are provided in Appendix C of this Draft EIR. The emissions from existing conditions will be subtracted from Project emissions and net emissions will be presented.
106 See: http://www.caleemod.com.
107 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.
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TABLE 4.6-6
ESTIMATED EXISTING PROJECT SITE GHG EMISSIONS
Emissions Sources Project CO2e (Metric Tons per Year)a,b Existing Operational
On Road Mobile Sources 286
Area (landscaping) 1
Energy (electricity and natural gas) 110
Water Conveyance and Wastewater Treatment 5
Solid Waste 7
Existing Total Emissions 409
a Totals may not add up exactly due to rounding in the modeling calculations b CO2e emissions are calculated using the global warming potential values from the IPCC AR4. Although the IPCC has released AR5 with updated GWPs, CARB reports the Statewide GHG inventory using the AR4 GWPs, which is consistent with international reporting standards.
SOURCE: ESA, 2023.
4.6.3 Project Impacts
Thresholds of Significance
The following thresholds of significance are based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would have a significant impact related to GHG emissions if it would:
• GHG-1: Generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment; or
• GHG-2: Conflict with any applicable plan, policy or regulation adopted for the purpose of reducing the emissions of GHGs.
Amendments to Section 15064.4 of the CEQA Guidelines were adopted to assist lead agencies in determining the significance of the impacts of GHG emissions. Consistent with existing CEQA practice, CEQA Guidelines Section 15064.4 gives lead agencies the discr etion to determine whether to assess those emissions quantitatively or qualitatively. If a qualitative analysis is used, in addition to quantification, this section recommends certain qualitative factors that may be used in the determination of significance (i.e., extent to which the project may increase or reduce GHG emissions compared to the existing environment; whether the project exceeds an applicable significance threshold; and extent to which the project complies with regulations or requirements adopted to implement a reduction or mitigation of GHGs). The amendments do not establish a threshold of significance; rather, lead agencies are granted discretion to establish significance thresholds for their respective jurisdictions, including looking to thresholds developed by other public agencies, or suggested by other experts, such as the California Air Pollution Control Officers Association (CAPCOA), so long as any threshold chosen is supported by substantial evidence (see CEQA Guidelines Section 15064.7(c)). The CNRA has also clarified that the CEQA Guidelines amendments focus on the effects of GHG emissions as cumulative impacts, and that they should
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be analyzed in the context of CEQA’s requirements for cumulative impact analysis (see CEQA Guidelines Section 15064(h)(3)).108
Although GHG emissions can be quantified, CARB, SCAQMD, and the City of Culver City have not adopted project-level significance thresholds for GHG emissions that would be applicable to the Project. The OPR released a technical advisory on CEQA and climate change that provided some guidance on assessing the significance of GHG emissions, and states that “lead agencies may undertake a project-by-project analysis, consistent with available guidance and current CEQA practice,” and that while “climate change is ultimately a cumulative impact, not every individual project that emits GHGs must necessarily be found to contribute to a significant cumulative impact on the environment.” 109
Furthermore, the technical advisory states that “CEQA authorizes reliance on previously approved plans and mitigation programs that have adequately analyzed and mitigated GHG emissions to a less than significant level as a means to avoid or substantially reduce the cumulative impact of a project.” 110
Per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project would comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of the project 111. To qualify, such a plan
or program must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency.
112 Examples of such programs include a “water
quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, [and] plans or regulations for the reduction of GHG emissions.”
113 Thus, CEQA Guidelines Section 15064(h)(3) allows a lead agency to make a finding of non-significance for GHG emissions if a project complies with a program and/or other regulatory schemes to reduce GHG emissions.
In the absence of any adopted, quantitative threshold, the Project would not have a significant effect on the environment if the Project is found to be consistent with the applicable regulatory plans and policies to reduce GHG emissions, including the emissions reduction measures discussed within CARB’s Climate Change Scoping Plan, Connect SoCal, and City of Culver City’s plans, programs, and policies including Culver City’s Green Building Program established for the purpose of increasing energy efficiency and reducing GHG emissions for new developments.
SCAQMD Thresholds
As discussed above, SCAQMD has an interim GHG significance threshold of 10,000 MTCO2e per year for stationary source/industrial projects where SCAQMD is the lead agency. This SCAQMD
108 See generally CNRA, Final Statement of Reasons for Regulatory Action (December 2009), pp. 11-13, 14, 16; see also Letter from Cynthia Bryant, Director of the OPR to Mike Chrisman, Secretary for Natural Resources, April 13, 2009. 109 Governor’s OPR, Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, 2008. 110 Governor’s OPR, Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, 2008. 111 CCR, Title 14, Section 15064(h)(3).
112 CCR, Title 14, Section 15064(h)(3).
113 CCR, Title 14, Section 15064(h)(3).
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interim GHG significance threshold is not applicable to the Project because it is a mixed -use residential and commercial project, and the City is the Lead Agency.
Methodology
Project GHG Emissions Estimates
For informational purposes, the analysis also calculates the amount of GHG emissions that would be attributable to the Project using recommended air quality models, as described below. The primary purpose of quantifying the Project’s GHG emissions is to satisfy CEQA Guidelines Section 15064.4(a), which requires a good-faith effort by the lead agency to describe and calculate emissions. The estimated emissions inventory is also used to determine if there would be a reduction in the Project’s incremental contribution of GHG emissions as a result of compliance with regulations and requirements adopted to implement plans for the reduction or mitigation of GHG emissions. The significance of the Project’s GHG emissions impacts is not based on the amount of GHG emi ssions resulting from the Project and is evaluated solely on the basis of consistency with GHG reduction plans, policies, and regulations.
The Climate Action Registry General Reporting Protocol provides procedures and guidelines for calculating and reporting GHG emissions from general and industry -specific activities. Although no numerical thresholds of significance have been adopted, and no specific protocols are available for land use projects, the General Reporting Protocol provides a framework for calculating and reporting GHG emissions from the Project. The GHG emissions provided in this report are consistent with the General Reporting Protocol framework. For the purposes of this Draft EIR, total GHG emissions (i.e., construction and operation) from the Project were quantified to provide information to decision makers and the public regarding the level of the Project’s annual GHG emissions. GHG emissions are typically separated into three categories that reflect different aspects of ownership or control over emissions:
• Scope 1: Direct, on -site and off -site combustion of fossil fuels (e.g., natural gas, propane, gasoline, diesel, and transportation fuels).
• Scope 2: Indirect, off-site emissions associated with purchased electricity or purchased steam. • Scope 3: Indirect emissions associated with other emissions sources, such as third -party vehicles and embodied energy.
114
CARB recommends consideration of indirect emissions to provide a more complete picture of the GHG footprint of a facility: “As facilities consider changes that would affect their emissions – addition of a cogeneration unit to boost overall efficiency even as it increases direct emissions, for example – the relative impact on total (direct plus indirect) emissions by the facility should be monitored. Annually reported indirect energy usage also aids the conservation awareness of the facility and provides information” to CARB to be considered for future strategies by the industrial sector.
115 For these reasons, CARB has proposed requiring the calculation of direct and indirect
114 Embodied energy includes energy required for water pumping and treatment for end-uses. 115 California Air Resources Board, Staff Report: Initial Statement of Reasons for Rulemaking, Revisions to the Regulation for Mandatory Reporting of Greenhouse Gas Emissions Pursuant to the California Global Warming Solutions Act of 2006 (AB 32), 2010, page 27.
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GHG emissions as part of the AB 32 reporting requirements. Additionally, OPR directs lead agencies to “make a good -faith effort, based on available information, to calculate, model, or estimate…GHG emissions from a project, including the emissions associated with vehicular traffic, energy consumption, water usage and construction activities.” 116 Therefore, direct and indirect
emissions have been calculated for the Project.
A fundamental challenge in the analysis of GHG emissions is the global nature of the existing and cumulative future conditions. Changes in GHG emissions can be difficult to attribute to a particular project because the project may cause a shift in the locale for some type of GHG emissions, rather than simply causing “new” GHG emissions. As a result, there is a lack of clarity as to whether a project’s GHG emissions represent a net global increase, reduction, or no change in GHGs that would exist if the project were not implemented. Therefore, the analysis of the Project’s GHG emissions is conservative in that it assumes all of the GHG emissions are new additions to the atmosphere.
For purposes of this analysis, it was considered reasonable, and consistent with criteria pollutant calculations, to consider GHG emissions resulting from direct Project -related activities, including use of vehicles, and natural gas, to be new emissions. These emissions include Project construction activities such as demolition, hauling, and construction worker trips, as well as operational emissions. This analysis also considers indirect GHG emissions from water conveyance, wastewater generation, and solid waste handling. Since potential impacts resulting from GHG emissions are long-term rather than temporary, GHG emissions were calculated on an annual basis. As previously discussed, the Project would remove existing office uses and associated GHG emissions. The GHG emissions analysis subtracted existing emissions as a credit when calculating net Project emissions.
GHG emissions for the Project are estimated using CalEEMod (Version 2022.1.1 ), which is a statewide land use emission 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. CalEEMod was developed in collaboration with the air districts of California and is recommended by SCAQMD. Regional data (e.g., emission factors, trip lengths, meteorology, source inventory, etc.) have been provided by the various California air districts to account for local requirements and conditions. The model is considered to be an accurate and comprehensive tool for quantifying air quality and GHG impacts from land use projects throughout California. Mobile source emissions have been estim ated based on CARB’s on-road vehicle emissions factor (EMFAC2021) model.
As discussed previously, the City of Culver City has adopted and implemented a range of GHG reduction activities and strategies including Culver City’s Green Building Program that would reduce GHG emissions. In addition, SCAG has adopted Connect SoCal applicable to the region, which outlines SCAG’s plan for integrating the transportation network and related strategies with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. The SCS focuses the majority of new housing and job growth in HQTAs and other opportunity areas in existing main streets, downtowns, and commercial corridors, resulting in an improved jobs -housing balance and more opportunity for TOD and
116 Governor’s Office of Planning and Research, Technical Advisory – CEQA and Climate Change: Addressing Climate Change through California Environmental Quality Act (CEQA) Review, 2008, page 5.
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demonstrates a reduction in per capita GHG emissions relative to 2005 of nine percent in 2020 and 16 percent in 2035. The project -level analysis describes the consistency of the Project’s GHG emission sources with local and regional GHG emissions reduction strategies.
Construction Emissions
The emissions of GHGs associated with construction of the Project were calculated for each year of construction activity using CalEEMod and EMFAC2021. Construction emissions are forecasted by assuming a conservative estimate of construction activities (i.e., assuming all construction occurs at the earliest feasible date). Project construction is estimated to start in 2025 but may commence at a later date. If the onset of construction is delayed to a later date than assumed in the modeling analysis, construction impacts would be similar to or less than those analyzed, because a more energy-efficient and cleaner burning construction equipment and vehicle fleet mix would be expected in the future. This is because State regulations require construction equipment fleet operators to phase-in less polluting heavy-duty equipment and trucks over time. As a result, should the Project commence construction on a later date than modeled in this GHG impact analysis, GHG impacts would be less than the impacts disclosed herein.
Project construction activities would include demolition , grading and excavation, foundations , building construction, paving and architectural coating. Demolition activities would generate demolition debris (asphalt and general construction debris), which would require transport by haul truck. Soil excavation and grading activities would generate soil for export, which would require transport by haul truck. Heavy-duty construction equipment, vendor supply trucks and concrete trucks would be used during construction of foundations and buildings , as well as during paving and architectural coating.
The output values used in this analysis were adjusted to be Project -specific based on equipment types and the construction schedule. These values were then applied to the same construction phasing assumptions used in the criteria pollutant analysis in Sect ion 4.2, Air Quality, to generate GHG emissions values for each construction year.
SCAQMD’s Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold recognizes that construction -related GHG emissions from projects “occur over a relatively short-term period of time” and that “they contribute a relatively small portion of the overall lifetime project GHG emissions.”
117 The guidance recommends that construction project
GHG emissions should be “amortized over a 30 -year project lifetime, so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies.”
118 In accordance with that SCAQMD guidance, GHG emissions from construction
117 SCAQMD, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October 2008, http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance- thresholds/year-2008-2009/ghg-meeting-6/ghg-meeting-6-guidance-document-discussion.pdf?sfvrsn=2. Accessed July 12, 2020.
118 SCAQMD, Draft Guidance Document – Interim CEQA Greenhouse Gas (GHG) Significance Threshold, October 2008, http://www.aqmd.gov/docs/default-source/ceqa/handbook/greenhouse-gases-(ghg)-ceqa-significance- thresholds/year-2008-2009/ghg-meeting-6/ghg-meeting-6-guidance-document-discussion.pdf?sfvrsn=2. Accessed September 25, 2023.
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have been amortized over the 30-year lifetime of the Project. More detailed descriptions of the Project’s construction subphasing and equipment list are available in Appendix C of this Draft EIR.
Operational Emissions
Operation of the Project would generate GHG emissions from on -site operations such as natural gas combustion for heating/cooking, landscaping equipment and the use of consumer products.
CalEEMod was used to estimate operational GHG emissions from electrici ty, natural gas, solid waste, water and wastewater, refrigerants and landscaping equipment. GHG emissions would also be generated by Project-generated vehicle trips. Operational impacts were assessed for the first full Project buildout year in 2027.
This EIR quantifies the Project’s annual GHG emissions and compares them to a Project without Reduction Features scenario, as defined by CARB’s most updated projections for AB/SB 32. This approach mirrors the concepts used in CARB’s 2022 Climate Change Scoping Plan, which demonstrates GHG reductions compared to a Project without implementation of GHG reduction characteristics, features, and measures where operational GHG emissions were calculated based on a scenario without Project Design Features and consi stent with CARB’s Climate Change Scoping Plan Statewide BAU forecast. The Project without Reduction Features scenario does not account for energy efficiency measures that would exceed the Title 24 Building Standards Code. The Project without Reduction Features does not account for GHG -PDF-1 and assumes the Project without Reduction Features scenario will utilize natural gas in all land uses and does not include a solar photovoltaic system. A 50 percent diversion rate of solid waste was assumed for the Project as well as the Project without Reduction Features scenario. This comparison is being done for informational purposes only, including to disclose the relative carbon efficiency of the Project. The City of Culver City, as lead agency, is focusing its determination of the significance of the Project’s GHG emissions in relation to the Project’s location and design and its consistency with local City of Culver City regulatory schemes, as explained below.
Project energy demand and the consumption of fossil fuels to generate electricity and to provide space heating and cooling and hot water generates GHG emissions. Emissions of GHGs associated with energy usage under the Project’s proposed land uses are calculated using the CalEEMod tool. Future fuel consumption rates are estimated based on specific square footage of the Project’s residential, retail, and vehicular parking land uses, as well as predicted water supply needs of the Project . The Project electricity demands are supplied by SCE. The Project and Project without Reduction Features use a CO
2e intensity factor based on CalEEMod forecasted future year carbon intensities that reflect utility-specific planning considerations, including future integration of renewables for 2027 including SB 100 requirements, which requires local publicly owned electric utilities to procure eligible renewable electricity for 44 percent of retail sales by December 31, 2024, 52 percent by 2027, 60 percent by 2030, and 100 percent by 2045. While 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 Title 24 Building Energy Efficiency Standards but does not include correction factors for the 2022 standards. Thus, the analysis of building energy- related GHG emissions does not reflect additional building energy reductions and associated GHG emissions reductions from 2022 Title 24 compliance. The Project’s GHG analysis conservatively assumes the
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Project will remain with SCE as their electricity provider and will not take additional credit for renewable energy beyond the expected SCE renewable energy percentage for year 2027 based on the future trend under SB 100 and CalEEMod forecasted future year carbon intensities.119 Mobile emissions in both the Project and the Project without Reduction Features were estimated based on emission factors from EMFAC along with Project VMT calculations as shown in the VMT Calculator outputs provided for the Project in the Project’s Transportation Study, provided in Appendix I, consistent with calculations in Section 4.2, Air Quality , of this Draft EIR. 120 All vehicle types could visit the Project Site. Therefore, this assessment uses Los Angeles County’s motor vehicle fleet mix and the fleet average calendar year emissions factors from EMFAC to estimate mobile source GHG emissions. 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 are qualitatively discussed in the analysis in Section 4.11, Transportation. Thus, the GHG analysis conservatively estimates mobile emissions, because the estimates do not account for the reduced emissions that would occur through implementation of the Project’s TDM Program.
As previously described above, within Culver City, in 2019 all residential and commercial users were automatically enrolled in the CPA program. Electricity customers in the City of Culver City are automatically defaulted to receive electricity from 100 percent renewable resources unless they opt out of the CPA. However, the analysis for the Project conservatively assumes that the renewable usage is equal to that of Southern California Edison’s renewable production as predicted through SB 100 and CalEEMod forecasted future year carbon intensities. 121
Emissions of GHGs associated with solid waste disposal under the Project’s proposed land uses are calculated using the CalEEMod tool. The emissions are based on the size of the Project’s residential and retail uses, the waste disposal rate for the land uses are estimated based on land use type through CalEEMod, and the GHG emission factors for solid waste decomposition. The GHG emission factors, particularly for CH
4, depend on characteristics of the landfill, such as the presence of a landfill gas capture system and subsequent flaring or energy recovery. The default values, as provided in CalEEMod, for landfill gas capture (e.g., no capture, flaring, energy recovery) are statewide averages and are used in this assessment. In addition, a 50 percent diversion rate of solid waste is assumed for the Project and the Project without Reduction Features.
119 For the purposes of estimating GHG emissions in this Draft EIR, the emissions analysis conservatively assumes Project would not switch electricity providers from SCE to the Clean Power Alliance (CPA) (i.e., does not take any credit for 36 percent, 50 percent, or 100 percent renewable electricity, depending on the selected CPA plan). Should the Project switch electricity providers from SCE to the CPA, the Project’s electricity-related emissions would be lower than those disclosed in this section if they chose 50 or 100 percent renewable electricity. 120 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
121 The CPA allows for 100 percent, 50 percent, and 36 percent renewable energy content as well as the option to opt out of the program all together. Assuming that all of the City of Culver City’s residents opt out of the program is a highly conservative assumptions and therefore the analysis will likely overestimate net Project emissions.
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The emissions of GHGs associated with water demand and wastewater generation from the Project are calculated using CalEEMod. The emissions are based on the size of the Project land uses, the water demand factors, the electrical intensity factors for water supply, treatment, and distribution for wastewater treatment, the GHG emission factors for the electricity utility provider, and the GWP values for the GHGs emitted. Emissions were calculated using CalEEMod and were based on the water usage rate consistent with Section 4.1 3.1, Utilities and Service Systems – Water Supply, of this Draft EIR.
The emissions of GHGs associated with operational area sources under the Project are calculated using the CalEEMod tool. The emissions for landscaping equipment are based on the size of the open space based on the Project’s residential and retail land uses, the GHG emission factors for fuel combustion, and the GWP values for the GHGs emitted. Refrigerant emissions are based on Project land use type since different types of refrigeration equipment are used by different types of land uses. CalEEMod quantifies refrigerant emissions from leaks during regular operation and routine servicing of the refrigeration equipment lifetime, and then derives average annual emissions from the lifetime estimate.
As previously stated, operational GHG impacts are calculated by subtracting existing emissions from Project emissions. The GHG emissions calculations incorporate GHG reductions sustainability measures, some of which are required by regulation, such as the City of Culver City’s Green Building Program requirements, and compliance with SCAQMD rules and regulations and reductions in energy, water, and waste demand.
Consistency with GHG Reduction Plan, Policies, and Actions The Project’s potential for GHG impacts is also evaluated by assessing the Project’s consistency with applicable GHG reduction strategies and local actions adopted by CARB, SCAG, and the City.
As there is no applicable adopted or accepted numerical threshold of significance for GHG emissions, the methodology for evaluating the Project’s impacts related to GHG emissions focuses on whether the Project is not in conflict with, and therefore is consistent with, Statewide, regional, and local plans adopted for the purpose of reducing and/or mitigating GHG emissions. This evaluation of consistency with such plans is the sole basis for determining the significance of the Project’s GHG-related impacts on the environment consistent with CEQA Guidelines Section 15064.4 and CEQA Guidelines Appendix G. Based on CEQA case law, when no guidance exists, the lead agency may look to and assess general compliance with comparable regulatory schemes. 122
A consistency analysis is provided and describes the Project’s compliance with performance-based standards included in the regulations outlined in the applicable portions of CARB’s 2022 Climate Change Scoping Plan, Connect SoCal and the City’s Green Building Program.
122 See Protect Historic Amador Waterways v. Amador Water Agency (2004) 116 Cal. App. 4th 1099, 1107 [“‘[A] lead agency’s use of existing environmental standards in determining the significance of a project’s environmental impacts is an effective means of promoting consistency in significance determinations and integrating CEQA environmental review activities with other environmental program planning and resolution.”’”]. Lead agencies can, and often do, use regulatory agencies’ performance standards. A project’s compliance with these standards usually is presumed to provide an adequate level of protection for environmental resources. See, e.g., Cadiz Land Co. v.
Rail Cycle (2000) 83 Cal.App.4th 74, 99 (upholding use of regulatory agency performance standard).
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For this Project, the City of Culver City serves as the lead agency. OPR encourages lead agencies to make use of programmatic mitigation plans and programs from which to tier when they perform individual project analyses. The City of Culver City does not have a programmatic mitigation plan to tier from, such as a GHG Emissions Reduction Plan as recommended in the CEQA Guidelines.
However, the City of Culver City has adopted the Green Building Program that encourage s and requires applicable projects to implement energy efficiency measures. In addition, the California CAT Report provided recommendations for specific emission reduction strategies for reducing GHG emissions and reaching the targets established in HSC Division 25.5. Thus, if the Project is designed and operated in accordance with these policies and regulations, it would result in a less than significant impact, because it would be consistent with the overarching State regulations on GHG reductions.
Appendix D, Local Actions, of the 2022 Scoping Plan Update includes “recommendations intended to build momentum for local government actions that align with the State’s climate goals, with a focus on local GHG reduction strategies (commonly referred to as climate action planning) and approval of new land use development projects, including through environmental review under the California Environmental Quality Act (CEQA).”
123
The State encourages local governments to adopt a CEQA -qualified CAP addressing the three priority areas (transportation electrification, VMT reduction, and building decarbonization).
However, the State recognizes that almost 50% of jurisdictions do not have an adopted CAP, among other reasons because they are costly, requiring technical expertise, staffing, funding. Additionally, CAPs need to be monitored and updated as State targets change and new data is available.
Jurisdictions that wish to take meaningful climate action (such as preparing a non-CEQA-qualified CAP or as individual measures) aligned with the State’s climate goals in the absence of a CEQA - qualified CAP should also look to the three priority areas when developing local climate plans, measures, policies, and actions. “By prioritizing climate action in these three priority areas, local governments can address the largest sources of GHGs within their jurisdiction.” 124
The State also recognizes in Appendix D, Local Actions, of the Scoping Plan that each community or local area has distinctive situations and local jurisdictions must balance the need for housing while demonstrating that a Project is in alignment with the State’s Climate Goals. 125 The State calls
for the climate crisis and the housing crisis to be confronted simultaneously. Jurisdictions should avoid creating targets that are impossible to meet as a basis to determine significance. Ultimately, targets that make it more difficult to achieve statewide goals by prohibiting or complicating projects that are needed to support the State’s climate goals, like infill development, low-income housing or solar arrays, is not consistent with the State’s goals. The State also recognizes the lead agencies’ discretion to develop evidence -based approaches for determining whether a project would have a potentially significant impact on GHG emissions.
123 CARB, Final 2022 Climate Change Scoping Plan – Appendix D: Local Actions, November 2022. 124 CARB, Final 2022 Climate Change Scoping Plan – Appendix D: Local Actions, November 2022. 125 The State recognizes the need for 2.5 million housing units over the next eight years, with one million being affordable units. See page 20, Appendix D, 2022 Scoping Plan Update, November 2022.
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Project Design Features
The following project design features would be implemented as part of the Project:
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.
In addition to Project Design Feature GHG-PDF -1, the Project would implement Project Design Feature TRAF -PDF-2 ( Transportation Demand Management (TDM) Program ), which would reduce single occupancy trips, and VMT. These PDFs would also reduce GHG emissions.
Analysis of Project Impacts
Impact GHG-1: The Project could have a significant impact if it would generate GHG emissions, either directly or indirectly, that may have a significant impact on the environment.
Impact GHG-2: The Project could have a significant impact if it would conflict with any applicable plan, policy, regulation, or recommendation of an agency adopted for the purpose of reducing the emissions of GHGs.
Impact Analysis
Consistency with State Plans, Policies, or Regulations
In the absence of any adopted quantitative threshold, the significance of the Project’s GHG emissions is evaluated consistent with CEQA Guidelines Section 15064.4(b)(2) by considering whether the Project complies with applicable plans, policies, regulations, and requirements adopted for the purpose of reducing the emissions of GHGs.
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The analyses below demonstrate that the Project is consistent with the applicable GHG emission reduction plans and policies included within the 2008 Climate Change Scoping Plan and subsequent updates, SCAG’s Connect SoCal, and the City of Culver City’s Green Building Program. As shown herein, the Project would be consistent with the applicable GHG reduction plans, policies, and regulations.
CARB’s Climate Change Scoping Plan
As discussed above, jurisdictions that want to take meaningful climate action (such as preparing a non-CEQA-qualified CAP or as individual measures) aligned with the State’s climate goals in the absence of a CEQA-qualified CAP should also look to the three priority areas (transportation electrification, VMT reduction, and building decarbonization). To assist local jurisdictions, the 2022 Scoping Plan Update presents a non-exhaustive list of impactful GHG reduction strategies that can be implemented by local governments within the three priority areas (Priority GHG Reduction Strategies for Local Government Climate Action Priority Areas). 126 Specifically, Table
3 of Appendix D discusses attributes for residential and mixed-use project that would accommodate growth in a manner consistent with State GHG reduction and equity prioritization goals. 127 A detailed assessment of the Project’s consistency with applicable goals, plans, and policies implemented by the City which would support the GHG reduction strategies in the three priority areas is provided below.
128 In addition, further details are provided regarding the correlation between these reduction strategies and applicable actions included in Table 2 -1 (page 72) of the Scoping Plan (Actions for the Scoping Plan Scenario).
Transportation Electrification
The priority GHG reduction strategies for local government climate action related to transportation electrification are discussed below and would support the Scoping Plan action to have 100 percent of all new passenger vehicles to be zero emissions by 2035 (see Table 2-1 of the Scoping Plan). • Convert local government fleets to zero-emission vehicles (ZEV) The CARB approved the Advanced Clean Cars II rule which codifies Executive Order N-79-20 and requires 100 percent of new cars and light trucks sold in California be zero -emission vehicles by 2035. The State has also adopted AB 2127, which requires the CEC to analyze and examine charging needs to support California’s EVs in 2030. This report would help decision-makers allocate resources to install new EV chargers where they are needed most.
Culver’s City’s EV Infrastructure Plan aims to foster increased EV charging stations at public facilities and in private development. The City with assistance from the City's EV Infrastructure Plan looks to foster private EV charging station development by increasing education and awareness about EVs and EV charging stations; create policies and initiatives that encourage and streamline EV charging stations development, installation, and use; and connect EV and EV charging stations stakeholders to funding resources to reduce upfront costs. As noted in the City’s
126 Table 1 of Appendix D, 2022 Scoping Plan Update, November 2022. 127 Table 3 of Appendix D, 2022 Scoping Plan Update, November 2022. 128 Table 1 and 3 of Appendix D, 2022 Scoping Plan Update, November 2022.
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EV Infrastructure Plan, depending on the mix of EV charging station types, Culver City may need between 380 and 1,154 charging stations by 2030 to support statewide goals.
The Project would support these goals by providing EV charging stations for Project residential uses and commercial uses. The Project would provide a total of 428 parking spaces. While the CCMC no longer has any minimum amount of required parking for any use citywide, the Project’s voluntarily provided parking would meet CCMC Section 17.320.035.O.3 requirements with installation of the conduit and panel capacity to accommodate future electric vehicle charging stations into a minimum of 20 percent of the parking spaces (approximately 8 6 spaces: 81 residential + 5 commercial), with 10 percent of the spaces further improved to be EV ready (approximately 44 spaces: 41 residential + 3 commercial), and with 10 percent of the spaces further improved with electric vehicle charging stations (approximately 41 residential spaces + 3 commercial spaces). Installation of additional EV chargers would encourage adoption of EVs. • Create a jurisdiction-specific ZEV ecosystem to support deployment of ZEVs statewide (such as building standards that exceed state building codes, permit streamlining, infrastructure siting, consumer education, preferential parking policies, and ZEV readiness plans)
The State has adopted AB 1236 and AB 970, which require cities to adopt streamline permitting procedures for EV charging stations. As a result, CCMC Section 17.320.035.O.3, includes EV parking design requirements with installation of the conduit and panel capacity to accommodate future electric vehicle charging stations into a minimum of 20 percent of the parking spaces, with 10 percent of the spaces further improved to be EV ready, and with 10 percent of the spaces further improved with electric vehicle charging stations. In addition, the City also aims to foster increased EV charging stations at public facilities and in private development through Culver’s City’s EV Infrastructure Plan.
The City’s goals of increasing EV chargers in both public and private development throughout the City would be consistent with the Scoping Plan goals of transitioning to EVs. The Project would support this GHG reduction strategy by providing EV charging stations for both residential and commercial parking spaces . The Project would provide a total of 428 parking spaces. While the CCMC no longer has any minimum amount of required parking for any use citywide, the Project’s voluntarily provided parking would meet CCMC Section 17.320.035.O.3 parking design requirements regarding EV Capable, EV Ready and spaces with full EV charging stations (see discussion above for specific number of spaces provided for each by the Project ), which would encourage adoption of EVs.
VMT Reduction
The priority GHG reduction strategies for local government climate action related to VMT reduction are discussed below and would support the Scoping Plan action to reduce VMT per capita 25 percent below 2019 levels by 2030 and 30 percent below 2019 levels by 2045. • Reduce or eliminate minimum parking standards in new developments • Implement parking pricing or transportation demand management pricing strategies
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The City’s Municipal Code Section 7.05.015 (Transportation Demand and Trip Reduction Measures), requires development greater than 25,000 gross square feet to implement transportation demand and trip measures, including measures associated with parking, related to VMT reduction prior to issuance of a certificate of occupancy.
As described in the 4.11, Transportation, of this Draft EIR, the Project proposes a CCMC Section
7.05.015 required 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. 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 the following: 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; Pedestrian-Friendly Environment; Employee Parking; Bus Stop Improvements. Additional TDM strategies that may be offered 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 includ e: Project Transportation Coordinator; Transportation Information Packet for New Residents and Employees; and Bike Repair Station (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 Pro gram (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 . While the Project voluntarily proposes to provide 428 parking stalls, the Project would be consistent with the overall intent of this GHG reduction policy through the Project’s TDM Program (TRAF-PDF-2). • Implement Complete Streets policies and investments, consistent with general plan circulation element requirements
The City adopted the Complete Streets Policy in January 2020. The Complete Streets Policy lays out a plan for designing safer, more vibrant streets that are accessible to people, no matter how they travel. The policy sets a variety of goals and standards in the application of complete streets principles including improving mobility for all road users, enhancing safety, and creating a standard set of criteria applicable to all city departments and private developers who construct within the public right of way. The Project would incorporate the complete streets principles into the Project design to encourage multi -modal transportation options within the community. The Complete Streets Policy emphasizes a balanced transportation system that considers all users of the road (cyclists, pedestrians, transit riders, and vehicles) while planning development and transportation projects.
The Project would implement Complete Street policy 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. In addition, the first floor retail use at the corner of Hannum Avenue and Buckingham Parkway would serve as a
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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. The Project would occupy a location that is highly accessible by existing transit options along Hannum Avenue and Buckingham Parkway provided by the Culver City Department of Transportation and further detailed below.
In addition, the Project would include 92 bicycle parking spaces (11 short -term and 81 long-term spaces), as required by CMCC Section 7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF -PDF-2). The Project’s bicycle parking spaces and facilities would be provided at various locations throughout the Project Site, which 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) . In addition, 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.
Also, 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 Buckingham Driveway and loading area 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 requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site as well as bicyclists crossing the driveway. Therefore, the Project complies with complete street policies and would not conflict with implementation of Complete Streets policies.
• Increase access to public transit by increasing density of development near transit, improving transit service by increasing service frequency, creating bus priority lanes, reducing or eliminating fares, microtransit, etc.
• Increase public access to clean mobility options by planning for and investing in electric shuttles, bike share, car share, and walking
• Amend zoning or development codes to enable mixed-use, walkable, transit-oriented, and compact infill development (such as increasing the allowable density of a neighborhood) • Preserve natural and working lands by implementing land use policies that guide development toward infill areas and do not convert “greenfield” land to urban uses (e.g., green belts, strategic conservation easements).
The above strategies are supported through implementation of SB 375 which requires integration of planning processes for transportation, land-use and housing and generally encourages jobs/housing proximity, promote TOD, and encourages high- density residential/commer cial development along transit corridors. To implement SB 375 and reduce GHG emissions by correlating land use and transportation planning, SCAG adopted Connect SoCal. Connect SoCal’s “Core Vision” prioritizes the maintenance and management of the region’s transportation network, expanding mobility choices by co-locating housing, jobs, and transit, and increasing investment in
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transit and complete streets. Please refer below for additional discussion of consistency with Connect SoCal and as shown in Table 4.6-7, Consistency with Applicable SCAG Connect SoCal Actions and Strategies, below, the Project would not conflict with Connect SoCal's goals.
On a local level, the City has adopted the Complete Streets Policy in January 2020 where the goal of this concept is to transform the City of Culver City into a place with an extensive bicycle and pedestrian network that allows travelers of all levels and abilities to feel comfortable walking and biking to their destinations as well as the Culver City Bicycle & Pedestrian Action Plan, which aims to provide a safe, convenient, and accessible active transportation network. In addition, Culver’s City’s EV Infrastructure Plan aims to foster increased EV charging stations at public facilities and in private development. The EV Charging Station Study/Infrastructure Plan aims to assist Culver City to expand its EV charging network as it determines the most suitable sites in Culver City to install EV charging stations and identifies hurdles to installing EV charging stations and develop solutions. Culver’s City’s EV Infrastructure Plan also highlights that while the City will increase EV charging stations at publicly owned locations, the majority of EV charging stations will be owned and operated by the private sector. As mentioned above, t he City with assistance from the City's EV Infrastructure Plan looks to foster private EV development by increasing education and awareness about EVs and EV charging stations; create policies and initiatives that encourage and streamline EV charging stations development, installation, and use; and connect EV and EV charging stations stakeholders to funding resources to reduce upfront costs.
The Project would occupy a location that is highly accessible by existing transit options along Hannum Avenue and Buckingham Parkway provided by the Culver City Department of Transportation. The Project is a mixed-use development and represents an infill development at a location served by several public transit options , including Culver CityBus 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 Metropolitan Transportation Authority (Metro) Bus Lines 108 and 110, as well as Culver CityBus Line 6. Also, the Project would include 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section
7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PDF-2). The Project’s bicycle parking spaces and facilities would be provided at various locations throu ghout the Project Site, which 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) . Therefore, the Project complies with Complete Street policies and would not conflict with implementation of Complete Streets policies.
In addition, 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. Also, 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. However, the Buckingham Driveway and loading area would intersect the southbound bicycle lane on the west side of Buckingham Parkway, so additional bike amenities are expected to increase around the Project Site in the future . Therefore, the Project complies with the above strategies by increasing development density near public transit and access to bicycle parking and facilities to encourage increased bike share.
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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 d oes not support residential and/or residential mixed-use projects. Per the Culver City Zoning Code (Zoning Code), the Project Site is zoned 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.
129 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 Preferred 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 not convert any natural and working lands to urban uses. 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 public transportation for visitors, residents, employees and patrons . As described above, the Project would implement 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. 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.
California continues to experience a severe housing shortage. The State must plan for more than
2.5 million residential units over the next eight years, and no less than one million of those residential units must be affordable to lower -income households. 130 This represents more than
double the housing planned for during the last eight years. 131 The housing crisis and the climate crisis must be confronted simultaneously, and it is possible to address the housing crisis in a manner
129 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.
130 California Department of Housing and Community Development. 2022. Statewide Housing Plan. Available at www.hcd.ca.gov/docs/statewide-housing-plan.pdf.
131 California Department of Housing and Community Development. 2022. Statewide Housing Plan. Available at www.hcd.ca.gov/docs/statewide-housing-plan.pdf.
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that supports the State’s climate and regional air quality goals. 132 CAPCOA’s Handbook for Analyzing Greenhouse Gas Emission Reductions, Assessing Climate Vulnerabilities, and Advancing Health and Equity (CAPCOA’s Handbook) provides a VMT reduction measurement for incorporation of low -income housing. Measure T -4 (Integrate Affordable and Below Market Rate Housing) shows a 28.6 percent reduction in VMT for low -income units in comparison to market rate units.
As discussed in Section 4.7, Land Use and Planning, the Culver City General Plan Land Use Element’s Objective 3 aims to increase housing for all members of the public, including the provision of affordable housing. The Project would comply with Objective 3 by providing 27 affordable housing units of the Project’s 309 residential units. Also, as discussed above, the Project would not convert any natural and working lands to urban uses. Additionally, 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 highly accessible by existing public transit options along Hannum Avenue and Buckingham Parkway for visitors, residents, employees and patrons . This colocation of uses on an accessible Project Site provides the opportunity to further reduce GHG emissions. In addition, the Project would provide a total of 428 parking spaces and would meet CCMC Section 17.320.035.O.3 parking design requirements regarding EV Capable, EV Ready and spaces with full EV charging stations (see discussion above for specific number of spaces provided for each by the Project), which may also help to further reduce GHG emissions by encouraging increased EV use.
Therefore, the Project would be consistent with these reduction strategies. While these reduction strategies mainly apply to traffic circulation infrastructure within the City, the Project would support these reduction strategies.
Building Decarbonization
The priority GHG reduction strategies for local government climate action related to electrification are discussed below and would support the Scoping Plan actions regarding meeting increased demand for electrification without new fossil gas -fire resources and all electric appliances beginning in 2026 (residential) and 2029 (commercial) (see Table 2-1 of the Scoping Plan). • Adopt all-electric new construction reach codes for residential and commercial uses California’s transition away from fossil fuel –based energy sources will bring the project’s GHG emissions associated with building energy use down to zero as our electric supply becomes 100 percent carbon free. California has committed to achieving this goal by 2045 through SB 100, the 100 Percent Clean Energy Act of 2018. SB 100 strengthened the State’s Renewables Portfolio Standard (RPS) by requiring that 60 percent of all electricity provided to retail users in California come from renewable sources by 2 030 and that 100 percent come from carbon-free sources by 2045. The land use sector will benefit from RPS because the electricity used in buildings will be
132 Elkind, E. N., Galante, C., Decker, N., Chapple, K., Martin, A., & Hanson, M. 2017. Right Type, Right Place:
Assessing the Environmental and Economic Impacts of Infill Residential Development through 2030. Available at https://ternercenter.berkeley.edu/research-and-policy/right-type-right-place/.
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City of Culver City 4.6-54 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
increasingly carbon-free, but implementation does not depend (directly, at least) on how buildings are designed and built.
The City of Culver City has adopted green building ordinances to reduce GHG emissions for new development. The City of Culver City has adopted a Photovoltaic Requirement that requires 1 kilowatt (kw) of photovoltaic power installed per 10,000 square feet (sf) of new development or the developer will pay an in-lieu fee in an amount equal to the cost of a solar photovoltaic system consistent with Section 117.2 Exceptions of the California Building Code . In addition, the Culver City Green Building Program requires new developments totaling more than 50,000 sf to achieve LEED rating system at a "certified" performance level or higher. As described above, in 2019, the CPA became the new electricity supplier for Culver City for both residential customers (February) and for non-residential customers (May). With this change, CPA purchases the renewable energy resources for electricity, and SCE delivers it to Culver City customers. The CPA is a Joint Powers Authority made up of public agencies across Los Angeles and V entura counties working together to bring clean, renewable power to Southern California. With the recent switch in energy providers, electricity customers in Culver City are automatically defaulted to have 100 percent renewable energy serving their electricity needs. Alternatively, customers can opt to have their electricity power consisting of 50 percent renewable content or 36 percent or opt out of the CPA and remain with SCE as their provider. In future years, the SCE will be required to increase the amo unt of renewable energy in the power mix to comply with SB 100 requirements. The combination of the energy efficiency regulations and increasing availability of renewable energy will serve to reduce GHG emissions from sources traditionally powered by natural gas.
Although this GHG reduction measure is aimed primarily at jurisdictions and not individual projects, as discussed in subsection, Project Design Features, of this GHG section above, 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 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. In addition, as part of Project Design Feature GHG - PDF-1, the Pr oject 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 . While building electrification would result in higher electricity usage, it would greatly reduce the use of a fossil fuel and the associated GHG emissions (i.e., natural gas combustion) from building energy demand since only the retail space still uses natural gas. The Project would also comply with applicable solar installation regulatory requirements.
• Adopt policies and incentive programs to implement energy efficiency retrofits for existing buildings, such as weatherization, lighting upgrades, and replacing energy - intensive appliances and equipment with more efficient systems (such as Energy Star - rated equipment and equipment controllers)
This reduction strategy would support the Scoping Plan action regarding electrification of appliances in existing residential buildings (see Table 2 -1 of the Scoping Plan). As stated above, the City of Culver City has adopted green building ordinances to reduce GHG emissions for new development, including a Photovoltaic Requirement that requires 1 kilowatt (kw) of photovoltaic
4. Environmental Impacts Analysis
4.6. Greenhouse Gas Emissions
City of Culver City 4.6-55 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
power installed per 10,000 square feet (sf) of new development or the developer will pay an in-lieu fee and the Green Building Program requirement that new developments totaling more than 50,000 sf achieve LEED certified performance level or higher.
The Project would support this measure by meeting or exceeding electricity requirements in the 2022 Building Efficiency Standards which encourages efficient electric heat pumps, establishes electric-ready requirements for new homes, expands solar photovolt aic and battery storage standards, and strengthens ventilation standards. As described above, 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 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. Also, as described above, 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. Whil e building electrification would result in higher electricity usage, it would greatly reduce the use of a fossil fuel and the associated GHG emissions (i.e., natural gas combustion) from building energy demand since only the retail space still uses natural gas. The Project would also comply with applicable solar installation regulatory requirements. Therefore, based on the above, the Project would not conflict with energy strategies in the 2022 Scoping Plan.
As a result, the Project would not conflict with applicable Climate Change Scoping Plan strategies and regulations to reduce GHG emissions.
Post-2030 Analysis
The 2022 Scoping Plan Update also outlines strategies to reduce GHG emissions to achieve the 2030 target from sectors that are not directly controlled or influenced by the Project, but nonetheless contribute to Project-related GHG emissions. For instance, the Project itself is not subject to the Cap-and-Trade regulation; however, Project -related emissions would decline pursuant to the regulation as utility providers and transportation fuel producers are subject to renewable energy standards, Cap -and-Trade, and the LCFS. While CARB is in the process of expanding the regulatory framework to meet the 2030 reduction target based on the existing laws and strategies in the 2022 Scoping Plan, the Project would support or not impede implementation of these potential GHG reduction strategies identified by CARB for all the reasons summarized above.
In June 2018, an updated report was published on the California PATHWAYS model, which was used in the preparation of the 2022 Scoping Plan Update. This report determined that “meeting the state’s 2030 climate goals requires scaling up and using technologies already in the market such as energy efficiency and renewables, while pursing aggressive market transformation of new technologies that have not yet been utilized at scale in California (for example, zero -emission vehicles and electric heat pumps).”
133 Priority GHG reduction strategies include energy efficiency in buildings, renewable energy, and smart growth through increased use of public transit, walking,
133 California Energy Commission, Energy Research and Development Division, Final Project Report, Deep Decarbonization in a High Renewables Future Updated Results from the California PATHWAYS Model, June 2018.
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biking, telepresence, and denser, mixed-use community design. The Project would not conflict with these strategies given it would locate residential and retail uses on an infill Project Site located within a walkable area of the Fox Hills Sub -Area of the City with access to public transit and employment opportunities, restaurants , and entertainment. The Project would occupy a location that is highly accessible by existing public transit options along Hannum Avenue and Buckingham Parkway provided by the Culver City Department of Transportation and further detailed below.
The Project is a mixed-use development and represents an infill development at a location served by several public transit options, including Culver CityBus 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 Metro Bus Lines 108 and 110, as well as Culver CityBus Line 6. Furthermore, the Project would support the priority market transformation strategy of zero-emission light -duty vehicles by providing for the installation of the conduit and panel capacity to accommodate future electric vehicle charging stations where the Project would provide a total of 428 parking spaces and the Project’s voluntarily provided parking would meet CCMC Section 17.320.035.O.3 parking design requirements regarding EV Capable, EV Ready and spaces with full EV charging stations (see discussion above for specific number of spaces provided for each by the Project). As such, the Project would not conflict with the findings relevant to the Project from the updated California PATHWAYS model report.
With Statewide efforts underway to facilitate the State’s achievement of those Statewide goals, it is reasonable to expect the Project’s GHG emissions to decline from their opening year levels as reported in Table 4.6-9, below, as the regulatory initiatives identified by CARB in the 2022 Scoping Plan Update are implemented, and other technological innovations occur. Stated differently, the Project’s emissions at buildout likely represents the maximum emissions for the Project as anticipated regulatory devel opments and technology advances are expected to reduce emissions associated with the Project, such as emissions related to electricity use and vehicle use.
Even though the 2022 Scoping Plan Update and supporting documentation do not provide an exact regulatory and technological roadmap to achieve carbon neutrality by 2045 as established by AB 1279, they demonstrate that various combinations of policies could allow the Statewide emissions level to remain very low through 2045, suggesting that the combination of new technologies and other regulations not currently feasible at the time the 2022 Scoping Plan Update was adopted could enable the State to meet the 2045 targets.
134 For example, the 2022 Scoping Plan Update states
some policies are not feasible at this time, such as ZEV technology for off-road equipment and for propulsion, such as commercial aircraft or ocean-going vessels, but that this type of policy would be necessary to meet the 2045 target.
Based on the above, the Project would not conflict with CARB’s Climate Change Scoping Plan, and there would be an anticipated decline in Project emissions once fully constructed and operational; the Project would not conflict with the State’s GHG reduction targets for 2030,2045 and 2050. Therefore, impacts would be less than significant. As stated above, a detailed consistency table that contains a list of the State’s Climate Change Scoping Plan GHG-reducing strategies
134 California Air Resources Board. 2022. 2022 Scoping Plan For Achieving Carbon Neutrality, November 16. 2022 Scoping Plan Update (ca.gov). Accessed December 19, 2022.
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relevant to the Project and describes that the Project would not conflict with the Climate Change Scoping Plan is available in the Air Quality and Greenhouse Gas Technical Documentation appendix for the Project, which is provided in Appendix C of this Draft EIR.
SCAG Connect SoCal
Transportation-related GHG emissions would be the largest source of emissions from the Project.
This finding is consistent with the findings in regional plans, including Connect SoCal, which recognizes that the transportation sector is the largest contributor to the State’s GHG emissions. At the regional level, Connect SoCal is an applicable plan adopted for the purpose of reducing GHGs.
The purpose of Connect SoCal is to achieve the regional per capita GHG reduction targets for the passenger vehicle and light-duty truck sector established by CARB pursuant to SB 375. To accomplish this goal, Connect SoCal identifies various strategies to reduce per capita VMT.
Connect SoCal is expected to help SCAG reach its GHG reduction goals, as identified by CARB, with reductions in per capita passenger vehicle GHG emissions for specified target years.
In addition to demonstrating the region’s ability to attain and exceed the GHG emission-reduction targets set forth by CARB, Connect SoCal outlines a series of actions and strategies for integrating the transportation network with an overall land use pattern that responds to projected growth, housing needs, changing demographics, and transportation demands. Thus, successful implementation of Connect SoCal would result in more complete communities with a variety of transportation and housing choices, while reducing automobile use. With regard to individual developments, such as the Project, strategies and policies set forth in Connect SoCal can be grouped into the following three categories: (1) reduction of vehicle trips and VMT, (2) increased use of alternative fuel vehicles, and (3) improved energy efficiency. These strategies and policies are addressed below.
In order to assess the Project’s potential to conflict with Connect SoCal , this section analyzes the Project’s land use characteristics for consistency with the strategies and policies set forth in Connect SoCal to meet GHG emission -reduction targets set by CARB. 135 Generally, projects are
considered to not conflict with applicable land use plans and regulations, such as SCAG’s Connect SoCal, if they are compatible with the general intent of the plans and would not preclude the attainment of their primary goals. The Project would support reducing VMT given that it is a mixed- use development with residential and retail land uses and represents an infill development at a location served by several public transit options, including Culver CityBus 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 Metro Bus Lines 108 and 110, as well as Culver CityBus Line 6.
The Project would not conflict with Connect SoCal goals and benefits intended to improve mobility and access to diverse destinations, provide better “placemaking,” provide more transportation choices, and reduce vehicular demand and associated emissions. Thus, successful implementation
135 As discussed in Connect SoCal, the actions and strategies included in Connect SoCal remain unchanged from those adopted in the 2012-2035 and 2016-2040 RTP/SCS.
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of Connect SoCal would result in more complete communities with jobs near a variety of transportation and housing choices, which would reduce automobile use.
Integrated Growth Forecast
Connect SoCal provides socioeconomic forecast projections of regional population growth. The population, housing, and employment forecasts, which are adopted by SCAG’s Regional Council, are based on the local plans and policies applicable to the specific area; these are used by SCAG in all phases of implementation and review. The Project would introduce new residential uses, new businesses, and new employees. 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 194 percent of SCAG’s year 2045 estimated increase of 1,000 households within the City, relative to 2020.
136 Based on Connect SoCal growth projections, the Project’s estimated 733 resident population would comprise approximately 89 percent of SCAG’s year 2045 estimated increase of 821 population within the City, relative to 20 20.137 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, which would comprise a decrease of approximately 1 percent of SCAG’s year 2045 estimated increase of 17,073 employees within the City, relative to 2020.138 Therefore, the Project’s contribution to population and employment would be consistent with SCAG population and employment projections for the City and would be consistent with SCAG’s Connect SoCal goals and with the growth projections contained in Connect SoCal .
Accordingly, the Project’s generation of population and employees would not conflict with employment generation projections contained in Connect SoCal. However, while the Project’s contributions to households would exceed those estimated household projections for the City contained in Connect SoCal , 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)
139 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 ( refer 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, of this Draft EIR, for additional information regarding consistency with Connect SoCal.
VMT Reduction Strategies and Policies
As similarly described in Section 4.1 1, Transportation, the Project is served by several public transit options, including Culver CityBus Bus Line 5C2 – Overland/Fox Hills, which includes Stop 306 Hannum Ave/Buckingham Parkway, approximately 210 feet west of the Project Site. In
136 Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information. 137 Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information. 138 Refer to Section 4.9, Population and Housing, of this Draft EIR for additional information. 139 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 Connect SoCal’s 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).
4. Environmental Impacts Analysis
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addition, the Project Site is located 0.6 mile east of the Culver City Transit Center which serves Metro Bus Lines 108 and 110, as well as Culver CityBus Line 6. In addition, 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. Also, 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 Project would also provide the Project would include 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section 7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PDF- 2). The Project’s bicycle parking spaces and facilities will be provided at various locations throughout the Project Site, which include short-term facilities (e.g., bicycle racks) and secure long- term bicycle parking (e.g., fully enclosed rooms or bicyc le lockers that protect the bicycle from inclement weather and accessible only to the owner). 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. The streets immediately bordering the Project Site and all other public streets in the vicinity include sidewalks on both sides of the street, facilitating pedestrian movement. In addition, as discussed in Section 4.11, Transportation, the Project would have a less than significant impact on household VMT per capita as estimated by the City’s VMT Calculator where the daily household VMT per capita for the Project is estimated at 6.8, which is below the citywide household VMT threshold of 7.1 per capita (see Section 4.11, Transportation, for additional details). Therefore, the Project would facilitate a reduction in VMT and related vehicular GHG emissions and would not conflict with the VMT Reduction Strategies and Policies of Connect SoCal.
The Project would also not be in conflict with the following key GHG reduction strategies in SCAG’s Connect SoCal as substantiated below, which are based on changing the region’s land use and travel patterns in the following key areas:
140
• Compact growth in areas accessible to transit
• Locate jobs in proximity to transit
• Locate job growth focused in Priority Growth Areas
• Biking and walking infrastructure to improve active transportation options and transit access As described above, the Project would concentrate residential and retail land uses in an area served by several transit providers within the immediate vicinity of the Project Site. Connect SoCal focuses on orienting job growth in Priority Growth Areas served by high quality transit and into other infill areas where urban infrastructure including housing and other services already exists. The Project supports this by locating residential and retail land uses in an area well served by public transit and bicycle/pedestrian facilities. Furthermore, the Project would also provide 92 bicycle spaces.
Therefore, the Project would facilitate a reduction in VMT and related vehicular GHG emissions, which would not conflict with the goals of Connect SoCal.
140 SCAG, Connect SoCal, May 2020, pp. 3, 21, 26, 50, 52, 69, and 144.
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Increased Use of Alternative Fueled Vehicles Policy Initiative A goal of Connect SoCal, with regard to individual development projects, such as the Project, is to increase alternative fueled vehicles to reduce per capita GHG emissions. Connect SoCal policy initiative focuses on providing charge port infrastructure and accelerating fleet conversion to electric or other near zero-emission technologies. The Project would provide a total of 428 parking spaces. While the CCMC no longer has any minimum amount of required parking for any use citywide, the Project’s voluntarily provided parking would meet CCMC Section 17.320.035.O.3 parking design requirements regarding EV Capable, EV Ready and spaces with full EV charging stations (see discussion above for specific number of spaces provided for each by the Project). The Project would comply with the City of Culver City Municipal Code (CCMC) as applicable for electric vehicle parking. As such, the Project would not conflict with this goal of Connect SoCal.
Energy Efficiency Strategies and Policies
Connect SoCal includes strategies for individual developments, such as the Project, to improve energy efficiency (e.g., reducing energy consumption) to reduce GHG emissions. As discussed in Chapter 2, Project Description , of the Draft EIR, the Project has been designed and would be constructed to incorporate environmentally sustainable building features and construction protocols required by the applicable Culver City Green Building Program and CALGreen Building Code.
These standards would reduce energy and water usage and waste and, thereby, reduce associated GHG emissions and help minimize the impact on natural resources and infrastructure. The Project design would include sustainability features, including energy saving and sustainable design features that would be incorporated into the Project as the proposed buildings would comply with the applicable Title 24 California Code of Regulations. As discussed under subsection, Project Design Features, above, 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 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 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. Therefore, based on the above, the Project would not conflict with energy strategies in Connect SoCal.
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Land Use Characteristics
In order to assess the Project’s consistency with Connect SoCal, this Draft EIR also analyzes the Project’s land use characteristics, such as density and proximity to job centers, for consistency with those utilized by SCAG in its SCS. The Project’s consistency with the applicable land use goals and principles set for th in Connect SoCal is discussed in Section 4.7 , Land Use and Planning, and Table 4.6-7, Consistency with Applicable SCAG Connect SoCal Actions and Strategies. As concluded therein, the Project would not conflict with applicable land use strategies of Connect SoCal.
As discussed above and in Table 4.6-7, the Project would not conflict with and would support the applicable goals and benefits of Connect SoCal to reduce GHG. Accordingly, the Project is the type of land use development that is encouraged by Connect SoCal to reduce VMT and expand multi-modal transportation options in order for the region to achieve the GHG reductions from the land use and transportation sectors required by SB 375, which, in turn, advances the State’s long- term climate policies. By furthering implementation of SB 375, the Project supports regional land use and transportation GHG reductions consistent with State regulatory requirements.
Culver City’s Green Building Program
As discussed in Chapter 2, Project Description, of the Draft EIR, and as described in subsection, Project Design Features, above, 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 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 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 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 consist ent 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. 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. Therefore, based on the above, the Project would not conflict with Culver City’s Green Building Program.
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TABLE 4.6-7
CONSISTENCY WITH APPLICABLE SCAG CONNECT SOCAL ACTIONS AND STRATEGIES Actions and Strategies
Responsible
Party(ies) Consistency Analysis
Land Use Actions and Strategies
Encourage the use of range-limited battery electric and other alternative fueled vehicles through policies and programs, such as, but not limited to, neighborhood-oriented
development, complete streets, and Electric (and other
alternative fuel) Vehicle Supply Equipment in public parking lots.
Local Jurisdictions,
COGs, SCAG,
CTCs
No Conflict. This action applies to local jurisdictions, Council of Governments (COGs), SCAG and County Transportation Commissions (CTCs). While the use of alternative-fueled vehicles is beyond the direct control or influence of the Project, the Project would encourage the use of alternative-fueled vehicles by providing 428 parking spaces and would meet CCMC Section
17.320.035.O.3 requirements with installation of the conduit and panel capacity to accommodate future electric vehicle charging stations into a minimum of 20 percent of the parking spaces (approximately 86 spaces: 81 residential + 5 commercial), with 10 percent of the spaces further improved to be EV ready (approximately 44 spaces: 41 residential + 3 commercial), and with 10 percent of the spaces further improved with electric vehicle charging stations (approximately 41 residential spaces + 3 commercial spaces). The Project would comply with CCMC as applicable for electric vehicle parking.
Support projects, programs, and policies that support active and healthy community environments that encourage safe
walking, bicycling, and physical activity by children, including, but not limited to development of complete streets, school siting policies, joint use agreements, and bicycle and
pedestrian safety education.
Local Jurisdictions,
SCAG
No Conflict. While this action applies to local jurisdictions and SCAG, the Project would facilitate pedestrian and bicycle movements by providing convenient access to and from on-site uses. The Project is served by an existing Class II bike lane provided on both sides of Hannum Avenue adjacent to the Project Site. Also, 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. However, the Buckingham Driveway and loading area would intersect the southbound bicycle lane on the west side of Buckingham Parkway. The Project would provide the Project would include 92 bicycle parking spaces (11 short-term and 81 long-term spaces), as required by CMCC Section 7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PDF-2). The Project’s bicycle parking spaces and facilities will be provided at various locations throughout the Project Site, which 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). 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. The streets immediately bordering the Project Site and all other public streets in the vicinity include sidewalks on both sides of the street, facilitating pedestrian movement. Furthermore, the Project would implement a TDM Program, as described in Project Design Feature TRAF-PDF-2, that would encourage alternative transportation choices by employees accessing the Project Site.
Update local zoning codes, General Plans, and other
regulatory policies to promote a more balanced mix of
residential, commercial, industrial, recreational and
institutional uses located to provide options and to contribute to the resiliency and vitality of neighborhoods and districts.
Local Jurisdictions No Conflict. While this action applies to local jurisdictions, the Project would support this action/strategy by adding residential and retail land uses in an area developed primarily with a mix of commercial and residential uses. The Project Site is located within a walkable area of the Fox Hills Sub-Area of the City. The Project would support the Project Objective to reduce VMT by increasing employee density in proximity to transit and housing.
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TABLE 4.6-7
CONSISTENCY WITH APPLICABLE SCAG CONNECT SOCAL ACTIONS AND STRATEGIES Actions and Strategies
Responsible
Party(ies) Consistency Analysis
Create incentives for local jurisdictions and agencies that support land use policies and housing options that achieve the goals of SB 375.
State, SCAG No Conflict. While this action applies to the State and SCAG, the Project would be consistent with and would not conflict with the goals of SB 375, including the goal to reduce VMT and the corresponding emission of GHGs. The Project is a mixed-use development with residential and retail uses that would increase residential, retail and employee density in proximity to transit and housing and would provide bicycling and pedestrian facilities. Furthermore, the Project would implement a TDM Program, as described in Project Design Feature TRAF-PDF-2, to reduce vehicle trips and VMT by encouraging walking and non-automotive forms of transportation, which would result in corresponding reductions in transportation-related emissions.
Transportation Network Actions and Strategies
Collaborate with local jurisdictions to plan and develop residential and employment development around current and planned transit stations and neighborhood commercial
centers.
SCAG, CTCs,
Local Jurisdictions
No Conflict. While this action applies to local jurisdictions, SCAG and CTCs, the Project is currently served by several public transit options, including Culver CityBus 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 Metro Bus Lines 108 and 110, as well as Culver CityBus Line 6.
Encourage transit fare discounts and local vendor product and service discounts for residents and employees of
TOD/HQTAs or for a jurisdiction’s local residents in general who have fare media.
Local Jurisdictions No Conflict. While this action applies to local jurisdictions and CTCs, the Project’s land use characteristics, including its location near transit, housing, and bicycle/pedestrian facilities, would encourage non-automotive forms of transportation. Additionally, the Project’s TDM Program, as described in Project Design Feature TRAF-PDF-2 in Section 4.11, Transportation, of this Draft EIR, would provide a TIC, which is 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.
Transportation Demand Management (TDM) Actions and Strategies Support work-based programs that encourage emission
reduction strategies and incentivize active transportation commuting or ride-share modes.
SCAG, Local
Jurisdictions
No Conflict. While this action applies to local jurisdictions and SCAG, the Project is proposed in an area well served by public transit. The Project would also provide a TDM Program, as described in Section 4.11, Transportation, of this Draft EIR, which would provide a TIC, which is 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. In addition, the Project’s TDM Program (TRAF-PDF-2) would feature the measure Employee Parking where at least 10 percent 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. Also, the Project’s TDM Program (TRAF-PDF-2) would feature Bicycle Parking and Amenities that 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).
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TABLE 4.6-7
CONSISTENCY WITH APPLICABLE SCAG CONNECT SOCAL ACTIONS AND STRATEGIES Actions and Strategies
Responsible
Party(ies) Consistency Analysis
Encourage the development of telecommuting programs by
employers through review and revision of policies that may discourage alternative work options.
Local Jurisdictions,
CTCs
No Conflict. While this action applies to local jurisdictions and CTCs, the telecommuting programs for the Project’s uses will depend on the office tenants that occupy those uses. While the Project would not implement any telecommuting programs, the Project would provide a TDM Program (TRAF-PDF-2), as described in Section 4.11, Transportation, of this Draft EIR, which would provide a TIC, which is 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.
Clean Vehicle Technology Actions and Strategies
Support subregional strategies to develop infrastructure and supportive land uses to accelerate fleet conversion to electric or other near zero-emission technologies. The activities committed in the two subregions (Western Riverside COG
and South Bay Cities COG) are put forward as best practices that others can adopt in the future.
SCAG, Local
Jurisdictions
No Conflict. While this action applies to local jurisdictions and SCAG, the Project would not interfere with the City of Culver City’s or SCAG’s ability to encourage the use of alternative- fueled vehicles through various policies and programs. The Project would provide a total of 428 parking spaces. While the CCMC no longer has any minimum amount of required parking for any use citywide, the Project’s voluntarily provided parking would meet CCMC Section
17.320.035.O.3 parking design requirements regarding EV Capable, EV Ready and spaces with full EV charging stations (see discussion above for specific number of spaces provided for each by the Project). The Project would comply with the CCMC as applicable for electric vehicle parking.
SOURCE: SCAG, 2020-2045 Regional Transportation Plan/Sustainable Communities Strategy (2020-2045 RTP/SCS), referred to as Connect SoCal, May 2020, p. 21 and 46. The actions and strategies included in Connect SoCal are similar to, and consistent with the 2012-2035 and 2016-2040 RTP/SCS.
ESA, 2024.
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Construction Emissions
As explained in the subsection, Methodology, the emissions of GHGs associated with construction of the Project were calculated for each year of construction activity. Detailed emissions calculations including a complete list of construction equipment, construction phasing, and other assumptions are provided in Appendix C. Construction is anticipated to commence in the second quarter of 2025 and is expected to take approximately 30 months to complete. Project operations are expected to commence in 2027. Results of the Project’s construction related GHG emissions calculations are presented in Table 4.6 -8, Project Construction GHG Emissions. Although construction related GHGs are one-time emissions, any assessment of Project emissions should include construction emissions. The SCAQMD recommends that a project’s construction -related GHG emissions be amortized over the project’s 30-year lifetime, so that GHG reduction measures will address construction GHG emissions as part of the operational GHG reduction strategies. The Project’s estimated construction GHG emissions have been amortized over a 30-year period in accordance with SCAQMD guidance.
It is estimated that the Project would export approximately 57,000 cubic yards of soil, all of which would be exported from the Project Site. It should be noted that the GHG emissions shown in Table
4.6-8 are based on construction equipment operating continuously throughout the workday. In reality, construction equipment tends to operate periodically or cyclically throughout the workday.
Therefore, the GHG emissions shown reflect a conservative estimate.
TABLE 4.6-8
PROJECT CONSTRUCTION GHG EMISSIONS
Year CO2e (Metric Tons)a
2025 1,140
2026 858
2027 358
Total Construction Emissions 2,356
Amortized Construction Emissions (30-years) 79
a Totals may not add up exactly due to rounding in the modeling calculations Detailed emissions calculations are provided in Appendix C.
SOURCE: ESA, 2024.
Although GHGs are generated during construction and are accordingly considered one -time emissions, it is important to include them when assessing all of the long-term GHG emissions associated with a project. As recommended by the SCAQMD, construction-related GHG emissions were amortized over a 30 -year project lifetime in order to include these emissions as part of a project’s annualized lifetime total emissions. In accordance with this methodology, the estimated Project’s construction GHG emissions have been amortized over a 30-year period and are added to the annualized operational GHG emissions.
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Operational Emissions
The Project’s annual GHG emissions included emissions from operations and construction calculated by CalEEMod and EMFAC for mobile source emissions. As previously described, construction GHG emissions for the entire construction period were amortized over 30 years. The Project must comply with the portions of the City of Culver City’s Green Building Code and mandatory Green Building Program. These plans and policies are intended to reduce GHG emissions in accordance with the goals of AB 32. As explained above, the Project’s mobile source emission calculations associated with the Project are calculated using the VMT from the VMT Calculator, which is attached in Appendix C, prepared for the Project.
The Project would implement Project Design Feature GHG-PDF -1 (Green Building Features), which include the Project buildings achieving the USGBC LEED Certified performance level or higher to improve building energy efficiency. LEED Certification requires documenting achievement of the rating system requirements and the required credits after the completion of construction. Projects may achieve credits in a variety of categories, including categories that are relevant to energy such as Location and Transportation, Water Efficiency, and Energy and Atmosphere. It not yet known which specific credits in each of the LEED categories the Project will achieve; therefore, it is not possible at this time to accurately quantify specific amounts of energy and VMT reducti on and associated GHG emissions reductions the Project would achieve from LEED Certification above regulatory requirements. Therefore, LEED Certification is not quantitatively accounted for in this analysis.
Maximum unmitigated, annual net GHG emissions resulting from on road mobile sources, area sources (landscape maintenance equipment , refrigerants), energy (i.e., electricity, natural gas), water conveyance and wastewater treatment, and solid waste were calculated for the Project buildout year (2026). The Project’s total and net GHG emissions from operation of the Project are shown in Table 4.6-9, Estimated Annualized Unmitigated Project GHG Emissions.
Physical and operational Project characteristics for which sufficient data are available to quantify the reductions from building energy and water consumption (see Section 4.13.1 , Utilities and Service Systems – Water Supply, for water usage) have been included in the quantitative analysis and include water reduction and efficiency features such as: low flow faucets and water -efficient landscape design with weather -based controllers and drip irrigation systems The Project would 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. There is no quantification of the TDM P rogram (TRAF-PDF-2) in Section 4.11, Transportation.
4. Environmental Impacts Analysis
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TABLE 4.6-9
ESTIMATED ANNUALIZED UNMITIGATED PROJECT GHG EMISSIONS
Emissions Sources
Operational Emissions CO2e
(metric tons per year)a
Proposed Project
Project without GHG
Reduction Characteristics,
Features, and Measures
Opening Operational Year (2026)
Mobile 1,399 1,399
Area 10 10
Energy (Electricity and Natural Gas) 344 488
Waste 40 40
Water 39 39
Amortized Construction Emissions 79 79
Total Project Emissions 1,911 2,055
Existing Emissions 409 409
Net Emissions 1,646 1,502
Emissions Reduction 144 —
Percent Reduction 10.0% —
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.
While other methodologies for calculating Project GHG reduction efficiencies exist, this analysis compares the Project’s GHG emissions to the emissions that would be generated by the Project without implementation of GHG reduction characteristics, features, and measures and is presented here for informational purposes only, in order to evaluate the efficacy of the GHG reduction characteristics, features, and measures that would be implemented as part of the Project as required by GHG reduction plans and policies. This comparison is provided to evaluate the Project’s efficiency with respect to GHG emissions but is not the threshold of significance used for impact analysis. The analysis assumes the Project without implementation of GHG reduction characteristics, features, and measures would incorporate the same land uses and building square footage as the Project.
Furthermore, this analysis is consistent with the current regulatory policies and GHG quantification methods. As shown in Table 4.6-9, the Project would achieve a 50 percent diversion rate for solid waste, similar to the Project without Reduction Features scenario, as this diversion rate is based on compliance with AB 939. Reductions to emissions from energy are due to GHG-PDF-1 where the Project would only utilize electricity and no natural gas in all land uses except for the retail space, whereas the Project without Reduction Features scenario would use utilize both electricity and natural gas in all land uses. While building electrification would result in higher electricity usage, it would greatly reduce the use of a fossil fuel and the associated GHG emissions (i.e., natural gas combustion) from building energy demand since only the retail space still uses natural gas.
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The quantification of GHG emissions for the Project without implementation of GHG reduction characteristics, features, and measures scenario is evaluated based on the specific and defined circumstances that CARB relied on when it projected the State’s GHG emissions in the absence of GHG reduction measures in the Climate Change Scoping Plan. (For complete list of assumptions refer to Appendix C of this Draft EIR).
Emissions reductions from the Project’s two highest GHG-emitting sources, mobile and electricity, would decrease over the next decade due to state mandates discussed above, and beyond, ensuring that the Project’s total GHG emissions would be further reduced. Emissions from electricity would decline as utility providers, including SCE, meet their RPS obligations consistent with SB 350 and SB 100, which would achieve additional reductions in emissions from electricity demand. Although the actual reduction will depend on the mix of fossil fuels that the utility providers will replace with renewables and the relative CO
2 intensities of those fossil fuels. Project emissions from mobile sources would also decline in future years as older vehicles are replaced with newer vehicles resulting in a greater percentage of the vehicle fleet meeting more stringent combustion emissio ns standards, such as the model year 2017 –2025 Pavley Phase II standards. It should be noted that Project-related GHG emissions presented above are provided for informational purposes as there is no numeric threshold applicable to the Project. The Project’s evaluation of consistency with the relevant plans to reduce GHG emissions is the basis for determining the significance of the Project’s GHG-related impacts on the environment.
Post Buildout Emissions
Executive Orders S -3-05 and B -30-25 establish a goal to reduce GHG emissions to 80 percent below 1990 levels by 2050. This goal has not been codified by the Legislature and CARB has not adopted a strategy or regulations to meet the 2050 goal. However, studies have shown that, in order to meet the 2050 goal, aggressive technologies in the transportation and energy sectors, including electrification and the decarbonization of fuel, would be required.
The 2022 Scoping Plan Update is designed to chart a path to achieving an even stricter GHG goal of carbon neutrality by year 2045 and recognizes additional work will be required to fully design and implement any policies and actions identified in this plan to achieve the more stringent 2045 goal. 141
For example, the 2022 Scoping P lan Update acknowledges that ZEV technology for off- road equipment and for propulsion, such as commercial aircraft or ocean-going vessels, but that this type of research, technological development and policy would be necessary to meet the 2045 target.142 • Energy Sector: Technological improvements such as increased decarbonization of the electricity sector and additions to California’s renewable resource portfolio would favorably influence the Project’s emissions level.143
141 California Air Resources Board, 2022 Scoping Plan For Achieving Carbon Neutrality, November 16, 2022. 142 California Air Resources Board, 2022 Scoping Plan For Achieving Carbon Neutrality, November 16, 2022, pages 195-206.
143 California Air Resources Board, 2022 Scoping Plan For Achieving Carbon Neutrality, November 16, 2022, pages 184-194.
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• Transportation Sector: Anticipated deployment of improved vehicle efficiency, zero emission technologies, lower carbon fuels, and improvement of existing transportation systems all would serve to reduce the Project’s emissions level.144 The methodology used for GHG analysis in this section was prepared after thorough investigation of feasible methodologies to determine the potential GHG impacts associated with the Project. Due to the technological shifts required and the unknown parameters of the regulatory framework in 2045, quantitatively analyzing the Project’s impacts relative to the 2045 goal is speculative for purposes of CEQA. Despite the thorough investigation performed, due to the uncertainty regarding specific State and local actions that would be implemented to achieve the state’s carbon neutrality goal in 2045, calculating Project emissions levels for 2045 would be highly speculative.
Nonetheless, Statewide efforts are underway to facilitate the State’s achievement of those goals, and it is reasonable to expect the Project’s emissions level to decline as the regulatory initiatives identified by CARB in the 2022 Scoping Plan Update are implemented, and other technological innovations occur.
In addition, the Project is the type of land use development that is encouraged by Connect SoCal to reduce VMT and expand multi -modal transportation options in order for the region to achieve the GHG reductions from the land use and transportation sectors required by SB 375, which, in turn, advances the State’s long-term climate policies. The Project Site is located at a location served by several public transit options, including Culver CityBus 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 Metro Bus Lines 108 and 110, as well as Culver CityBus Line 6. In addition, the Project would include 92 bicycle parking spaces (11 short -term and 81 long- term spaces), as required by CMCC Section 7.05.015, as well as bicycle amenities as part of the Project’s TDM Program (TRAF-PDF-2). The Project’s bicycle parking spaces and facilities will be provided at various locations throughout the Project Site, which include short -term facilities (e.g., bicycle racks) and secure long -term bicycle parking (e.g., fully enclosed rooms or bicycle l ockers that protect the bicycle from inclement weather and accessible only to the owner). Therefore, the Project complies with complete street policies and would not conflict with implementation of Complete Streets policies. In addition, an existing Class II bike lane is provided on both sides of Hannum Avenue adjacent to the Project Site. Also, while no existing bicycle lanes are currently provided on Buckingham Parkway, the Culver City Bicycle & Pedestrian Action Plan calls for a Class IV bike lane to be installed, so additional bike amenities are expected to increase around the Project Site in the future. Therefore, the Project would facilitate pedestrian and bicycle movements by providing convenient access to and from on-site uses.
These Project characteristics are related to key GHG reduction strategies in Connect SoCal, which include locating uses in areas accessible to transit and providing biking infrastructure to improve active transportation options and transit access. Additional details regarding the Project’s furtherance of key GHG reduction strategies in Connect SoCal are discussed in Threshold (b). By
144 California Air Resources Board, First Update to the AB 32 Scoping Plan, May 2014, pages 55–56.
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furthering implementation of SB 375, the Project supports regional land use and transportation GHG reductions and would not conflict with State climate targets for 2030 and beyond.
Stated differently, the Project’s emissions total at buildout represents the maximum emissions inventory for the Project as California’s emissions sources are being regulated (and foreseeably expected to continue to be regulated in the future) in furtherance of the State’s environmental policy objectives. As such, given the reasonably anticipated decline in Project emissions once fully constructed and operational, the Project would not conflict with the 2030 and 2050 Statewide targets and Executive Orders S-3-05 and B-30-15.
Mitigation Measures
No mitigation measures are required as impacts would be less than significant.
Level of Significance after Mitigation
Not applicable. Project-specific impacts regarding GHG emissions were determined to be less than significant.
Cumulative Impacts
Impact Analysis
Analysis of GHG emissions is cumulative in nature because impacts are caused by cumulative global emissions . A dditionally, climate change impacts related to GHG emissions do not necessarily occur in the same area as the Project is located. Due to the complex physical, chemical, and atmospheric mechanisms involved in global climate change, there is no basis for concluding that the Project’s increase in annual GHG emissions would cause a measurable change in global GHG emissions necessary to influence global climate change. Newer construction materials and practices, energy efficiency requirements, and newer appliances tend to emit lower levels of air pollutant emissions, including GHGs, as compared to those built years ago; however, the net effect is difficult to quantify. The GHG emissions of the Project alone would not likely cause a direct physical change in the environment. According to CAPCOA, “GHG impacts are exclusively cumulative impacts; there are no non -cumulative GHG emission impacts from a climate change perspective.”
145 It is global GHG emissions in their aggregate that contribute to climate change, not any single source of GHG emissions alone. Given that the Project would generate GHG emissions that would not conflict with applicable reduction plans and policies and given that GHG emission impacts are cumulative in nature, the Project’s incremental contribution to cumulatively significant GHG emissions would be less than significant.
Although the Project is expected to emit GHGs, the emission of GHGs by a single project into the atmosphere is not itself necessarily an adverse environmental effect. Rather, it is the increased accumulation of GHG from more than one project and many sourc es in the atmosphere that may result in global climate change. A project’s GHG emissions typically would be very small in comparison to state or global GHG emissions and, consequently, they would, in isolation, have no significant direct impact on climate change. The State has mandated a goal of reducing statewide
145 California Air Pollution Control Officers Association (CAPCOA), Quantifying Greenhouse Gas Mitigation Measures, August 2010, p. 39.
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emissions to 40 percent below 1990 levels by 2030, even though statewide population and commerce are predicted to continue to expand. In order to achieve this goal, CARB is in the process of establishing and implementing regulations to reduce statewide GHG emissions. Currently, there are no applicable CARB, SCAQMD, or City of Culver City significance thresholds or specific reduction targets, and no approved policy or guidance to assist in determining significance at the project or cumulative levels. Additionally, there is currently no generally accepted methodology to determine whether GHG emissions associated with a specific project represent new emissions or existing, displaced emissions. Therefore, consistent with CEQA Guidelines Section 15064(h)(3),
146 the City of Culver City, as lead agency, has determined that the Project’s contribution to cumulative GHG emissions and global climate change would be less than significant if the Project would not conflict with the applicable regulatory plans and policie s to reduce GHG emissions: Climate Change Scoping Plan, SCAG’s Connect SoCal , and Culver City’s Green Building Program.
As described above, the CARB’s Climate Change Scoping Plan illustrates that implementation of the Project’s regulatory requirements and project design features, including State mandates, would contribute to GHG reductions. These reductions represent a reduction from the Project without implementation of GHG reduction characteristics, features, and measures scenario and support State goals for GHG emissions reduction. The methods used to establish this relative reduction are consistent with the approach used in CARB’s 2022 Climate Change Scoping Plan for the implementation of AB 32.
The Project would be consistent with the approach outlined in CARB’s Climate Change Scoping Plan, particularly its emphasis on the identification of emission reduction opportunities that promote economic growth while achieving greater energy efficiency and accelerating the transition to a low- carbon economy. In addition, as recommended by CARB’s Climate Change Scoping Plan, the Project would use “green building” features as a framework for achieving GHG emissions reductions as new buildings would be designed to comply with the CCMC and the CALGreen Building Code.
As part of SCAG’s Connect SoCal, a reduction in VMT within the region is a key component to achieving the 2035 GHG emission reduction targets established by CARB. As discussed previously, the Project Site’s characteristics demonstrate that the Project’s VMT would be reduced based on its location near public transit, provision of bicycling/pedestrian access and facilities, and a TDM Program, as described in Project Design Feature TRAF-PDF-2.
The Project would comply with the City of Culver City Green Building Program, which emphasizes improving energy conservation and energy efficiency, and increasing renewable energy generation.
146 As indicated above, the CEQA Guidelines were amended in response to SB 97. In particular, the CEQA Guidelines were amended to specify that compliance with a GHG emissions reduction program renders a cumulative impact insignificant. Per CEQA Guidelines Section 15064(h)(3), a project’s incremental contribution to a cumulative impact can be found not cumulatively considerable if the project will comply with an approved plan or mitigation program that provides specific requirements that will avoid or substantially lessen the cumulative problem within the geographic area of the project. To qualify, such a plan or program must be specified in law or adopted by the public agency with jurisdiction over the affected resources through a public review process to implement, interpret, or make specific the law enforced or administered by the public agency. Examples of such programs include a “water quality control plan, air quality attainment or maintenance plan, integrated waste management plan, habitat conservation plan, natural community conservation plan, [and] plans or regulations for the reduction of GHG emissions.”
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The Project’s regulatory requirements and project design features (refer to Project Design Feature GHG-PDF-1) provided above and throughout this Draft EIR would advance these objectives.
Furthermore, the related projects would also be anticipated to comply with many of these same emissions reduction goals and objectives.
As discussed above, the Project would not conflict with the applicable GHG reduction plans and policies. The comparison of the Project’s emissions to a scenario without GHG reduction features demonstrates the efficacy of the measures contained in these policies. Moreover, while the Project is not directly subject to the Cap-and -Trade Program, that Program would indirectly reduce the Project’s GHG emissions by regulating “covered entities” that affect the Project’s GHG emissions, including energy, mobile, and construction emissions. More importantly, the Cap-and -Trade Program would backstop the GHG reduction plans and policies applicable to the Project in that the Cap-and-Trade Program would be responsible for relatively more emissions reductions if California’s direct regulatory measures reduce GHG emissions less than expected. The Cap -and- Trade Program would ensure that the GHG reduction targets of AB 32 and SB 32 are met.
The 2017 Scoping Plan demonstrates that the State’s existing and proposed regulatory framework would allow the State to reduce its GHG emissions level to 40 percent below 1990 levels by 2030.
Even though the 2017 Scoping Plan and supporting documentation do not provide an exact regulatory and technological roadmap to achieve the 2050 goal, they demonstrated that various combinations of policies could allow the statewide emissions level to remain very low through 2050, suggesting that the combination of new technologies and other regulations not analyzed in the studies could allow the State to meet the 2050 target.
Given that the Project would generate GHG emissions consistent with applicable reduction plans and policies and given that GHG emission impacts are cumulative in nature, the Project’s incremental contribution to cumulatively significant GHG emissions would not be cumulatively considerable, 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. Cumulative impacts regarding GHG emissions were determined to be less than significant.
4. Environmental Impacts Analysis
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4.7 Land Use and Planning
4.7.1 Introduction
Development on the Project Site is guided by land use policies and regulations set forth in local and regional plans and local zoning regulations. This section provides an analysis of the potential impacts of the Project with regard to land use and planning. The analysis in this section evaluates whether the Project would conflict with any land use plans, policies or regulations adopted for the purpose of avoiding or mitigating an environmental effect. Analyses of consistency and/or potential conflicts with plans that are more directly related to other environmental topics are addressed in other sections of this Draft EIR. Section 4.2, Air Quality, addresses relevant air quality plans and policies; Section 4.6, Greenhouse Gas Emissions, discusses relevant plans and policies to reduce greenhouse gas emissions; and Section 4.11, Transportation, discusses consistency with transportation plans.
4.7.2 Environmental Setting
Regulatory Framework
Following is a summary of the applicable local and regional regulatory land use plans, policies, and ordinances that apply to development at the Project Site. Specific provisions of these documents that pertain to land use are evaluated under the Environme ntal Impacts subsection for consistency with the Project.
State
California Government Code Section 65915
The State Density Bonus Law (DBL), Government Code section 65915, provides the opportunity to develop additional market -rate housing and receive other benefits in exchange for including affordable units in a project. The DBL promotes the construction of housing for low -income families, seniors, students, and other disadvantaged segments of the population. Assembly Bill (AB) 2345, which became effective January 1, 2021, amended the State DBL, found in Government Code 65915. Under AB 2345, the maximum available density bonus for projects not composed exclusively of affordable housing increased from 35 to 50 percent, where additional affordable units are built. To receive the maximum 50 percent density bonus, a project must comply with unit replacement requirements and set aside at least (1) 24 percent of units for low-income households, (2) 15 percent of units for very low -income households, or (3) 44 percent of for -sale units for moderate-income households. Bonuses between 35 and 50 percent are granted on a sliding scale, while current affordability requirements to obtain a lesser bonus will remain unchanged from the DBL. California Government Code Section 65302
California law requires that every city and county prepare and adopt a long-range comprehensive General Plan to guide future development and to identify the community’s environmental, social, and economic goals. As stated in Section 65302 of the California Government Code, “The general plan shall consist of a statement of development policies and shall include a diagram or diagrams and text setting forth objectives, principle, standard, and plan proposals.” While a general plan will contain the community vision for future growth, California law also requires each plan to address
4. Environmental Impacts Analysis
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the mandated elements listed in Section 65302. The mandatory elements for all jurisdictions are land use, circulation, housing, conservation, open space, noise, and safety.
Senate Bill 375
On September 30, 2008, Senate Bill (SB) 375 was instituted to help achieve Assembly Bill (AB) 32 goals through regulation of cars and light trucks. SB 375 aligns three policy areas of importance to local government: (1) regional long- range transportation plans and investments; (2) regional allocation of the obligation for cities and counties to zone for housing; and (3) achievement of greenhouse gas (GHG) emission reduction targets for the transportation sector set forth in AB 32.
It establishes a process for the California Air Resource Board (CARB) to develop GHG emission reduction targets for each region (as opposed to individual local governments or households). SB 375 also requires Metropolitan Planning Organizations (MPO) to prepare a Sustainable Communities Strategy (SCS) within the Regional Transportation Plan (RTP) that guides growth while taking into account the transportation, housing, environmental, and economic needs of the region. SB 375 uses California Environmental Quality Act (CEQA) streamlining as an incentive to encourage residential or mixed-use residential projects, which help achieve AB 32 goals to reduce GHG emissions.
Regional
Southern California Association of Governments Regional Transportation Plan/Sustainable Communities Strategy (Connect SoCal)
The Southern California Association of Governments (SCAG) is the designated regional planning agency for six counties: Los Angeles, Orange, San Bernardino, Riverside, Ventura, and Imperial.
SCAG is a joint powers agency with responsibilities pertaining to regional issues. SCAG’s mandated responsibilities include developing plans and policies with respect to the region’s population growth, transportation programs, air quality, housing, land use, sustainability, and economic development.
On September 3, 2020, the Southern California Association of Governments (SCAG) Regional Council adopted the 2020 –2045 Regional Transportation Plan/Sustainable Communities Strategy (RTP/SCS), also known as Connect SoCal. Connect SoCal presents a long-term transportation vision through the year 2045 for the six-county region of Imperial, Los Angeles, Orange, Riverside, San Bernardino, and Ventura counties. Connect SoCal contains baseline socioeconomic projections that are used as the basis for SCAG’s transportation planning, and the provision of services by other regional agencies. SCAG’s overarching strategy for achieving its goals is integrating land use and transportation. SCAG policies are directed towards the development of regional land use patterns that contribute to reductions in vehicle miles and improvements to the transportation system.
Rooted in past RTP/SCS plans, Connect SoCal’s “Core Vision” centers on maintaining and better managing the region’s transportation network, expanding mobility choices by co-locating housing, jobs, and transit, and increasing investment in transit and complete streets. The plans “Key Connections” augment the “Core Vision” to address challenges related to the intensification of core planning strategies and increasingly aggressive GHG reduction goals, and include but are not limited to, Housing Supportive Infrastructure, Go Zones, and Shared Mobility. Connect SoCal intends to create benefits for the SCAG region by achieving regional goals for sustainability, transportation equity, improved public health and safety, and enhancement of the regions’ overall
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quality of life. These benefits include but are not limited to a five percent reduction in vehicle miles traveled (VMT) per capita and vehicle hours traveled by nine percent, increase in work -related transit trips by two percent, create more than 264,500 new jobs, reduce greenfield development by 29 percent, and, building off of Connect SoCal, increase the share of new regional household growth occurring in High Quality Transit Areas (HQTA’s) 1 by six percent and the share of new
job growth in HQTAs by 15 percent. According to SCAG, the Project Site is located within an HQTA.2
Local
City of Culver City General Plan
State law requires that every city and county prepare and adopt a long-range comprehensive General Plan to guide future development and to identify the community’s environmental, social, and economic goals. The City’s General Plan includes nine elements th at have been updated at various points between 1968 and 2014. The City’s General Plan includes the Land Use Element (adopted in 1996 and amended through 2004), the Circulation Element (amended through 1995), the Housing Element (approved in 2022 ), the Open Space Element (approved in 1996), the Noise Element (approved in 1996), Conservation Element (adopted in 1973), Seismic Safety Element (adopted in 1974), Public Safety Element (adopted in 1975), and Recreation Element (adopted in 1968). The City’s General Plan elements and policies relevant to the topic of land use and open space are discussed below. Other General Plan elements and policies related to topics addressed in this Draft EIR are discussed in applicable sections in Chapter 4, Environmental Impact Analysis.
The Circulation Element is addressed in Section 4.11, Transportation, elements and policies relevant to the topic of Housing are addressed in Section 4.9, Population and Housing, and Noise and Public Safety Elements are addressed in Sections 4.8, Noise, 4.10.1, Fire Protection , and
4.10.2, Police Protection, of this Draft EIR.
The City is currently in the process of comprehensively updating its General Plan to respond to changing needs and conditions in the City and region, and to reflect new state laws. The current General Plan update is the first time all of the elements are t o be updated at one time. Since the General Plan Update is not yet adopted, the analysis in this section compares the Project to the current General Plan.
However, for informational purposes, 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 is Mixed- Use High which permits 100 dwelling units per acre, consistent with the 2022 Housing Element preferred designation and density.
Land Use Element
The Land Use designation of the Project Site is Commercial - Regional Center. This designation allows large-scale commercial uses and is intended to support existing and anticipated regional -
1 HQTAs are corridor-focused areas within 0.5 mile of an existing or planned transit stop or a bus transit corridor with a 15-minute or less service frequency during peak commuting hours. 2 SCAG GIS data (High Quality Transit Areas (HQTA) 2045 – SCAG Region) available online. https://gisdata- scag.opendata.arcgis.com/datasets/43e6fef395d041c09deaeb369a513ca1_1/explore. Accessed November 13, 2023.
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serving commercial developments. The Commercial - Regional Center designation is intended to support existing and anticipated regional -serving commercial de velopments. The designation is characterized by areas with a two-to three -story height limit, recognizing the proximity to residential neighborhoods, and other areas with up to a 56-foot height limit.
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 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. The Commercial - Regional Center along Hannum Avenue reflects the long -standing existence of regional -serving commercial uses within this area of the City.
3 As indicated in the Land Use Element, Figure LU-12, the Project Site is located within the Fox Hills Sub-Area of the City. Issues specific to the Fox Hills Sub-Area, pertain to a lack of connection to other areas in the City, safety, and moderate-income housing opportunities . No specific objectives or policies were identified for or are directly applicable to the Project Site.
For informational purposes, as stated above, the draft Land Use Element under consideration as part of Culver City’s General Plan 2045 Update, the Project Site’s draft land use designation is Mixed-Use High and permitted density is 100 dwelling units per acre, consistent with the 2022 Housing Element preferred designation and density.
Housing Element
The Housing Element was created to provide an assessment of current and future housing needs, and the constraints in and resources for meeting those needs. It also identifies and prioritizes the housing needs of the City and outlines the goals, policies, and programs to address those needs while balancing community character, objectives, and resources. State law requires Housing Elements to be updated at least every eight years to reflect a community’s changing housing needs. The most recent update was appr oved in October 2022 and covers an eight -year period, extending from October 2021 through October 2029. The primary issues addressed in the Housing Element include:
1) preservation and improvement of the existing housing stock, 2) housing availability for special needs populations, 3) planning for a sufficient supply of new housing to meet the city’s fair share of regional need, and 4) fair housing. The 2021-2029 Housing Element indicated that the total housing growth need for the City during the 2021-2029 planning period is 3,341 units. Under the approved Housing Element, the Project Site is designated as Mixed -Use High. Per the City’s 2021- 2029 Housing Element, Mixed-Use High land uses are permitted to develop up to 100 units per acre.
Open Space Element
The intent of the Open Space Element is to protect, expand, and enhance, visible and usable open space resources. The Open Space Element identifies existing City resources; provides open space
3 City of Culver City, General Plan Land Use Element, adopted 1996, amended through 2004, page LU-20, https://www.culvercity.org/files/assets/public/v/1/documents/planning-amp-development/advance- planning/general-plan/landuseelement.pdf. Accessed September 7, 2023.
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definitions and standards; and presents goals, objectives and open space policies. 4 Objective 1 addresses open space protection and acquisition, Objectives 2 and 3 address active and passive recreation, respectively, and Objective 4 addresses natural areas. Policy 2.C of the Open Space Element encourages private sponsorship of bikeway or public park land improvements in exchange for development incentives. In addition, Policy 3.E is to provide seating, bike rack, and drinking fountains in passive recreation areas. The Open Space Element also addresses the streetscape, which is implemented through the City’s Bicycle and Pedestrian Action Plan, the Urban Forest Master Plan, and the Municipal Code.
Culver City Bicycle & Pedestrian Action Plan
The City updated the Bicycle & Pedestrian Master Plan with the Culver City Bicycle & Pedestrian Action Plan (Action Plan) which received public input from 2017 through 2019. The Action Plan was adopted by the City Council in June 2020.
5 The Action Plan establishes the visions and values
that focus on establishing walking and cycling as viable modes of travel for all trip types. The Action Plan aims to provide a safe, convenient, and accessible active transportation network. The Action Plan includes goals to support increased access to neighborhood destinations and transit stations, empowering residents to live a more active lifestyle, and increasing affordability and collaboration for transportation within the community. Both sides of Hannum Avenue, adjacent to the Project Site, contain a Class II Bike lane. The approved Action Plan shows that Buckingham Parkway between Hannum Avenue and Green Valley Circle, immediately adjacent to the Project Site, are planned as Class IV Separated Bikeways.
6 Section 4.11, Transportation, of this Draft EIR
includes a list of applicable actions set forth in the Action Plan that are applicable to the Project, as well as a Project consistency analysis with these actions.
Culver City Urban Forest Master Plan
The Culver City Urban Forest Master Plan (UFMP) is a comprehensive long -term management plan that includes designations of tree species to be planted on each street segment when an existing tree must be removed, and best management practices for tree plann ing, preservation, and maintenance. In addition, the UFMP includes recommendations for green connections throughout the City to encourage recreation, walking, biking and public transit use. Recommendations are also provided for plant palettes and planting structure, places of priority, designations of trees and plants to assist with wayfinding and placemaking, and action areas and strategies to be implemented by the City in public areas.
7 As indicated in the UFMP, in the vicinity of and adjacent to the Project
4 City of Culver City, General Plan Open Space Element, adopted 1996, amended through 2004, https://www.culvercity.org/files/assets/public/v/1/documents/planning-amp-development/advance- planning/general-plan/openspaceelement.pdf. Accessed September 7, 2023. 5 City of Culver City, Bicycle & Pedestrian Action Plan, June 2020, https://www.culvercity.org/files/assets/public/v/1/documents/public-works/mobility/2021-10-cc-bikepedplan- app2020-v10-final.pdf. Accessed September 7, 2023.
6 As defined by Caltrans, a Class IV separated bikeway is an on-street facility that is physically separated from other motor vehicle traffic by a vertical element or barrier, such as a curb, bollards, or vehicle parking aisle. 7 City of Culver City, Culver City Urban Forest Master Plan, 2015, https://www.culvercity.org/files/sharedassets/public/v/1/city-hall/culver_city_urban_forest_master_plan.pdf.
Accessed September 7, 2023.
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Site, Hannum Avenue and Buckingham Parkway are designated as proposed bicycle routes, where additional trees and landscaping are recommended to provide shade and aid in wayfinding.8 City of Culver City Municipal Code
The Culver City Zoning Code (Title 17 of the Culver City Municipal Code [CCMC]) implements the policies of the General Plan by classifying and regulating the uses of land and structures within the City. The zoning designation of the Project Site is Regional Business Park (CRB), which is consistent with the Regional Center land use designation in the General Plan. 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.
Adjacent zoning designations include CRB directly across Hannum Avenue to the north and to the west of the Project Site. Zoning designations east and south of the Project Site include RHD (Residential High Density Multiple) across Buckingham Parkway and Open Space (OS) to the northeast (Fox Hill Parkette). Across Hannum Avenue to the northeast is zoned CN (Commercial Neighborhood).
CCMC Sections 17.240.010 and 17.240.015 describe the purpose and requirements of the Culver City Planned Development (PD) District as allowing large scale residential and commercial complexes within a physically integrated and contiguous area and which may only be applied to sites of 1 acre or greater. Development requires the approval of a Comprehensive Plan through a rezoning of the site. No building may exceed 56 feet in height, and all utilities within the limits of a PD zone must be located underground. The allowed uses and development standards for PD districts are developed as part of the project approval process.
CCMC Section 17.560, Comprehensive Plans, provides requirements and procedures for reviewing Comprehensive Plans, which allow for flexibility in the application of Z oning Code standards to proposed development. Per the Zoning Code (Title 17 of the CCMC) , 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.
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 (111 total parking spaces) 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 above mean sea level (amsl) and the southernmost elevation (near Windsor Way) at approximately 103 feet amsl. 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
8 City of Culver City, Culver City Urban Forest Master Plan, 2015, page 164.
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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, via an access easement through the adjacent property to the west.
As discussed above, the General Plan land use designation of the Project Site is Commercial - Regional Center. Figure 4.7 -1, Project Site and Surrounding Land Use Designations, illustrates General Plan land use designations for the Project Site and surrounding areas. The zoning designation of the Project Site is Regional Business Park (CRB), which is consistent with the Regional Center land use designation in the General Plan. Figure 4.7 -2, Zoning on the Project Site and in the Surrounding Area, illustrates the zoning designations for the Project Site and surrounding uses.
A Tree Inventory Report was prepared for the Project and is included in Appendix A of the Initial Study (see Appendix A of this Draft EIR for a copy of the Initial Study). No native or heritage trees were observed during the tree survey. A total of 119 tre es are located within the Project Site including carrotwood, Canary Island Pine, Brazilian pepper, olive, weeping bottlebrush, paperbark, and podocarpus were recorded as part of the survey. Fourteen (14) carrotwood street trees were observed along Buckingh am Parkway and all others were observed throughout the Project Site.
There are no street trees on Hannum Avenue.
As discussed in detail in Section 4.11, Transportation, of this Draft EIR, the Project Site and local area is served by five bus lines, which include City Bus Lines 2, 3 and 5C2, as well as Los Angeles Bus Local Lines 108 and 110. These bus lines are shown in Figure 4.11-1, Existing Transit Service, of this Draft EIR. The Culver City Transit Center is also located approximately 0.6 miles west of the Project Site, but 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. Also, adjacent to the Project Site, both sides of Hannum Avenue contain a Class II Bike lane. Additionally, a Class II bike lane follows both sides of Centinela Avenue from Green Valley Circle to Bristol Parkway, as shown in Figure 4.11-2 , Existing Bicycle Facilities , in Section 4.11, Transportation , of this Draft EIR.
Pedestrian access is provided via sidewalks located along Hannum Avenue, Buckingham Parkway, and Uplander Way.
Surrounding Uses
The Project Site is located in an urban area and represents infill redevelopment at the southwest corner of the intersection at Hannum Avenue and Buckingham Parkway. 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 the following:
• No
rth – Land uses to the north across Hannum Avenue have a General Plan land use designation of Commercial - Regional Center. Office uses directly north of the site are part of the larger office complex known as Corporate Pointe, which is bounded by Hannum Avenue to the west and south, Bristol Parkway to the south and east, and Slauson Avenue to the north.
Within Corporate Pointe, between Bristol Parkway and Buckingham Parkway, there are six office buildings (up to 12-stories) and three parking structures (up to 8-stoies).
Project
Site
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.7-1
Project Site and Surrounding Land Use Designations
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5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.7-2
Zoning on the Project Site and in the Surrounding Area
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• East – Land uses to the east across Buckingham Parkway include multi -family residential (up to 4 -stories) uses and the Fox Hills Parkette. The multi -family uses are designated by the General Plan for Planned Residential Development use, while the Fox Hills Parkette has an Open Space land use designation.
• West – A business park building and surface parking lot are located immediately adjacent to the west of the Project Site. This area has a General Plan land use designation of Commercial – Regional Center.
• South – Because of the curved nature of Buckingham Parkway, the uses south of the Project Site are considered to include multi-family residential uses (up to 4-stories) across Buckingham Parkway, which are designated by the General Plan for Planned Residential Development use.
See Figures 4.7- 1 and 4.7-2 for illustrations of the General Plan land use and zoning designations, respectively, of the surrounding land uses.
4.7.3 Environmental Impacts
Thresholds of Significance
The following threshold of significance is based on the Environmental Checklist contained in Appendix G of the CEQA Guidelines. A project would result in significant adverse impacts related to Land Use and Planning if it would:
• LU-1 Cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
Potentially significant impacts related to the Project’s potential to conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect are discussed and analyzed further below.
The City determined in the Initial Study that the following environmental issue area would result in no impacts or less-than-significant impacts and, therefore, is 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:
• Physically divide an established community.
As detailed in the Initial Study, provided in Appendix A -2 of the Draft EIR, the Project Site is currently developed with a two-story office building, surface parking and ornamental landscaping.
The Project vicinity is urbanized and generally built out and is characterized by a mix of office, business park and residential uses and includes a fully developed roadway system. As such, the Project would represent redevelopment and infill development of an already developed site.
Furthermore, the Project would n ot close any public streets or otherwise alter established infrastructure in the area. The Project would encourage multiple modes of travel by providing bicycle access and bicycle parking spaces. Therefore, the Project would not physically divide an established community. No further analysis of this issue is therefore included in this Draft EIR.
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Methodology
The analysis of potential land use impacts considers consistency of the Project with adopted plans, regulations, and development guidelines, and in some instances advisory guidance, which are applicable to the Project Site and the Project and that have been adopted for the specific purpose of avoiding or mitigating an environmental effect.
CEQA Guidelines Section 15125(d) requires an EIR include a discussion of any inconsistencies between the proposed project and applicable general plans, specific plans, and regional plans.
Separately, Appendix G recommends that a lead agency consider whether the project would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
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 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.
This Land Use section evaluates Project consistency with applicable plans, policies and regulations that have been adopted for the purpose of avoiding or mitigating an environmental effect. These include SCAG’s Connect SoCal , the Culver City General Plan and the 2021-2029 Housing Element, the Culver City Bicycle & Pedestrian Action Plan, the Culver City UFMP, and the Culver City Municipal Code. With the exception of the Culver City UFMP and Culver City Municipal Code, the applicable plans, policies and regulations are evaluated in detail in Tables 4.7-1 through
4.7-3. The results and determination of whether the Project would cause a significant environmental impact due to a conflict with any applicable land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect considers the Project’s potential to conflict with applicable plans/policies/regulations as shown on the tables and summarized in the impact analysis below. Policies relevant to land use and planning within these planning documents is provided within this Land Use and Planning section. To the extent that the Projects’ potential to conflict with a plan, program or policy is analyzed in another section of the EIR , that plan is not
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further discussed in the Land Use Section. For example, consistency with air quality plans is analyzed in Section 4.2, Air Quality, of this Draft EIR. However, the UFMP and the Culver City Bicycle & Pedestrian Action Plan are also evaluated in Section 4.1, Aesthetics, and 4.11, Transportation, respectively, with analyses pertinent to those issues areas provided therein.
Project Design Features
There are no Project Design Features relative to land use and planning.
Analysis of Project Impacts
Threshold LU -1: The Project would have a significant impact if it would cause a significant environmental impact due to a conflict with any land use plan, policy, or regulation adopted for the purpose of avoiding or mitigating an environmental effect.
Impact Analysis
SCAG’s Connect Socal
SCAG’s Connect SoCal incorporate goals that are applicable to the Project. These SCAG goals are discussed below. Table 4.7-1, Consistency of the Project with Applicable Goals of Connect Socal, provides a detailed analysis of the Project’s consistency with applicable Connect SoCal goals.
TABLE 4.7-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF CONNECT SOCAL Strategy Would the Project Conflict?
Goals
Encourage regional economic prosperity and
global competitiveness.
No Conflict. This goal pertains to SCAG funding and policies. The Project would not adversely affect the capacity to encourage regional economic prosperity and global competitiveness. As the Project does provide regional economic benefits and does so in a manner consistent with other Connect SoCal goals as discussed below, the Project would support SCAG policies related to this goal.
Improve mobility, accessibility, reliability, and
travel safety for people and goods.
No Conflict. The location of the Project Site, in proximity to the Culver City Transit Center and multiple regional and local bus lines, the I-405, and bicycle facilities, would serve to improve mobility, accessibility, reliability, and travel safety for people and goods in support of this goal. Also, the Project would provide approximately 5,600 sf of retail use which would provide goods to the residents on-site and adjacent neighboring land uses.
Enhance the preservation, security, and
resilience of the regional transportation
system.
No Conflict. The proximity of the Project Site to alternative transit modes, including regional and local bus lines, would support the region’s transportation investment and the sustainability of the regional transportation system.
Increase person and goods movement and
travel choices within the transportation
system.
No Conflict. The location of the Project Site, in proximity to the Culver City Transit Center, multiple regional and local bus lines, the I-405, and bicycle facilities, would support an increase in person and goods movement and increase the available travel choices within the transportation system.
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TABLE 4.7-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF CONNECT SOCAL Strategy Would the Project Conflict?
Reduce greenhouse gas emissions and
improve air quality.
No Conflict. The Project would provide a pedestrian-friendly design, promote access from the nearby transit options, as well as provide bicycle parking and storage facilities for Project residents, employees, and visitors. The Project would also be designed to include electric vehicle parking and charging stations and a solar photovoltaic per the City’s Green Building Ordinance and CALGreen standard.
Furthermore, as discussed in Section 4.11, Transportation, the Project would implement a Transportation Demand Management Program as a project design feature to VMT. All of these features would reduce GHG emissions and improve air quality.
Support healthy and equitable communities. No Conflict. As noted above, the Project would implement design features to reduce air quality and GHG impacts, including compliance with the City’s Green Building Ordinance and CALGreen standard (refer to Sections 4.2, Air Quality, and 4.4, Greenhouse Gas Emissions, of this Draft EIR). The Project includes the provision bicycle parking spaces and associated amenities and pedestrian amenities in proximity to the Culver City Transit Center and multiple regional and local bus lines as well as commercial points of interest including the Westfield Culver City Mall and commercial businesses along Hannum Avenue, thereby promoting a healthier and more active lifestyle. The Project would also provide a gym for Project residents.
Adapt to changing climate and support an
integrated regional development pattern and
transportation network.
No Conflict. The Project would develop mixed-use residential and retail uses within proximity to the Culver City Transit Center and multiple regional and local bus lines, the I-405, and bicycle facilities.
The Project’s accessibility to numerous alternative transportation facilities and provision of bicycle facilities would support an integrated regional development pattern and transportation network that would reduce GHG emissions.
Leverage new transportation technologies
and data-driven solutions that result in more
efficient travel.
No Conflict. This goal pertains to SCAG leveraging new
transportation technologies and data-driven solutions that result in more efficient travel. The Project would not adversely affect SCAG’s ability to develop more efficient travel consistent with this goal.
Encourage development of diverse housing
types in areas that are supported by multiple
transportation options.
No Conflict. Development of the proposed mixed-use development with residential and retail uses would include diverse housing types in support of this goal, including 282 market-rate units and 27 units affordable to very low income households, within proximity to multiple transportation options. The Project would, thus, not conflict with SCAG’s goal to encourage the development of diverse housing types in an area with multiple transit options.
Promote conservation of natural and
agricultural lands and restoration of habitats.
No Conflict. As detailed in the Initial Study, provided in Appendix A-2 of this Draft EIR, the Project Site does not contain agricultural uses or related operations, nor is the Project Site located within a designated riparian habitat or support suitable habitat for candidate, sensitive, or special status species; as such, the development of the Project would not conflict with this goal to promote conservation of natural agricultural lands and restoration of habitats.
Focus Growth Near Destinations and Mobility Options
Emphasize land use patterns that facilitate
multimodal access to work, educational and
other destinations.
No Conflict. The Project represents an intensification of development in proximity to public transit options including the Culver City Transit Station, numerous bus lines and bicycle lanes, and as such, would not conflict with this strategy that emphasize land use patterns facilitating multi-modal access to work and other destinations.
Plan for growth near transit investments and
support implementation of first/last mile
strategies.
No Conflict. The Project would not conflict with strategies that plan for growth near transit investments and support implementation of first/last mile strategies. The Project Site is located in close proximity to the Culver City Transit Center, multiple regional and local bus lines, and bicycle facilities. Connect SoCal recommends an increase in the number of trips accomplished by walking, bicycling, and the use of I
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TABLE 4.7-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF CONNECT SOCAL Strategy Would the Project Conflict?
micro-mobility devices to reduce automobile vehicle miles traveled (VMT) (Connect SoCal, page 69). These strategies include building physical infrastructure such as local and regional bikeways, sidewalk improvements, and first-last mile connections to transit. According to Connect SoCal, these strategies would also improve air quality and public health by reducing emissions and increasing levels of physical activity. Because of its proximity to transit, the Project would encourage walking between the transit options and the Project Site. In addition, with public sidewalk improvements and safe vehicle egress at all driveways, and proximity to employment opportunities and services in the local area, the Project would encourage walking (a first mile/last mile strategy) between the Project Site and public transit, as well as nearby employment opportunities. The Project would not conflict with Connect SoCal strategy to reduce automobile vehicle miles, reduce air emissions, and improve public health through first/last mile strategies. Therefore, the Project would not conflict with policies that encourage growth near transit investments and support implementation of first/last mile strategies.
Prioritize infill and redevelopment of
underutilized land to accommodate new
growth, increase amenities and connectivity
in existing neighborhoods.
No Conflict. The Project would not conflict with policies that prioritize infill redevelopment to accommodate new growth, increase amenities and connectivity in existing neighborhoods. The Project would represent an infill development that would increase amenities, including public amenities, and connectivity in the existing area. As an infill use, it would not result in urban sprawl or other effects that would conflict with the objectives of Connect SoCal to reduce vehicle miles and improve air quality. Therefore, the Project would not conflict with policies that prioritize infill and redevelopment of underutilized land to accommodate new growth, increase amenities and connectivity in existing neighborhoods.
Encourage design and transportation options
that reduce the reliance on and number of
solo car trips (this could include mixed uses
or locating and orienting close to existing
destinations).
No Conflict. The Project would not conflict with strategies that encourage design and transportation options that reduce the reliance on, and number of, solo car trips. The Project would implement a transportation demand management (TDM) Program to reduce the Project’s single occupant vehicle trips and increase the trips arriving via alternative modes of transportation (e.g., walking, bicycle, carpool, vanpool, and transit). 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 not limited to, the following:
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; Pedestrian-Friendly Environment; Employee Parking; Bus Stop Improvements. Additional TDM strategies that will be offered 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, but may not be limited to: Project Transportation Coordinator and Transportation Information Packet for New Residents and Employees (see Section
4.11, Transportation, of this Draft EIR for a detailed explanation of all TDM measures contained in TRAF-PDF-2). Therefore, the Project would not conflict with policies that encourage design and transportation options that reduce the reliance on and number of solo car trips.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-15 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF CONNECT SOCAL Strategy Would the Project Conflict?
Support Implementation of Sustainability Policies
Support development of local climate
adaptation and hazard mitigation plans, as
well as project implementation that improves
community resiliency to climate change and
natural hazards.
No Conflict. 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 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. The Project’s environmentally sustainable building features and construction protocols would meet the requirements of Culver City’s mandatory Green Building Program requirements and CALGreen Building Code. Sustainability features would include, but would not be limited to, water-efficient landscape design, rainwater management systems, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use; EV charging, EV capable, and EV ready spaces; and bicycle facilities that would meet City requirements; Energy Star–labeled appliances, where possible; energy-efficient and water conserving HVAC systems; active indoor/outdoor air circulation, and adequate daylight. These features would reduce energy and water usage and hydrological hazards. Therefore, the Project would support local climate adaptation and hazard mitigation plans, as well as implement policies that improve community resiliency to climate change and natural hazards.
Support local policies for renewable energy
production, reduction of urban heat islands
and carbon sequestration.
No Conflict. The Project would remove the existing asphalt paved surface parking lot, which contributes to heat island effects. The Project would incorporate an extensive landscaping program in accordance with CCMC requirements. Existing canopy street trees would remain along Buckingham Parkway and Hannum Avenue as well as 56 new trees interior to the Project Site. Planted areas within the Project perimeters and within the interior courtyard, would serve to minimize heat island effects and promote carbon sequestration. The Project’s building design would include a solar system and EV parking and charging facilities. All of The Project’s landscaping would emphasize the use water-saving native plantings. contribute to passive cooling strategies and enhanced biodiversity. Therefore, the Project’s landscaping and building design would not conflict with policies for renewable energy and reduction of heat islands and carbon sequestration.
Promote more resource efficient
development focused on conservation,
recycling and reclamation.
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 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. Sustainability features would include water-efficient landscape design, rainwater management systems, high efficiency plumbing fixtures and weather-based controller and drip irrigation systems to promote a reduction of indoor and outdoor water use. With the implementation of these features, the Project would not conflict with policies that support resource efficient development focused on conservation, recycling, and reclamation.
Preserve, enhance and restore regional
wildlife connectivity
No Conflict. The Project is located within a developed, urban area.
Wildlife in the surrounding area is limited to migrating species, such as birds, which do not access the area through ground-level corridors.
Although the Project would not block or divert any existing wildlife ground corridors, the Project’s tree program could accommodate migrating bird species that frequent the region. Therefore, the Project would not conflict with strategies to enhance and restore regional wildlife connectivity.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-16 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-1
CONSISTENCY OF THE PROJECT WITH APPLICABLE GOALS OF CONNECT SOCAL Strategy Would the Project Conflict?
Reduce consumption of resource areas,
including agricultural land
No Conflict. The Project is located within an existing developed site, surrounded by existing urban development. Therefore, the Project would not consume natural areas or agricultural land and would not conflict with the policy to reduce consumption of resource areas, including agricultural land.
Identify ways to improve access to public
park space
No Conflict. The Project would provide 7,507 square feet of publicly accessible open space as part of the Hannum Plaza fronting Hannum Avenue. The Project operator would maintain the public open space area’s hardscape and landscape, as well as manage any commercial vendors using the amenity area. With the incorporation of an outdoor open space area for public use, the Project would not conflict with programs to Identify ways to improve access to public park space.
SOURCE: ESA, 2023.
Based on the analysis presented in Table 4.7-1, the Project would not conflict with policies/strategies adopted to avoid or mitigate an environmental effect and, as such, impacts with respect to Connect SoCal would be less than significant.
City of Culver City General Plan
As shown in Figure 4.7-1, the Culver City 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.
The Project is requesting a discretionary approval from the City to permit the Project’s proposed mix of multi-family and retail uses, in the form of a General Plan Amendment Map to re-designate the Project Site from Regional Center to General Corridor. The General Corridor designation would permit the Project’s proposed uses and is consistent with the proposed zoning designation amendment from CRB to Planned Development (PD). For informational purposes, a draft General Plan Land Use map was released by the City on September 29, 2023 which largely conforms to the approved Housing Element map. Under both the approved Housing Element map and the draft General Plan Land Use map, the Project Site would be designated as Mixed-Use High, which would allow 100 dwelling units per acre. The draft General Plan also limits nonresidential floor area ratio (FAR) to 4.0:1. The Project would have a FAR of 3.73:1.
The Project would provide a mixed-use development consisting of 309 units of multi-family housing, of which 27 would be affordable units, as well as 5,600 sf of retail use. The housing units would range in size and would include studio, one-bedroom and two-bedroom units, thereby providing housing opportunities for all members of the community. The commercial uses would include retail, which would contribute to the economic diversity within the City. The Project would redevelop the Project Site with a site plan that would revitalize the area through a cohesive design that would integrate uses and provide various community benefits, including 7,507 sf of publicly accessible open space and affordable housing, as well as streetscape improvements. The Project would activate the pedestrian environment in the area by providing ground level commercial space that fronts on the streets, and
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
publicly accessible open space areas. The provision of publicly accessible open space at the intersection of Hannum Avenue and Buckingham Parkway would contribute to a sense of place and would provide a gathering area that would liven the pedestrian environment (see Figure 2 -4). In addition, the Project would enhance the Project frontage sidewalks with street trees, lighting, and aesthetic treatments on building facades. Refer to Section 4.1, Aesthetics, for further discussion of the Project’s design characteristics and renderings of the proposed building.
Table 4.7-2, Comparison of the Project to Applicable Policies of the Culver City General Plan , evaluates the consistency of the Project with objectives and policies of the adopted General Plan Land Use Element, Housing Element, Open Space Element, and Noise Element.
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
Land Use Element
Goal: Residential neighborhoods that offer residents the qualities of a peaceful, small-town environment.
Objective 1. Neighborhood Character. Protect
the low-to medium density character of residential
neighborhoods throughout the City
• Policy 1.B. Protect the City’s residential
neighborhoods from encroachment of
incompatible land uses and environmental
hazards which may have negative impacts on
the quality of life (such as traffic, noise, air
pollution, building scale and bulk, and visual
intrusions).
No Conflict. Development of the Project, which would include both commercial and multi-family residential uses, would serve as a transition between the surrounding residential uses to the east and the commercial uses to the north, west and south. The Project’s multi- family residential uses would be similar to the adjacent multi-family uses to the east of the Project Site across Buckingham Parkway, while offering retail uses that could also be used by the adjacent residents. As discussed throughout this Draft EIR, operation of the Project would not result in any long-term significant impacts to the environment or adjacent residential areas. Thus, no long-term environmental hazards which may have negative impacts on the quality of life would occur from Project implementation.
Objective 2. Housing Supply. Encourage the
retention and creation of housing throughout the
City.
• Policy 2.B. Continue to allow and encourage
multiple family housing opportunities in areas
designated for such development.
No Conflict. The Project would provide 309 multi-family residences on a property that is designated Regional Center. The Project would require a General Plan Amendment Map to designate the Project Site as General Corridor, which would allow the proposed multi-family residential uses. The multi-family uses allowed under proposed designation is consistent the City’s draft General Plan Land Use map released by the City on September 29, 2023 which largely conforms to the approved Housing Element map. Under both the approved Housing Element map and the draft General Plan Land Use map, the Project Site would be designated as Mixed-Use High, which would allow 100 dwelling units per acre. The Project would provide 309 multi-family units and approximately 5,600 sf of commercial floor area.
Thus, the Project would encourage and provide multi-family housing opportunities on a site that is contemplated for residential use in its various foreseeable planning documents.
• Policy 2.E. Develop standards and guidelines
for residential unit development in appropriate
commercial areas.
No Conflict. The Project’s Comprehensive Plan would incorporate standards to ensure that the proposed mixed-use development would be compatible with the surrounding area. The Comprehensive Plan would include requirements for the Project’s proposed uses, setbacks, height, parking, as well as open space and landscape requirements.
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. The
Comprehensive Plan would be reviewed and approved by the City.
The design standards in the Comprehensive Plan have been developed to all the Project to serve as a between the surrounding residential uses to the east and the commercial uses to the north, west and south.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-18 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
Objective 3. Affordable Housing. Encourage the
provision of housing opportunities for all members
of the community.
No Conflict. The Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one-bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community. Therefore, the Project would not conflict with policies related to affordable housing.
Goal: Economic Vitality that serves the community and protects the quality of life.
Objective 5. Economic Diversity. Encourage new
business opportunities that expand Culver City’s
economic base and serve the needs of the City’s
residential and business community.
No Conflict. The Project would redevelop the Project Site with a mix of multi-family residential and retail uses. The Project inclusion of 5,600 sf of new retail floor area would provide new business opportunities in the area that support the Project’s residential uses, as well as the neighboring residential and business park/office uses. The Project’s proposed 309 residential units would provide much needed housing within the City per the City’s updated Housing Element goals and SCAG’s 6
th Cycle Regional Housing Needs Assessment (RHNA)
allocation (see Section 4.9, Population and Housing, of this Draft EIR, for further discussion of this issue).
• Policy 5.D. Provide development incentives for
projects that provide specific community or
neighborhood needs.
No Conflict. As stated above, the Project would provide much needed housing within the City, including affordable housing. 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 percent 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 would be within the allowed number of units with the density bonus incentives included.
Objective 7. Commercial Centers. Maintain
commercial centers that serve the community as
well as regional markets.
• Policy 7.B. Allow existing regional and
community centers to upgrade and expand in
response to changing market conditions, to
maintain their economic viability, with adequate
mitigation of impacts to nearby residential
neighborhoods
No Conflict. The Project would provide 309 multi-family residences on a property that is designated Regional Center. The Project would require a General Plan Amendment Map to designate the Project Site as General Corridor, which would allow the proposed multi-family residential uses. Based on the current market conditions, operation of the existing on-site office uses in no longer a viable financial option.
Furthermore, the proposed multi-family and retail uses allowed under the Project’s proposed General Corridor designation is consistent the City’s draft General Plan Land Use map released by the City on September 29, 2023 which largely conforms to the approved Housing Element map. Under both the approved Housing Element map and the draft General Plan Land Use map, the Project Site would be designated as Mixed-Use High, which would allow 100 dwelling units per acre. The Project would provide 309 multi-family units and approximately 5,600 sf of commercial floor area. Thus, the Project would provide land uses that are consistent with the current market demands and housing needs of the City. Also, as discussed throughout this Draft EIR, operation of the Project would not result in any long-term significant impacts to the environment or adjacent residential areas.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-19 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
Objective 8. Fiscal Health. Foster the growth of
businesses that increase City revenues by
promoting attractive, quality retail establishments
that serve neighborhood, community and regional
markets.
• Policy 8.A. Support desirable retail
establishments in proximity to residential
neighborhoods that provide needed goods and
services.
No Conflict. The Project would result in a mixed-use development with 309 multi-family residential units and approximately 5,600 sf of retail use. The retail use would provide goods and services to Project residents, while also serving residents in the surrounding neighborhoods. Further, the Project would change the character and quality of the existing dated office building and parking lot site to a new, modern high-quality architecturally designed building. See Section 4.1, Aesthetics, of this Draft EIR, for further discussion and renderings of the Project’s building.
Objective 12. Urban Design. Ensure that new
construction and renovation of existing residential
and non-residential buildings and streetscapes are
accomplished with the highest quality of
architectural and site design.
No Conflict. The Project would redevelop the Project Site with an integrated, high-quality, mixed-use development that would provide 309 residential units and approximately 5,600 sf of commercial uses.
The Project would create an active streetscape through the provision of ground level retail use as well as approximately 7,507 sf of publicly accessible open space. The provision of publicly accessible open space at the intersection of Hannum Avenue and Buckingham Parkway would contribute to a sense of place and would provide a gathering area that would liven the pedestrian environment. The Project’s open space areas would include amenities, such as planting areas, walkways, trees, and seating areas. With the provision of open space, the building setbacks would vary on the Site with the retail use close to the street, which would serve to activate the street. Private balconies for the residential units would provide articulation and would break up the building mass. High-quality building materials would be varied and would include concrete, brick veneer, and glass. The overall color palette would be warm and soft, including white, brown, and grey, which would contribute to the architectural look and feel of the structure. Therefore, the Project would not conflict with policies to provide high quality urban design.
Open Space Element
Objective 3. Passive Recreation. Provide passive
recreational open space within walking distance of
all City neighborhoods.
No Conflict. As indicated above in Policy 5.D, the Project would provide a total of approximately 54,156 sf of open space, including 7,507 sf of publicly accessible open space, which would exceed the minimum requirement of 23,175 sf of common and/or private open space. The 7,507 sf Hannum Plaza at the corner of Hannum Avenue and Buckingham Parkway, would include amenities such as seating and landscape designed to serve residents, visitors, retail space users, and community members. The open space and gathering areas on the Project Site would be within walking distance from nearby neighborhoods. In addition, the Project would provide common open space for Project residents in the form of an amenity deck, community rooms, a gym, and open air courtyard. Therefore, the Project would not conflict with policies to provide passive recreational open space within walking distance of residential neighborhoods.
Housing Element
Goal 1: A city that proactively provides equitable
access to safe, healthy, and affordable housing for
all income levels to create a balanced jobs-to-
housing ratio and commits to addressing the
housing needs of persons experiencing
homelessness and special needs populations.
Goal 2: A city with a variety of rental and
ownership housing opportunities that complement
and enhance the city's goals for continued
economic vitality and prosperity.
Goal 3: A city that plans to grow sustainably and
intelligently by revisiting policies and programs
frequently to update and adjust if they are not
meeting goals.
No Conflict. The Project would redevelop the Project Site with an integrated, high-quality, mixed-use development that would provide 309 residential units of which 27 would be affordable, and approximately 5,600 sf of commercial uses. The Project would not conflict with goals identified in the Housing Element.
I I
I I
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-20 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
Goal 4: A city that affirmatively furthers fair
housing to reverse the legacy of segregation and
provide housing and opportunity for historically
disenfranchised groups.
Objective 1. Housing Maintenance. Encourage a
high level of housing maintenance to promote the
availability of decent housing and to protect the
quality of neighborhood environments.
• Policy 1.B: Maintain quality neighborhood
living environments throughout the entire city.
No Conflict. The Project would redevelop the Project Site with an integrated, high-quality, mixed-use development that would provide 309 residential units and approximately 5,600 sf of commercial uses.
The Project would create an active streetscape through the provision of ground level retail use as well as approximately 7,507 sf of publicly accessible open space. The provision of publicly accessible open space at the intersection of Hannum Avenue and Buckingham Parkway would contribute to a sense of place and would provide a gathering area that would liven the pedestrian environment and maintain a quality neighborhood living environment.
• Policy 1.F: Promote sustainable development
through energy conservation, water
consumption, and waste reduction measures to
reduce future operating costs, and ensure local
regulations support environmental justice that
protects public health and open space, and
expands the tree canopy.
No Conflict. The Project design incorporates environmentally sustainable building features and construction protocols required by the applicable Culver City Green Building Program and CALGreen Building Code. These standards would reduce energy and water usage and waste and, thereby, reduce associated GHG emissions and help minimize the impact on natural resources and infrastructure.
The Project design would include sustainability features, including energy saving and sustainable design features that would be incorporated into the Project as the proposed buildings would comply with the applicable Title 24 California Code of Regulations. 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 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. 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.
Objective 2. Housing Supply. Expand
opportunities for developing a variety of housing
types.
• Policy 2.A: Provide for a residential lifestyle
that is environmentally sound and aesthetically
pleasing and that places a high priority on
quality development.
No Conflict. The Project would result in a mixed-use development with 309 multi-family residential units and approximately 5,600 sf of retail use. The retail use would provide goods and services to Project residents, while also serving residents in the surrounding neighborhoods. Further, the Project would change the character and quality of the existing dated office building and parking lot site to a new, modern high-quality architecturally designed building. See Section 4.1, Aesthetics, of this Draft EIR, for further discussion and renderings of the Project’s building.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-21 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
• Policy 2.B: Coordinate the plans, programs,
and policies of all city departments to ensure
that residential development is orderly, and that
new development is adequately and effectively
served by a balanced system of transportation,
transit, amenities, community facilities, and
public services. Residential development must
be sensitive to the environmental, recreational,
social, and economic needs of the community.
The City should promote access, where
feasible, to the LA Metro E Line Culver City
Station, for new residential development.
No Conflict. The Project supports this policy by introducing a development that is conducive to walking, biking, and taking transit.
The Project would introduce new bicycle parking and additionally would enhance pedestrian rights-of-way by introducing increased sidewalk widths, publicly available open space as part of the Hannum Plaza, and enhanced streetscape, landscape and street trees along Hannum Avenue and Buckingham Parkway. Existing transit options within close proximity to the Project Site would allow for pedestrian and bicycle access to public transit.
• Policy 2.C: Promote mixed use residential
development that is sensitive to adjacent
residential uses and reinforce the compatible
nonresidential uses of the area.
No Conflict. The Project would redevelop the Project Site with a mix of multi-family residential and retail uses. The Project inclusion of 5,600 sf of new retail floor area would provide new business opportunities in the area that support the Project’s residential uses, as well as the neighboring residential and business park/office uses. • Policy 2.D: Encourage the incremental infilling
of residential neighborhoods to enhance
housing affordability and supply through the
provision of smaller units.
No Conflict. the Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one-bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community. Therefore, the Project would not conflict with policies related to housing affordability or supply. • Policy 2.E: Promote programs that seek to
provide housing opportunities to meet the
needs of people who work in the city.
No Conflict. The Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one-bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the project would support programs that seek to provide housing opportunities to meet the needs of people who work in the city.
Objective 3. Housing Affordability: Encourage a
diverse range of rental and ownership housing
opportunities that are compatible with the needs of
all socioeconomic segments of the community.
• Policy 3.A: Encourage the inclusion of
affordable housing units in new housing
developments by granting incentives as called
for by the Zoning Code and the State Density
Bonus law.
No Conflict. The Project would provide much needed housing within the City, including affordable housing. 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 percent 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 would be within the allowed number of units with the density bonus incentives included.
• Policy 3.B: Actively support affordable housing
development by private and non-profit housing
developers.
No Conflict. The Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one-bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community. Therefore, the Project would not conflict with the development of affordable housing.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-22 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
• Policy 3.F: Encourage an equitable distribution
and the production of affordable housing in
areas that have historically not accommodated
affordable housing or have excluded diverse
housing opportunities, especially in the highest
opportunity areas, to help overcome historic
patterns of segregation. Explore strategies like
public funding, incentives, infrastructure
investments, and a “Right to Return” program to
support historically displaced families and
individuals in Culver City with housing.
No Conflict. As described above, the Project would provide 309 residential units, of which 27 would be affordable. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community.
Therefore, the Project would not conflict with the development of affordable housing.
• Policy 3.J: Incentivize housing development on
surface parking lots on underused sites that
would not displace existing residents.
No Conflict. The Project would redevelop the Project Site with a mix of multi-family residential and retail uses. The Project Site is currently developed with an existing two-story office building and associated surface parking. Through the provision of residential uses, the Project would provide housing opportunities on the Project Site that is not currently developed for residential use. Therefore, the Project would not displace existing residents or conflict with this policy.
Objective 4. Housing Access: Improve access to
quality housing for all members of the community
by eliminating discrimination, reducing
governmental and non-governmental constraints,
increasing the number of affordable housing units,
and supporting access to emergency shelters
• Policy 4.A: Promote efforts aimed at the
development of housing available to all income
and age levels.
No Conflict. The Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one-bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community. Therefore, the Project would not conflict with this policy.
• Policy 4.B: Promote housing opportunities for
households of all income levels to help maintain
the family-oriented character of the city into the
future.
No Conflict. As described above, the Project would provide 309 residential units, of which 27 would be affordable. In addition, the Project would provide a mix of units, with 39 studio units, 180 one- bedroom units, and 90 two-bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the community. Therefore, the Project would not conflict with this policy.
Noise Element
Goal: A Community that Minimizes Noise Disturbance.
Objective 1. Land Use Compatibility. Ensure that
compatibility of land uses with regard to noise
sources and receptors.
No Conflict. The Project would consist of multi-family and retail uses, a central internal courtyard, and amenity deck on the 6 th floor and the
publicly accessible Hannum Plaza. The proposed uses would not include uses such as entertainment venues, restaurants, manufacturing, or other uses that could potentially generate high noise levels. Adjacent uses include business park, office and multi- family residential uses. The most sensitive receptors would be the residential uses to the east and south of the Project Site across Hannum Avenue. As discussed in Section 4.8, Noise, of this Draft EIR, the operation of the Project would not increase noise levels that would exceed the City’s noise standards at any sensitive receptor site.
Therefore, the Project would not conflict with policies to ensure compatibility of land uses with regard to noise sources and receptors.
4. Environmental Impacts Analysis
4.7. Land Use and Planning
City of Culver City 4.7-23 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.7-2
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY GENERAL PLAN Objective/Policy Would the Project Conflict?
Objective 2. Stationary Noise Sources. Protect
those areas that are or may be subject to
unacceptable noise from stationary noise sources.
No Conflict. The highest stationary noise generator in the operation of the Project would be from heating and cooling systems. The publicly accessible, privately maintained Hannum Plaza would not accommodate large gatherings of people so as to cause unacceptable noise to residents across Hannum Avenue. The central courtyard, which could result in larger gatherings would be generally shielded from residential uses to the east and south across Hannum Avenue.
As further discussed in Section 4.10, Noise, of this Draft EIR, the operation of the Project would not increase ambient noise levels that would exceed the City’s noise standards at any of the receptor sites.
Therefore, the Project would not conflict with policies to protect sensitive receptors from stationary noise sources.
Objective 3. Transportation-Related Noise
Sources. Protect those areas that are or may be
subject to noise from transportation noise sources.
No Conflict. Vehicle traffic generated by the Project would result in an increase in ambient noise levels, particularly during commuting hours.
However, as discussed in Section 4.10, Noise, of this Draft EIR, noise levels from these mobile sources would not increase ambient noise levels that would exceed the City’s noise standards at any of the receptor sites. Therefore, the Project would not conflict with policies to protect sensitive receptors from transportation noise sources.
SOURCE: ESA, 2023.
As discussed in Table 4.7-2, the Project would be consistent with the objectives and policies of the Land Use Element. The Project would support Land Use Element Policy 1.B by providing a high- quality architecturally design building that would serve a transition between the surrounding residential uses to the east and the commercial uses to the north, west and south, while result in no long-term significant environ mental impacts; Policy 2.B by providing multi-family housing opportunities; Policy 2.E by imple menting site -specific design standards and guidelines in a Comprehensive Plan; Objective 3 by providing housing for all members of the public, including the provision of affordable housing; Objective 5 by providing new business opportunities that expand the City’s economic base while serving the needs of the residential and business communities; Policy
5.D through the inclusion of development incentives for providing affordable housing; Policy 7.B by providing uses that are reflective of current market conditions and provide much needed housing in the City; Policy 8.A by providing retail uses in proximity to residential neighborhoods; and Objective 12 by supporting urban design through high quality architecture and site design.
The Project would also be consistent with the objectives and policies of the Housing Element. The Project supports Housing Element Objectives 1 through 4 by redeveloping the Project Site with an integrated, high-quality, mixed -use development that would provide 309 residential units and approximately 5,600 sf of commercial uses. The Project would create an active streetscape through the provision of ground level retail use as well as approximately 7,507 sf of publicly accessible open space. The provision of publicly accessible open space at the intersection of Hannum Avenue and Buckingham Parkway would contribute to a sense of place and would provide a gathering area that would liven the pedestrian environment and maintain a quality neighborhood living environment. Development of the proposed mixed-use development with residential and retail uses would include diverse housing types, including 282 market -rate units and 27 units affordable to very low income households, within proximity to multiple transportation options . In addition, the
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Project would provide a mix of units, with 39 studio units, 180 one -bedroom units, and 90 two- bedroom units. Through the provision of affordable units and a range in unit size, the Project would provide housing opportunities for all members of the communit y in support of Policy 2.D, Policy
2.E, Policy 3.A, Policy 3.B, Policy 3.F, Policy 4.A, and Policy 4.B. For informational purposes, 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 is Mixed-Use High which permits 100 dwelling units per acre, consistent with the Housing Element preferred designation and density.
In regards to the General Plan Open Space Element, the Project would be consistent with the Objective 3 by providing approximately 7,507 sf of publicly accessible open space. A total of 54,156 sf of open space would be provided, which would exceed the minimum requirement of 23,175 sf of common and/or private open space on the Project Site that would be accessed from Hannum Avenue and Buckingham Parkway, as well as from the interior of the Project Site. Publicly accessible open space would include Hannum Plaza with amenities, such as seating, planting areas, and walkways.
In addition, the Project would provide common open space for Project residents in the form of the amenity deck, community rooms, a gym, an open air courtyard, and private balconies.
As discussed in Section 4.10, Noise, of the Draft EIR, the Project would not increase ambient noise levels that would exceed the City’s noise standards at any sensitive receptor sites from construction stationary or mobile noise sources and, thus, would not conflict with policies in the Noise Element to ensure compatibility of land uses with regard to noise sources and receptors.
Overall, the Project would not conflict with Culver City General Plan policies adopted to avoid or mitigate an environmental effect and, as such, impacts with respect to the General Plan would be less than significant.
Culver City Bicycle & Pedestrian Action Plan
Although the objectives, policies, and actions of Action Plan are directed towards the City and therefore not directly applicable to the Project, the Project would support the Action Plan through the provision of an enhanced streetscape plan, bicycle parking and other bicycle amenities that would serve to encourage alternative forms of transportation . Table 4.7 -3, Comparison of the Project to Applicable Policies of the Culver City Bicycle & Pedestrian Action Plan, evaluates the consistency of the Project with objectives and policies of the Action Plan. As discussed therein, the Project would provide bicycle and pedestrian facilities to promote alternative transit for residents, visitors and employees at the Project Site. The Project’s intensification of development on the Project Site near multiple transit options would support public transit service. Also, the Proje ct’s design would minimize the potential for collisions involving bicyclists and pedestrians through safe and comfortable bicycle and pedestrian facilities. Vehicular access to the Project Site would be provided via the Hannum Avenue driveway and Buckingham Parkway 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. Pedes trian access to the Project would be provided via separate lobby and retail entrances along Hannum Avenue. As described in Section 4.11, Transportation, development of the Project would maintain the existing Class II bike lane on Hannum; however, the Hannum Driveway would intersect with the eastbound bike lane on the south side of Hannum Avenue. To
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ensure maximum visibility, the Hannum Driveway would meet all of the City’s requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site as well as bicyclists and pedestrians wishing to cross the driveway.
TABLE 4.7-3
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY BICYCLE &
PEDESTRIAN ACTION PLAN
Policies Would the Project Conflict?
Goal 1- Access and Connectivity
Objective AC-1. Increase access and connectivity to
jobs, education, retail, parks and libraries, schools,
recreation centers, transit, and other neighborhood
destinations.
No Conflict. The Project Site is located within an urban environment well served by public transit. The Project would support this policy by enhancing pedestrian circulation and promoting an active streetscape with access to alternative transportation options (bus and bicycle facilities) through increased sidewalk widths, enhanced streetscape, landscape and street trees along Hannum Avenue and Buckingham Parkway. The Project would be located adjacent to existing bike lanes on Hannum Avenue that would provide access to the Project’s retail and residential uses. The Project would include 92 bicycle parking spaces to accommodate cyclists. The Project would enhance the Project frontage sidewalks with street trees, lighting, and aesthetic treatments on building facades. Because the Project would accommodate cyclists and would improve pedestrian routes in the area, it would not conflict with policies to education, retail, parks and libraries, schools, recreation centers, transit, and other neighborhood destinations.
Objective AC-2. Support public transit service. No Conflict. The Project would intensify development and occupancy with new residents, visitors and employees associated with the retail uses within proximity to the Culver City Transit Station, multiple regional and local bus lines, and bicycle facilities which provide a range of alternative transit opportunities. Also, 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 activated streetscape would promote walking to available transit options. With these features, the Project, the Project would not conflict with policies to support public transit service.
Goal 2 – Health and Safety
Objective HS-1. Reduce collisions involving bicyclists
and pedestrians through safe and comfortable bicycle
and pedestrian facilities.
No Conflict. An existing Class II bike lane is provided on both sides of the street adjacent to the Project. Development of the Project would maintain the existing bike lane; 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 of the City’s requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site as well as bicyclists and pedestrians wishing to cross the driveway.
No exceptional horizontal or vertical curvatures exist along this section of roadway that would create sight distance issues for Project traffic utilizing the proposed driveway. Therefore, the Project would not conflict with policies to reduce collisions involving bicyclists and pedestrians through safe and comfortable bicycle and pedestrian facilities.
Objective HS-3. Use infrastructure and programs to
promote an active lifestyle that includes bicycling and walking.
No Conflict. The Project would provide bicycle parking that would support active bicycle use by residents, visitors and on-site employees. The Project’s proximity to a range of transit options including the Culver City Transit Center, bus routes, and bike lanes, and other commercial uses and services and residential neighborhoods in the area would encourage pedestrian activity.
Therefore, the Project would not conflict with policies that use infrastructure and programs to promote an active lifestyle that includes bicycling and walking.
Objective HS-4. Reduce air pollution, asthma rates,
and greenhouse gas emissions.
No Conflict. The Project would provide a pedestrian-friendly design, promote access from the nearby transit options, as well as provide bicycle parking and storage facilities for Project residents, employees, and visitors. The Project would also be designed to include electric vehicle parking and charging stations and a solar photovoltaic per the City’s Green Building Ordinance and CALGreen standard. Furthermore, as discussed in Section 4.11, Transportation, the Project would implement a TDM Program as a project design feature to VMT. All of these features would reduce GHG emissions, improve air quality and serve to reduce asthma rates.
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TABLE 4.7-3
COMPARISON OF THE PROJECT TO APPLICABLE POLICIES OF THE CULVER CITY BICYCLE &
PEDESTRIAN ACTION PLAN
Policies Would the Project Conflict?
Goal 3 - Affordability
Objective A-1. Reduce long-term transportation
costs by reducing the need for vehicle ownership or
for parking in new developments.
No Conflict. The Project would provide on-site bicycle parking for residents, visitors, and employees. In addition, the Project would have access to a range of transportation options within walking distance, including a range of adjacent bus routes and bike lanes on Hannum Avenue. Because residents and employees could commute via the range of transit options in the area, the Project would not conflict with the policy to reduce long-term transportation costs by reducing the need for vehicle ownership or for parking in new developments.
SOURCE: ESA, 2023
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. 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 requirements and would provide adequate sight distance for drivers of vehicles entering and leaving the Project Site as well as bicyclists and pedestrians wishing to cross the driveway and loading area. Overall, the Project would not conflict with any of the applicable objectives of the Culver City Bicycle & Pedestrian Action Plan, as further discussed in Section 4.11, Transportation, of the Draft EIR.
Culver City Urban Forest Master Plan
Chapter 2 of the UFMP provides recommendations for the urban forest, beginning with the large scale and broad vision for the urban environment of the City. It envisions an urban forest to strengthen the important network of “green connections” throughout the City. More than just treelined streets, the UFMP describes a green infrastructure that includes the urban forest, park land, sustainable transportation networks, and pedestrian areas th at would provide vital functions for the City including improving air and water quality, mitigating the urban heat island effect, reducing energy demand, and improving public health. In the vicinity of the Project Site, Hannum Avenue and Buckingham Parkway are identified as bicycle routes. For each of these streets, the UFMP recommends trees in these areas to provide shade and to aid in wayfinding in an effort to promote cycling and walking. One of the most important components of the UFMP is the Tree Palette, which provides a plan for creating a more resilient urban forest in Culver City. The Tree Palette is a master list of the species that are recommended for Culver City’s urban forest based on proven local performance, ability to thrive in urban conditions, resiliency, environmental benefits, aesthetics, habitat/ecosystem value, and good “new” species for Culver City.
Currently, 14 carrotwood street trees are located along Buckingham Parkway and all other trees are located throughout the P roject Site. There are no street trees on Hannum Avenue. For any street tree removed, the Project would comply with the applicable provisions pertaining to the removal and replacement of street trees in the CCMC within Title 9: General Regulations, Chapter 9.08: Streets and Sidewalks – Tree Removal, Section 9.08.220: Removal of Trees in Parkways Related to Private
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Improvement or Development Project. Per the City’s requirements, the Project is required to plant two new Street Right-of-Way trees or Parkway trees for each tree that is removed from the site. The size and location of the replacement trees would be determined by the Department of Public Works based on what is appropriate for the particular Street Right -of-Way or Parkway. The Project anticipates that one street tree along Buckingham Parkway near the proposed driveway would be removed. This tree will either be re-planted or replaced along Buckingham Parkway and an additional tree would be planted along Buckingham Parkway to comply with City street tree replacement requirements.
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. In addition, the Project landscape design would incorporate trees along Hannum Avenue, with a tree palette consistent with that envisioned in the UFMP palette. The Project’s landscaping and trees would contribute to the improvements of Buckingham Parkway and Hannum Avenue envisioned in the UFMP. 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 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. As described in Section 4.1, Aesthetics, 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. N ew 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 identified in the UFMP’s performance criteria. The Project’s landscaping and trees would also enhance the pedestrian character of these streets. Because the Project would increase street trees in accordance with the UFMP palette and include a the landscaped, publicly accessible, privately maintained Hannum Plaza, it would not conflict with policies related to providing shade and wayfinding improvements within the designated bicycle routes shown in the UFMP along Hannum Avenue and Buckingham Parkway. Therefore, the Project would not conflict with UFMP policies adopted to avoid or mitigate an environmental effect and, as such, impacts with respect to this plan would be less than significant.
City of Culver City Municipal Code
As shown on Figure 4.7 -2, the Culver City zoning of the Project Site is CRB. The CRB zone 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 CRB zone permits industrial uses; recreation, education and public assembly; retail and service uses; and transportation and communication uses.
9 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
9 City of Culver City, CCMC Section 17.220.015.
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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 mor e effective responses to the settings of such properties and other environmental considerations. 10 To permit this, a
Comprehensive Plan regulates permitted uses, development standards, and conditions of approval on a Project Site.
CCMC Section 17.240.015, Planned Development (PD) District Requirements, sets forth requirements of PD designated areas. Per Section 17.240.015 A, development standards, allowable land uses and permit requirements for the PD Zoning District shall be established by a Comprehensive Plan. The minimum site area for PD Zoning is 1 acre or large, which the Project Site exceeds at 2.23 acres. Per Section 17.240.015 E, no building or structure in the PD Zone may exceed 56 feet in height, unless a height exception is granted pursuant to Section 17.300.025 (Height Measurement and Height Limit Exceptions). 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 developme nt incentive for providing affordable units. With this incentive, the Project would have a maximum building height of 78 feet. With this height increase, no significant physical impact to the environment would occur. Refer to Section 4.1, Aesthetics, of this Draft EIR for a discussion of aesthetics impacts. Also, Section 17.240.015.F (Underground Utilities), requires all utilities to be underground, which the Project would comply with.
Under CCMC Section 17.220.020, 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.
Under CCMC Sect ion 17.560.015.B, a 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 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.
CCMC Section 17.560, Comprehensive Plans, sets forth procedures for reviewing Comprehensive Plans. As stated in this section, the purpose is to allow consideration of innovation in site planning and other aspects of project design, and more effective design responses to site features, uses on adjoining properties, and other impacts than the zoning code standards would produce without
10 City of Culver City, CCMC Section 17.560.005
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adjustment. Consistent with Section 17.560.105 B, Comprehensive Plan Requirements, t he Project’s Comprehensive Plan includes a Site Plan; development standards, building plans, landscape plans, lighting and signage plans, civil engineering plans, and proposed Project uses and occupancy. CCMC Section 17.560.010, Finding and Decision, lists various findings the City must make as part of the approval process for a Comprehensive Plan. Consistent with the findings requirements, the Project would be completed wit hin four years, the Project is capable of creating an environment of sustained desirability and stability, and the proposed uses will not be substantially detrimental to present and potential surrounding uses as evidenced by the analysis in this Draft EIR (no long-term significant and unavoidable impacts), but will have a beneficial effect.
Also, the streets and thoroughfares serving the Project are suitable and adequate to carry anticipated traffic (refer to the non-CEQA traffic analysis included in the Project’s Transportation Assessment, included as Appendix I of this Draft EIR), and the development will not generate traffic that will overload the adjacent street network. The Project has been shown throughout this Draft EIR to be compatible with the surro unding area. The Comprehensive Plan is being proposed with a concurrent General Plan amendment in process. As shown in Section 4.13, Utilities and Service Systems, of this Draft EIR, existing and proposed utility services are adequate for the proposed uses. Finally, the Project’s Comprehensive Plan will comply with all applicable City requirements.
The Project is seeking approval of extended construction hours per CCMC Section 9.07.035.C.1 .
Per CCMC Section 9.07.035.A , Construction, allowed construction hours are 8:00 a.m. and 8:00 p.m. Mondays through Fridays; 9:00 a.m. and 7:00 p.m. Saturdays; 10:00 a.m. and 7:00 p.m.
Sundays. 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 earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction. The extended construction hours are being requested over the course of approximately four (4) months of construction. The other construction phases would occur per the allowable standard CCMC permitted construction hours. The request for extended construction hours will accompany the land use permit application and will be considered in conjunction with the P roject as a whole and will be subject to conditions of approval, as necessary. Refer to Section 4.10, Noise, of this Draft EIR for a discussion of noise impacts associated with the potential for extended construction hours.
Other ministerial approvals that would be required for the Project include, but may not be limited to, demolition, grading, excavation, and building permits as well as h aul route permits. None of these approvals would conflict with an applicable land use plan, policy or regulation of an agency with jurisdiction over the Project adopted for the purpose of avoiding or mitigating an environmental effect. These approvals have been assessed as part of the Project throughout this Draft EIR document.
Conclusion
Based on the analysis above, with approval of the requested discretionary actions, the Project would not conflict with or impede implementation of applicable land use plans, policies, or regulations of an agency with jurisdiction over the Project (including, but not limited to the general plan, specific plan, local coastal program, or zoning ordinance) adopted for the purpose of avoiding or mitigating an environmental effect. Therefore, the impact would be less than significant.
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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 land use and planning would be less than significant.
Cumulative Impacts
Chapter 3, Environmental Setting , of this Draft EIR provides a list of 12 related projects that are 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 Project would redevelop the Project Site and would represent infill development on an already urbanized site located near the Culver City Transit Center and multiple regional and local bus lines.
In addition, the Project includes the provision of bicycle and pedestrian amenities within a SCAG designated HQTA. The Project would be consistent with the proposed General Plan General Corridor land use designation and the proposed zoning designation of PD. As discussed above, for informational purposes, a draft General Plan Land Use map was released by the City on September 29, 2023 which largely conforms to the approved Housing Element map. Under both the approved Housing Element map and the draft General Plan Land Use map, the Project Site would be designated as Mixed-Use High, which would allow 100 dwelling units per acre. Currently, the City’s land use regulations do not specify or limit floor area ratio (FAR). It is anticipated that the draft General Plan would limit nonresidential FAR to 4.0:1. The Project would have a total FAR of 3.73:1, which is compliant with existing and potential development standards relating to FAR. The Project would also be consistent with other local and regional land use plans as discussed above.
Related projects are subject to CEQA review and review by City regulatory agencies. Most notably, related projects seeking increases in permitted densities or height are subject to review by the Culver City Planning Division Commission and other City departments and divisions for consistency with plan provisions and other City requirement s. The related projects represent infill development and as such are consistent with local and regional policies to concentrate development near public transit and encourage alternative transportation. Based on this and based on the determination that the Project would be consistent with the adopted land use plans and zoning, cumulative impacts regarding consistency with the land use regulatory framework 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 land use and planning would be less than significant.
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4.8 Noise
4.8.1 Introduction
This section analyzes potential noise and vibration impacts that would result from the Project. The analysis describes the existing noise environment in the vicinity of the Project Site, estimates future noise and vibration levels at surrounding land uses resulting from construction and operation of the Project, identifies the potential for significant impacts, and includes mitigation measures to address significant impacts . An evaluation of the Project’s contribution to potential cumulative noise impacts is also provided. Noise worksheets and technical data used in this analysis are provided in Appendix G, Noise Documentation, of this Draft EIR.
4.8.2 Noise and Vibration Basics
Noise Principles and Descriptors
Sound can be described as the mechanical energy of a vibrating object transmitted by pressure waves through a liquid or gaseous medium (e.g., air). Noise is generally defined as undesirable (i.e., loud, unexpected, or annoying) sound. Acoustics is defined as the physics of sound and addresses its propagation and control.1 In acoustics, the fundamental scientific model consists of a sound (or noise) source, a receiver, and the propagation path between the two. The loudness of the noise source and obstructions or atmospheric factors affecting the propagation path to the receiver determine the sound level and characteristics of the noise perceived by the receiver.
Sound, traveling in the form of waves from a source, exerts a sound pressure level (referred to as sound level) that is measured in decibels (dB), which is the standard unit of sound amplitude measurement and reflects the way people perceive changes in sound amplitude2. The dB scale is a logarithmic scale that describes the physical intensity of the pressure vibrations that make up any sound, with 0 dB corresponding roughly to the threshold of human hearing and 120 to 140 dB corresponding to the threshold of feeling pai n. Pressure waves traveling through air exert a force registered by the human ear as sound.3
Sound pressure fluctuations can be measured in units of hertz (Hz), which correspond to the frequency of a particular sound. Typically, sound does not consist of a single frequency, but, rather, a broad band of frequencies varying in levels of magnitude. When all of the audible frequencies of a sound are measured, a sound spectrum is plotted consisting of a range of frequencies spanning 20 to 20,000 Hz. The sound pressure level, therefore, constitutes the additive force exerted by a sound corresponding to the sound frequency/sound power level spectrum.4 The typical human ear is not equally sensitive to the frequency range from 20 to 20,000 Hz. As a consequence, when assessing potential noise impacts, sound is measured using an electronic filter
1 California Department of Transportation (Caltrans), Technical Noise Supplement (TeNS) to the Traffic Noise Analysis Protocol, Section 2.2.1, September 2013.
2 All sound levels measured in decibel (dB), as identified in the noise calculation worksheets included in Appendix G of this Draft EIR and in this section of the Draft EIR, are relative to 2x10-5 N/m2. 3 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.3, September 2013. 4 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.3, September 2013.
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that deemphasizes the frequencies below 1,000 Hz and above 5,000 Hz in a manner corresponding to the human ear’s decreased sensitivity to these extremely low and extremely high frequencies.
This method of frequency filtering or weighting is referred to as A-weighting, expressed in units of A -weighted decibels (dBA), which is typically applied to community noise measurements. 5 Some representative common outdoor and indoor noise sources and their corresponding A - weighted noise levels are shown in Figure 4.8-1, Decibel Scale and Common Noise Sources.
Noise Exposure and Community Noise
Community noise exposure is typically measured over a period of time; a noise level is a measure of noise at a given instant in time. Community noise varies continuously over a period of time with respect to the sound sources contributing to the community noise environment. Community noise is primarily the product of many distant noise sources, which constitute a relatively stable background noise exposure, with many unidentifiable individual contributors. Single-event noise sources, such as aircraft flyovers, sirens, etc., may cause sudden changes in background noise level. 6 However, generally, background noise levels change gradually throughout the day, corresponding with the addition and subtraction of distant noise sources, such as changes in traffic volume.
These successive additions of sound to the community noise environment change the community noise level from moment to moment, requiring the noise exposure to be measured over periods of time to legitimately characterize a community noise environment and evaluate cumulative noise impacts. The following noise descriptors are used to characterize environmental noise levels over time.7 Leq: The equivalent sound level over a specified period of time, typically, 1 hour (Leq). The Leq may also be referred to as the average sound level.
Lmax: The maximum, instantaneous noise level experienced during a given period of time.
Lmin: The minimum, instantaneous noise level experienced during a given period of time.
Lx: The noise level exceeded a percentage of a specified time period. For instance, L50 and L90 represent the noise levels that are exceeded 50 percent and 90 percent of the time, respectively.
Ldn: The average A-weighted noise level during a 24-hour day, obtained after an addition of 10 dBA to measured noise levels between the hours of 10:00 p.m. to 7:00 a.m. the next day to account for nighttime noise sensitivity. The Ldn is also termed the day-night average noise level (DNL).
CNEL: The Community Noise Equivalent Level (CNEL) is the time average A-weighted noise level during a 24 -hour day that includes an addition of 5 dBA to measured noise levels between the hours of 7:00 p.m. to 10:00 p.m. and an addition of 10 dBA to noise levels between the hours of 10:00 p.m. to 7:00 a.m. the next day to account for noise sensitivity in the evening and nighttime, respectively.
5 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.3, September 2013. 6 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.1, September 2013. 7 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.2, September 2013. 5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.8-1
Decibel Scale and Common Noise Sources
D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR\Illustrator SOURCE: State of California, Department of Transportation (Caltrans), Technical Noise Supplement (TeNS). October 1998. Available:
http://www.dot.ca.gov/hq/env/noise/pub/Technical Noise Supplement.pdf 110
100
90 80
70 60
50 40
30 20
10 0
Rock Band
Inside Subway Train (New York)
Food Blender at 3 Ft.
Garbage Disposal at 3 Ft.
Shouting at 3 Ft.
Vacuum Cleaner at 10 Ft.
Large Business Office
Concert Hall (Background)
Broadcast and Recording Studio
Threshold of Hearing
Jet Flyover at 1000 Ft.
COMMON INDOOR
NOISE LEVELS
COMMON OUTDOOR
NOISE LEVELS
NOISE
LEVEL
(dBA, Leq)
Gas Lawn Mower at 3 Ft.
Diesel Truck at 50 Ft.
Noisy Urban Daytime
Gas Lawn Mower at 100 Ft.
Commercial Area
Heavy Traffic at 300 Ft.
Quiet Urban Nighttime
Quiet Suburban Nighttime
Quiet Rural Nighttime
Small Theater, Large
Conference Room (Background)
Library
Dishwasher Next Room Quiet Urban Daytime
r ESA
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Effects of Noise on People
Noise is generally loud, unpleasant, unexpected, or undesired sound that is typically associated with human activity that is a nuisance or disruptive. The effects of noise on people can be placed into four general categories:
• Subjective effects (e.g., dissatisfaction, annoyance); • Interference effects (e.g., communication, sleep, and learning interference); • Physiological effects (e.g., startled response); and
• Physical effects (e.g., hearing loss).
Although exposure to high noise levels has been demonstrated to cause physical and physiological effects, the principal human responses to typical environmental noise exposure are related to subjective effects and interference with activities. Interference effects interrupt daily activities and include interference with human communication activities, such as normal conversations, watching television, telephone conversations, and interference with sleep.8 The World Health Organization’s Guidelines for Community Noise details the adverse health effects of high noise levels, which include hearing impairment, speech intelligibility, sleep disturbance, physiological functions (e.g., hypertension and cardiovascular effects), mental illness, performance of cognitive tasks, social and behavioral effects (e.g., feelings of helplessness, aggressive behavior), and annoyance.9
With regard to the subjective effects, the responses of individuals to similar noise events are diverse and influenced by many factors, including the type of noise, the perceived importance of the noise, the appropriateness of the noise to the setting, the duration of the noise, the time of day and the type of activity during which the noise occurs, and individual noise sensitivity. Overall, there is no completely satisfactory way to measure the subjective effects of noise, or the corresponding reactions of annoyance and dissatisfaction on people. A wide variation in individual thresholds of annoyance exists, and different tolerances to noise tend to develop based on an individual’s past experiences with noise. Thus, an important way of predicting a human reaction to a new noise environment is the way it compares to the existing environment to which one has adapted (i.e., comparison to the ambient noise environment). In general, the more a new noise level exceeds the previously existing ambient noise level, the less acceptable the new noise level will be judged by those hearing it. With regard to increases in A-weighted noise level, the following relationships generally occur:10 • Except in carefully controlled laboratory experiments, a change of 1 dBA in ambient noise levels cannot be perceived;
• Outside of the laboratory, a change of 3 dBA in ambient noise levels is considered to be a barely perceivable difference;
8 World Health Organization Team, edited by Berglund, Birgitta; Lindvall, Thomas; Schwela, Dietrich H, Guidelines for Community Noise, 1999.
9 World Health Organization Team, edited by Berglund, Birgitta; Lindvall, Thomas; Schwela, Dietrich H, Guidelines for Community Noise, 1999.
10 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.1, 2013.
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• A change of 5 dBA in ambient noise levels is considered to be a readily perceivable difference; and
• A change of 10 dBA in ambient noise levels is subjectively heard as doubling of the perceived loudness.
These relationships between change in noise level and human hearing response occur in part because of the logarithmic nature of sound and the dB scale. Because the dBA scale is based on logarithms, two noise sources do not combine in a simple additive fash ion, but, rather, logarithmically. Under the dBA scale, a doubling of sound energy corresponds to a 3 dBA increase. In other words, when two sources are each producing sound of the same loudness, the resulting sound level at a given distance would be approximately 3 dBA higher than one of the sources under the same conditions.
For example, if two identical noise sources produce noise levels of 50 dBA, the combined sound level would be 53 dBA, not 100 dBA. Under the dB scale, three sources of equal loudness together produce a sound level of approximately 5 dBA louder than one source, and 10 sources of equal loudness together produce a sound level of approximately 10 dBA louder than the single source.11 Noise Attenuation
When noise propagates over a distance, the noise level reduces, or attenuates, with distance depending on the type of noise source and the propagation path. Noise from a localized source (i.e., point source) propagates uniformly outward in a spherical pattern, referred to as “spherical spreading.” The rate of sound attenuation for a point source, such as a piece of mechanical or electrical equipment (e.g., air conditioner) or idling vehicle (e.g., bulldozer), is 6 dBA per doubling of distance from the noise source to the receptor over acoustically “hard” sites and 7.5 dBA per doubling of distance from the noise source to the receptor over acoustically “soft” sites.12 Hard sites are those with a reflective surface between the source and the receiver, such as asphalt or concrete surfaces or smooth bodies of water.
No excess ground attenuation is assumed for hard sites and the reduction in noise levels with distance (drop-off rate) is simply the geometric spreading of the noise from the source. Soft sites have an absorptive ground surface, such as soft dirt, grass, or scattered bushes and trees, which in addition to geometric spreading, provides an excess ground attenuati on value of 1.5 dBA (per doubling distance).13 For example, an outdoor condenser fan that generates a sound level of 60 dBA at a distance of 50 feet from a point source at an acoustically hard site would attenuate to 54 dBA at a distance of 100 feet from the point source and attenuate to 48 dBA at 200 feet from the point source.
Roadways and highways consist of several localized noise sources on a defined path, and, hence, are treated as “line” sources, which approximate the effect of several point sources.14 Noise from a line source propagates over a cylindrical surface, often referred to as “cylindrical spreading.”15 Line sources (e.g., traffic noise from vehicles) attenuate at a rate between 3 dBA for hard sites and 4.5
11 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.2.1.1, September 2013. 12 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Sections 2.1.4.1 and 2.1.4.2, September 2013.
13 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Sections 2.1.4.1 and 2.1.4.2, September 2013.
14 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.4.1, September 2013. 15 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.4.1, September 2013.
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dBA for soft sites for each doubling of distance from the reference measurement.16 Therefore, noise due to a line source attenuates less with distance than that of a point source with increased distance.
Structures (e.g., buildings and solid walls) and natural topography (e.g., hills and berms) that obstruct the line -of-sight between a noise source and a receptor further reduce the noise level if the receptor is located within the “shadow” of the obstructi on, such as behind a sound wall. This type of sound attenuation is known as “barrier insertion loss.” If a receptor is located behind the wall but still has a view of the source (i.e., the line -of-sight is not fully blocked), barrier insertion loss would s till occur but to a lesser extent. Additionally, a receptor located on the same side of the wall as a noise source may actually experience an increase in the perceived noise level as the wall can reflect noise back to the receptor, thereby compounding the noise. Noise barriers can provide noise level reductions ranging from approximately 5 dBA (where the barrier just breaks the line -of-sight between the source and receiver) to an upper range of 20 dBA with a larger barrier.17 Additionally, structures with closed windows can further attenuate exterior noise by a minimum of 20 dBA to 30 dBA. 18
Receptors located downwind from a noise source can be exposed to increased noise levels relative to calm conditions, whereas locations upwind can have lowered noise levels. 19 Atmospheric temperature inversion (i.e., increasing temperature with elevation) can increase sound levels at long distances. Other factors such as air temperature, humidity, and turbulence can, under t he right conditions, also have substantial effects on noise levels.20 Vibration Fundamentals
Vibration can be interpreted as energy transmitted in waves through the ground or man -made structures, which generally dissipate with distance from the vibration source. Vibration is an oscillatory motion through a solid medium in which the motion’s amplitude can be described in terms of displacement, velocity, or acceleration. Since energy is lost during its transfer from one particle to another, vibration becomes less perceptible with increasing distance from the source.
As described in the Federal Transit Administration’s (FTA) Transit Noise and Vibration Impact Assessment Manual , groundborne vibration can be a serious concern for nearby neighbors of a transit system route or maintenance facility, causing buildings to shake and rumbling sounds to be heard.21 In contrast to airborne noise, groundborne vibration is not a common environmental problem, as it is unusual for vibration from sources such as rubber -tired buses and trucks to be perceptible, even in locations close to major roads. Some common sources of groundborne vibration are trains, heavy trucks traveling on rough roads, and certain construction activities, such as blasting, pile-driving, and operation of heavy earth-moving equipment.22 Groundborne vibration
16 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.4.1, 2013. 17 Caltrans, TeNS to the Traffic Noise Analysis Protocol, Sections 2.1.4.24 and 5.1.1, September 2013. 18 Caltrans, TeNS to the Traffic Noise Analysis Protocol, Section 7.4.2, Table 7-1, September 2013. 19 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.4.3, September 2013. 20 Caltrans, Technical Noise Supplement to the Traffic Noise Analysis Protocol, Section 2.1.4.3, September 2013. 21 Federal Transit Administration (FTA), Transit Noise and Vibration Impact Assessment Manual, Section 7, 2018. 22 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 7, 2018.
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generated by man -made activities (e.g., road traffic, construction operations) typically weakens with greater horizontal distance from the source of the vibration.
Several different methods are used to quantify vibration. The peak particle velocity (PPV) is defined as the maximum instantaneous peak of the vibration signal in inches per second (in/sec), and is most frequently used to describe vibration impacts to buildings.23 The root mean square (RMS) amplitude is defined as the average of the squared amplitude of the signal and is most frequently used to describe the effect of vibration on the human body.24 Decibel notation (VdB) is commonly used to express RMS vibration velocity amplitude. The relationship of PPV to RMS velocity is expressed in terms of the “crest factor,” defined as the ratio of the PPV amplitude to the RMS amplitude. PPV is typically a factor of 1.7 to 6 times greater than RMS vibration velocity; FTA uses a crest factor of
4. 25 The decibel notation VdB acts to compress the range of numbers required to describe vibration.
Typically, groundborne vibration generated by man-made activities attenuates rapidly with distance from the source of the vibration. Sensitive receptors for vibration include buildings where vibration would interfere with operations within the building or cause damage (especially older masonry structures), locations where people sleep, and locations with vibration sensitive equipment.26 Groundborne noise specifically refers to the rumbling noise emanating from the motion of building room surfaces due to the vibration of floors and walls; it is perceptible only inside buildings.27 The relationship between groundborne vibration and groundborne noise depends on the frequency of the vibration and the acoustical absorption characteristics of the receiving room. For typical buildings, groundborne vibration that causes low frequency noise (i.e., the vibration spectrum peak is less than 30 Hz) results in a groundborne noise level that is approximately 50 decibels lower than the velocity level. For groundborne vibration that causes mid-frequency noise (i.e., the vibration spectrum peak is between 30 and 60 Hz), the groundborne noise level will be approximately 35 to 37 decibels lower than the velocity level.28 Therefore, for typical buildings, the groundborne noise decibel level is lower than the groundborne vibration velocity level at low frequencies.
4.8.3 Environmental Setting
Regulatory Framework
Federal
Noise Control Act of 1972
Under the authority of the Noise Control Act of 1972, the United States Environmental Protection Agency (USEPA) established noise emission criteria and testing methods published in Parts 201 through 205 of Title 40 of the Code of Federal Regulations (CFR) that apply to some transportation equipment (e.g., interstate rail carriers, medium trucks, and heavy trucks) and construction equipment. In 1974, USEPA issued guidance levels for the protection of public health and welfare
23 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 5.1, 2018. 24 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 5.1, 2018. 25 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 5.1, 2018. 26 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 6.1, 6.2, and 6.3, 2018. 27 FTA, Transit Noise and Vibration Impact Assessment Manual, Section 5.4, 2018. 28 FTA, Transit Noise and Vibration Impact Assessment Manual, Table 6-3 and Table 6-14, September 2018.
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in residential areas of an outdoor L dn of 55 dBA and an indoor L dn of 45 dBA. 29 These guidance levels are not standards or regulations and were developed without consideration of technical or economic feasibility. There are no federal noise standards that directly regulate environmental noise related to the construction or operation of the Project. Moreover, the federal noise standards are not reflective of urban environments that range by land use, density, proximity to commercial or industrial centers, etc. As such, for purposes of determining acceptable sound levels to determine and evaluate intrusive noise sources and increases, this document utilizes the City of Culver City Noise Regulations, discussed below.
Federal Transit Administration Vibration Standards
There are no federal vibration standards or regulations adopted by any agency that are applicable to evaluating vibration impacts from land use development projects such as the Project. However, the FTA has adopted vibration criteria for use in evaluating vibration impacts from construction activities.30 The vibration damage criteria adopted by the FTA are shown in Table 4.8-1, Construction Vibration Damage Criteria.
TABLE 4.8-1
CONSTRUCTION VIBRATION DAMAGE CRITERIA
Building Category PPV (in/sec)
I. Reinforced-concrete, steel, or timber (no plaster) 0.5 II. Engineered concrete and masonry (no plaster) 0.3
III. Non-engineered timber and masonry buildings 0.2
IV. Buildings extremely susceptible to vibration damage 0.12 SOURCE: FTA, Transit Noise and Vibration Impact Assessment Manual, 2018.
The FTA has also adopted standards associated with human annoyance for determining the groundborne vibration and noise impacts from groundborne noise on the following three off-site land- use categories: Vibration Category 1 – High Sensitivity, Vibration Category 2 – Residential, and Vibration Category 3 – Institutional.31 The FTA defines Category 1 as buildings where vibration would interfere with operations within the building, including vibration-sensitive research and manufacturing facilities, hospitals with vibration-sensitive equipment, and university research operations. Vibration- sensitive equipment includes, but is not limited to, electron microscopes, high-resolution lithographic equipment, and normal optical microscopes. Category 2 refers to all residential land uses and any buildings where people sleep, such as hotels and hospitals. Category 3 refers to institutional land uses such as schools, churches, other institutions, and quiet offices that do not have vibration -sensitive equipment but that still potentially involve activities that could be disturbed by vibration. The vibration thresholds associated with human annoyance for these three land use categories are shown in Table 4.8-2, Groundborne Vibration and Groundborne Noise Impact Criteria for General Assessment. No thresholds have been adopted or recommended for commercial or office uses.
29 United States Environmental Protection Agency, EPA Identifies Noise Levels Affecting Health and Welfare, 1974. 30 FTA, Transit Noise and Vibration Impact Assessment Manual, Table 7-5, page 186, 2018. 31 FTA, Transit Noise and Vibration Impact Assessment Manual, Table 6-1, page 124, 2018.
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TABLE 4.8-2
GROUNDBORNE VIBRATION AND GROUNDBORNE NOISE IMPACT CRITERIA FOR
GENERAL ASSESSMENT
Land Use Category
Frequent
Eventsa
Occasional
Eventsb
Infrequent
Eventsc
Category 1: Buildings where vibration would interfere with interior operations. 65 VdBd 65 VdBd 65 VdBd Category 2: Residences and buildings where people normally sleep. 72 VdB 75 VdB 80 VdB Category 3: Institutional land uses with primarily daytime use. 75 VdB 78 VdB 83 VdB NOTES:
a “Frequent Events” is defined as more than 70 vibration events of the same source per day. b “Occasional Events” is defined as between 30 and 70 vibration events of the same source per day. c “Infrequent Events” is defined as fewer than 30 vibration events of the same kind per day. d This criterion is based on levels that are acceptable for most moderately sensitive equipment, such as optical microscopes.
SOURCE: FTA, Transit Noise and Vibration Impact Assessment Manual, September 2018.
Occupational Safety and Health Act of 1970
Under the Occupational Safety and Health Act of 1970 (29 United States Code [USC] Sections 1919 et seq.), the Occupational Safety and Health Administration (OSHA) has adopted regulations designed to protect workers against the effects of occupational noise exposure. These regulations list permissible noise level exposure as a function of the amount of time during which the worker is exposed. The regulations further specify a hearing conservation program that involves monitoring noise to which workers are ex posed, ensuring that workers are made aware of overexposure to noise, and periodically testing the workers’ hearing to detect any degradation.32 State
Office of Planning and Research Guidelines for Noise Compatible Land Use The State of California has not adopted Statewide standards for environmental noise, but the Governor’s Office of Planning and Research (OPR) has established guidelines for evaluating the compatibility of various land uses as a function of community noise exposure, as presented in Figure 4.8-2, Guidelines for Noise Compatible Land Use.33 The purpose of these guidelines is to maintain acceptable noise levels in a community setting for different land use types. Noise levels are divided into four general categories, which vary in range according to land use type: “normally acceptable,” “condi tionally acceptable,” “normally unacceptable,” and “clearly unacceptable.” The City has developed its own compatibility guidelines in the Noise Element of the General Plan based in part on OPR Guidelines. California Government Code Section 65302 requires each county and city in the State to prepare and adopt a comprehensive long-range general plan for its physical development, with Section 65302(f) requiring a noise element to be included in the general plan. The Noise Element must identify and appraise noise problems in the community and analyze and quantify current and projected noise levels.
32 United States Department of Labor. OSH Act of 1970.
33 State of California, Governor’s Office of Planning and Research, General Plan 2017 Guidelines, page 377, 2017.
Land Use Category Noise Exposure (Ldn or CNEL, dBA)
55 60 65 70 75 80
Residential – Low Density Single-Family, Duplex,
Mobile Home
Residential – Multiple Family
Transient Lodging – Motel, Hotel
School, Library, Church, Hospital, Nursing Home
Auditorium, Concert Hall, Amphitheater
Sports Arena, Outdoor Spectator Sports
Playground, Neighborhood Park
Golf Course, Riding Stable, Water Recreation,
Cemetery
Office Building, Business Commercial and Professional
Industrial, Manufacturing, Utilities, Agriculture
NORMALLY ACCEPTABLE: Specified land use is satisfactory, based upon the assumption that any buildings involved are of normal conventional construction, without any special noise insulation requirements.
CONDITIONALLY ACCEPTABLE: New construction or development should be undertaken only after a detailed analysis of the noise reduction requirements is made and needed noise insulation features included in the design.
NORMALLY UNACCEPTABLE: New construction or development should be discouraged. If new construction or development does proceed, a detailed analysis of the noise reduction requirement must be made and needed noise insulation features included in the design.
CLEARLY UNACCEPTABLE: New construction or development should generally not be undertaken.
Construction costs to make the indoor environmental acceptable would be prohibitive and the outdoor environment would not be usable. 5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.8-2
Guidelines for Noise Compatible Land Use
SOURCE: State of California, General Plan Guidelines,
Governor’s Office of Planning and Research, 2003D202201041.01 - 5700 Hannum Avenue EIR\05 Graphics-GIS-Modeling-USE AZURE\EIR\Illustrator ~
1111111111111
r ESA
~
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The State has also established noise insulation standards for new multi -family residential units, hotels, and motels. These requirements are collectively known as the California Noise Insulation Standards (Title 24 of the California Code of Regulations [CCR]). The noise insulation standards set forth an interior standard of 45 dBA CNEL in any habitable room. The standards require an acoustical analysis demonstrating how dwelling units have been designed to meet this interior standard where such units are proposed in areas subject to exterior noise levels greater than 60 dBA CNEL. Title 24 standards are typically enforced by local jurisdictions through the building permit application process.
Assembly Bill 1307
Assembly Bill (AB) 1307 states that the effects of noise generated by project occupants and their guests on human beings shall not be considered a significant effect on the environment under CEQA given that the project is categorized within one of the following definitions as outlined in Section 21085.2 of AB 130734:
1) “Long-range development plan” means a physical development and land use plan to meet the academic and institutional objectives for a particular campus or medical center of public higher education.
2) “Public higher education” means the institutions described in subdivision (a) of Section 66010 of the Education Code.
3) “Residential or mixed-use housing project” means a project consisting of residential uses only or a mix of residential and nonresidential uses, with at least two-thirds of the square footage of the development designated for residential uses.
4) “Substantially surrounded” means at least 75 percent of the perimeter of the project site adjoins, or is separated only by an improved public right-of-way from, parcels that are developed with qualified urban uses.
5) Notwithstanding any other law or regulation, institutions of public higher education shall not be required, in an environmental impact report prepared for a residential or mixed-use housing project, to consider alternatives to the location of the residenti al or mixed-use housing project if both of the following requirements are met:
6) The residential or mixed-use housing project is located on a site that is no more than five acres and is substantially surrounded by qualified urban uses. 7) The residential or mixed-use housing project has already been evaluated in the environmental impact report for the most recent long-range development plan for the applicable campus.
The Project meets criteria No. 3 as a mixed -use housing project. Thus, noise generated by the Project occupants and their guests is not considered a significant effect on the environment under CEQA.
Regional
Los Angeles County Airport Land Use Commission Comprehensive Land Use Plan In Los Angeles County, the Regional Planning Commission has the responsibility for acting as the Airport Land Use Commission and for coordinating the airport planning of public agencies within
34 California Legislative Information, Assembly Bill No. 1307. September 7, 2023. Available at:
https://leginfo.legislature.ca.gov/faces/billTextClient.xhtml?bill_id=202320240AB1307. Accessed October 2023.
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the county. The Airport Land Use Commission coordinates planning for the areas surrounding public use airports. The Comprehensive Land Use Plan provides for the orderly expansion of Los Angeles County's public use airports and the area surrounding them. It is intended to provide for the adoption of land use measures that will minimize the public’s exposure to excessive noise and safety hazards. In formulating the Comprehensive Land Use Plan, the Los Angeles County Airport Land Use Commission has established provisions for safety, noise insulation, and the regulation of building height within areas adjacent to each of the public airports in the County.
Local
City of Culver City General Plan Noise Element
The City of Culver City Noise Standards are developed from those of several federal and State agencies including the FHWA, the USEPA, the Department of Housing and Urban Development, the American National Standards Institute, and the State of California De partment of Health Services. These standards set limits on the noise exposure level for various land uses. Table 4.8-3, City of Culver City Noise Standards, lists exterior noise level standards and the type of occupancy to which they should be applied. As with the California Noise Standards described above, these General Plan standards are related to the siting of land uses and are not typically used as thresholds of significance for determining noise impacts associated with construction and operation of th e Project. However, the standards do provide a means for judging whether an existing noise environment would be compatible with development of a new noise-sensitive land use or whether a new use would create an incompatible noise environment for existing noise-sensitive uses.
TABLE 4.8-3
CITY OF CULVER CITY NOISE STANDARDS
Zone Interior Standards (dBA CNEL) Exterior Standard (dBA CNEL) Residential 45 65
Commerciala 45 65
a This applies to Hotel, Motel, Transient Lodging, and not to other commercial uses such as retail.
SOURCE: City of Culver City, General Plan, Noise Element, 1996.
The City’s General Plan Noise Element includes the following policy related to noise control:
Policy 2.A Create a comprehensive ordinance establishing noise regulation criteria, and standards for noise sources and receptors to include but not be limited to the following:
• Noise reduction features during site planning to mitigate anticipated noise impacts on affected noise sensitive land uses, such as schools, hospitals, convalescent homes, and libraries.
• Temporary sound barrier installation at construction site if construction noise is impacting nearby noise sensitive land uses.
• Noise abatement and acoustical design criteria for construction and operation of any new development.
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City of Culver City Municipal Code
Chapter 9.07 of the City of Culver City Municipal Code (CCMC) provides specific noise restrictions and exemptions for noise sources within the City. CCMC noise regulations state that construction activity shall be prohibited, except between the hours of 8: 00 a.m. and 8:00 p.m.
Mondays through Fridays; 9:00 a.m. and 7:00 p.m. Saturdays; 10:00 a.m. and 7:00 p.m. Sundays.
There are no established noise limits for noise associated with construction activity when construction occurs within the permitted hours. It is prohibited for any person to operate any radio, disc player or cassette player or similar device at a construction site in a manner that results in noise levels that are audible beyond the construction site property line.
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 on an on -going basis which is audible at the subject property line. This section is applicable only to uses that would include regular and on -going amplification, such as outdoor speakers used for a drive-through restaurant.
4.8.4 Existing Conditions
The predominant existing noise source surrounding the Project Site is traffic noise from Slauson Avenue, Hannum Avenue, Buckingham Parkway, and Uplander Way. Secondary noise sources include general industrial/commercial -related activities, such as loading area/delivery truck activities, trash compaction, and refuse service activities, from the business park/office land uses to the north, west, and southwest of the Project Site. Periodic noise also occurs from residential activities, including lawnmowing and landscaping activities, from residences to the east and south of the Project Site located across Buckingham Avenue.
Noise-Sensitive Receptor Locations
Some land uses are considered more sensitive to noise than others due to the amount of noise exposure and the types of activities typically involved at the receptor location. Residences, schools, motels and hotels, libraries, religious institutions, hospitals, nursing homes, and parks are generally more sensitive to noise than commercial and industrial land uses. Existing noise sensitive uses near the Project Site include the following:
• R1: 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. • R2: Fox Hills Park to the south/southwest of the Project Site, west of Buckingham Parkway, approximately 670 feet from the Project boundary.
• R3: Multi -family r esidential uses to the south east of the Project Site, on the east side of Buckingham Parkway between Cambridge Way and Windsor Way, approximately 50 feet from the Project boundary.
• R4: 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 east of the Project Site.
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• R5: Multi-family residential uses to the northeast of the Project Site, on the east side of Buckingham Parkway between Slauson Avenue and Canterbury Drive, approximately 550 feet from the Project boundary.
Commercial Land Uses
Commercial land uses, such as retail and office , are not considered sensitive noise receptors.
However, for informational purposes only, t he following commercial land uses near the Project Site were evaluated:
• R6: Commercial land uses north of the Project Site, approximately 100 feet from the Project boundary.
• R7: Commercial land uses west of the Project Site, approximately 50 feet from the Project boundary.
• R8: Commercial land uses south/southwest of the Project Site, approximately 250 feet from the Project boundary.
Vibration-Sensitive Receptor Locations
Typically, groundborne vibration generated by man -made activities (i.e., rail and roadway traffic, operation of mechanical equipment and typical construction equipment) diminishes rapidly with distance from the vibration source. Construction activities, such as the use of bulldozers , would have the greatest effect on vibration-sensitive land uses. Energy is lost during the transfer of energy from one particle to another, and, as a result, vibration becomes less perceptible with increasing distance from the source. Wit h respect to potential structural damage, structures within approximately 100 feet to the Project Site are analyzed to determine if there would be impacts resulting in structural damage. As shown in Table 4.8-1, the structural category/construction type (i.e., reinforced -concrete, engineered concrete, non -engineered timber, building susceptible to damage, and historic buildings ) determines the vibration damage criteria for a specific building/structure.35 The structures in the vicinity of the Project Site range from Category I, which are defined as reinforced-concrete, steel, or timber (no plaster) capable of handling up to 0.5 in/sec PPV of vibration, to Category III, which hare defined as non -engineered timber and masonry buildings capable of handling up to 0.12 in/sec PPV of vibration. The following structures were considered in the vibration analysis:
• Category I:
– 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.
35 Where the structural category/type of a vibration-sensitive receptor is unclear, the analysis herein utilizes a conservative assumption. For example, although structures where industrial processes take place would generally be constructed of concrete, the threshold for non-engineered timber and masonry has been applied due to the uncertainty of building construction.
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• Category III:
– Multi-family r esidential uses to the south of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet from the Project boundary. – Multi-family residential uses and Fox Hills Parkette to the east of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet to the east of the Project Site.
With respect to human annoyance, sensitive land uses include buildings where use of vibration - sensitive equipment is used (e.g., hospitals, research, and manufacturing), residential land uses and buildings where people normally sleep, schools, churches, an d doctor’s offices. 36 Therefore, the land uses within approximately 100 feet to the Project Site considered for human annoyance impacts are:
• R3: Multi-family residential uses to the south of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet from the Project boundary. • R4: Multi-family residential uses and Fox Hills Parkette to the east of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet to the east of the Project Site.
Ambient Noise Levels
To quantify the existing noise environment, two sets of short-term (15-minute) measurements were conducted at eight locations, representing the ambient noise levels at land uses identified as R1 through R8 in Figure 4.8-3, Surrounding Land Uses and Noise Measurement Locations . A 15- minute measurement is a reasonable duration for sampling ambient noise levels where street traffic is the dominant source, as traffic noise generally does not vary significantly within an hour.
Ambient sound measurements were conducted on Wednesday, October 11 and Thursday, October 12, 2023, to characterize the existing noise environment in the Project vicinity. The first set of measurements were taken between 6:30 a.m. and 8:00 a.m. to capture ambient morning noise levels.37 The second set of measurements were taken between 11:00 a.m. and 12:30 p.m. to capture ambient daytime noise levels. The measurement locations are described below:
• M1: Multi -family residential uses to the south/southwest of the Project Site , east of Buckingham Parkway, approximately 450 feet from the Project boundary (representative of R1).
• M2: Multi -family r esidential uses to the south of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet from the Project boundary. (representative of R3).
• M3: Multi-family residential uses and Fox Hills Parkette to the east of the Project Site, on the east side of Buckingham Parkway, approximately 50 feet to the east of the Project Site. (representative of R4).
36 FTA, Transit Noise and Vibration Impact Assessment Manual, Table 6-1, September 2018. 37 Ambient morning measurements were taken because the applicant is requesting a construction start time outside of normally allowable construction hours (9:00 a.m. to 7:00 p.m.) !(
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Slauson Ave
Hannum Ave
BuckinghamPkwy
Canterbury Dr
Windsor Way
Cambridge Way
Uplander Way
Holy Cross
Catholic Cemetery
Fox Hills
Parkette
Woolster Ave
M1
M2
M3
M4
M5
M6
M7
M8
Site Area
R1
R2
R3
R4
R5
R6
R7
R8
Path: U:\GIS\GIS\Projects\2022xxx\D202201041_01_5700HannumAvenue_EIR\03_Project\Fig4.8-3_Sens_Receptors-Noise_Measurement_Loc.mxd, dkaneshiro 11/9/2023 SOURCE: ESA, 2022; ESRI Imagery, 2022
5700 Hannum Avenue Mixed-Use Residential and Commercial Project Figure 4.8-3
Surrounding Land Uses and Noise Measurement Locations
Project Site
!( Noise Monitoring Locations
Residential Use Zone
Commercial Use ZoneN
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Buckingham
Pkwy
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4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-17 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• M4: Multi-family residential uses to the east of the Project Site, on the south side of Hannum Avenue along Buckingham Parkway, approximately 550 feet from the Project boundary. (representative of R5).
• M5: Commercial land uses north of the Project Site, approximately 100 feet from the Project boundary. (representative of R6).
• M6: Commercial land uses west of the Project Site, approximately 50 feet from the Project boundary. (representative of R7).
• M7: Commercial land uses south/southwest of the Project Site, approximately 250 feet from the Project boundary. (representative of R8).
• M8: Fox Hills Park to the south/southwest of the Project Site, west of Buckingham Parkway, approximately 670 feet from the Project boundary. (representative of R2).
Noise measurements were conducted using Larson -Davis LxT1 Sound Level Meters (SLM). The Larson-Davis LxT1 SLM is a Type 1 standard instrument as defined in the American National Standard Institute (ANSI) S1.4. All instruments were calibrated and operated a ccording to the applicable manufacturer specification. The recording microphones were placed at a height of 5 feet above the local grade elevation. The sound level meters were setup to collect the hourly average noise level (Leq).
The results of the ambient sound measurements are summarized in Table 4.8 -4, Summary of Ambient Noise Measurements.
TABLE 4.8-4
SUMMARY OF AMBIENT NOISE MEASUREMENTS
Location
Measured Ambient Morning
Noise Levels, dBA Leq
Measured Ambient Daytime
Noise Levels, dBA Leq
R1 71.5 63.0
R2 68.7 63.4
R3 62.8 59.6
R4 64.3 61.2
R5 67.5 63.2
R6 66.2 65.7
R7 56.6 57.1
R8 56.7 53.5
SOURCE: ESA, 2023.
Existing Roadway Noise Levels
To further characterize the Project area’s ambient noise environment, CNEL noise levels attributed to existing traffic on local roadways were calculated using a traffic noise prediction model, which was developed based on calculation methodologies provided in the Federal Highway
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-18 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
Administration (FHWA) Traffic Noise Model (TNM) Technical Manual, 38 and traffic data provided in the Project’s Transportation Study39 (see Appendix I of this Draft EIR). The TNM model calculates the average noise level at specific locations based on traffic volumes, average speeds, and site environmental conditions.
Existing roadway noise levels were calculated for 27 roadway segments located in the vicinity of the Project Site. The roadway segments selected for analysis are those expected to be most directly impacted by Project-related traffic, which, for the purpose of this analysis, include the roadways located near and immediately adjacent to the Project Site. These roadways, when compared to roadways located further away from the Project Site, would experience the greatest percentage increase or largest increase in volume from traffic generated by the Project (as distances are increased from the Project Site, traffic is spread out over a greater geographic area and its effects are reduced).
The ambient noise environment in the Project vicinity can be characterized by 24-hour CNEL levels attributable to existing traffic on local roadways. Table 4.8-5, Predicted Existing Vehicular Traffic Noise Levels, indicates the calculated CNEL from actual existing traffic volumes on the analyzed roadway segments.
Ambient Vibration Levels
Groundborne Vibration Levels
Aside from periodic construction work, field observations noted that other sources of groundborne vibration in the Project Site vicinity are primarily limited to heavy-duty vehicular travel (e.g., refuse trucks, delivery trucks, etc.) on local roadways. Tr ucks traveling at a distance of 50 feet typically generate groundborne vibration velocity levels of 65 VdB (approximately 0.0068 in/sec PPV).40 Groundborne Noise Levels
Groundborne noise levels would generally be 20 to 50 decibels lower than the velocity level depending on the frequency level of the source.41 With a background groundborne vibration level in residential areas of 50 VdB or lower, groundborne noise levels would be approximately 0 to 30 dBA.
A bus traveling at a distance of 50 feet would generate groundborne noise levels of approximately 23 to 38 dBA. The approximate level of human perception of groundborne noise is 25 dBA for low frequency vibration (near 30 Hz) and 40 dBA for mid-frequency vibration (near 60 Hz).42
38 The traffic noise model which was developed based on calculation methodologies provided in the Caltrans TeNS document and traffic data provided in the Project’s Transportation Study provided in Appendix I to this Draft EIR.
This methodology, considered an industry standard, allows for the definition of roadway configurations, barrier information (if any), and receiver locations.
39 Gibson Transportation Consulting, Inc., Transportation Study for 5700 Hannum Avenue, August 2023. Provided in Appendix I of this Draft EIR.
40 FTA, Transit Noise and Vibration Impact Assessment Manual, Figure 5-4, September 2018. 41 FTA, Transit Noise and Vibration Impact Assessment Manual, September 2018, p. 146. 42 FTA, Transit Noise and Vibration Impact Assessment Manual, September 2018, p. 120.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-19 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
TABLE 4.8-5
PREDICTED EXISTING VEHICULAR TRAFFIC NOISE LEVELS
Roadway Segment Adjacent Land Use Existing CNEL (dBA)a Bristol Pkwy
between Hannum Ave and Green Valley Cir Commercial 71.2 between Slauson Ave and Hannum Ave Commercial 70.1
n/o Slauson Ave Cemetery 59.8
s/o Green Valley Cir Residential/Hotel/Cemetery 64.4
Buckingham Pkwy
between Hannum Ave and Green Valley Cir Residential/Commercial/ Open Space 66.6 between Slauson Ave and Hannum Ave Residential/Commercial 61.8 n/o Hannum Ave Commercial 52.7
n/o Slauson Ave Commercial 60.6
Centinela Ave
e/o Green Valley Cir Residential/Commercial 74.4
w/o Green Valley Cir Cemetery 72.9
Fox Hills Dr
s/o Hannum Ave Commercial 65.6
Green Valley Cir
between Bristol Pkwy and Buckingham Pkwy Residential/Educational/ Open Space 69.6 between Buckingham Pkwy and Centinela Ave Residential 70.7 w/o Bristol Pkwy Hotel/Commercial 70.5
Hannum Ave
between Bristol Pkwy and Uplander Wy Commercial 68.9
between Fox Hills Dr and Bristol Pkwy Commercial 66.6
between Slauson Ave and Hannum Ave Commercial 66.8
between Uplander Wy and Buckingham Pkwy Commercial 68.8 n/o Slauson Ave Residential/Commercial 70.6
Marina Fwy
s/o Slauson Ave Freeway Off Ramp 73.1
Slauson Ave
between Bristol Pkwy and Buckingham Pkwy Commercial/Cemetery 74.8 between Hannum Ave and Marina Fwy Residential/Commercial 70.2 between Marina Fwy and Bristol Pkwy Commercial 73.8
e/o Buckingham Pkwy Residential/Commercial 75.9
w/o Hannum Ave Residential/Commercial 70.7
Uplander Wy
n/o Hannum Ave Commercial 53.9
s/o Hannum Ave Commercial 56.3
a Calculated based on existing traffic volumes.
SOURCE: ESA, 2023.
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-20 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
4.8.5 Environmental Impacts
Thresholds of Significance
The following thresholds of significance are based on the Environmental Checklist contained in Appendix G of the State CEQA Guidelines. A project would result in a significant noise or vibration impact would occur if it would result in:
• NOISE-1: Generation of a substantial temporary or permanent increase in ambient noise levels in the vicinity of the project in excess of standards established in the local general plan or noise ordinance, or applicable standards of other agencies;
• NOISE-2: Generation of excessive groundborne vibration or groundborne noise levels; or • NOISE-3: For a project located within the vicinity of a private airstrip or an airport land use plan or, where such a plan has not been adopted, within two miles of a public airport or public use airport, would the project expose people residing or working in the project area to excessive noise levels.
Potentially significant impacts related to noise are discussed and analyzed further below.
The City determined in the Initial Study that noise issues due to airport proximity (NOISE-3) would result in no impacts or less -than-significant impacts and, therefore, this issue is 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 this issue. As discussed in the Initial Study, the Project Site is not located within an airport land use plan area or within two miles of a public airport or public use airport. The Project Site is not located within the vicinity of a private airstrip, or heliport or helistop.
Airport and airfields in proximity to the Project Site include Santa Monica Airport approximately
4.2 miles to the northwest, and Los Angeles International Air port approximately 2.5 miles to the south/southwest. Therefore, the Project would not expose people to excessive noise levels from such uses and no impact would occur. No further analysis of this issue is therefore included in this Draft EIR.
Based on the regulatory framework described above, significant impacts would occur if any of the following criteria are met.
Construction:
• Noise Criteria (NC) -1: Without City approval for extended construction hours, Project construction activities would not occur between the hours of 8:00 p.m. and 8:00 a.m. Mondays through Fridays; 7:00 p.m. and 9:00 a.m. Saturdays; 7:00 p.m. and 10:00 a.m. Sundays.
Construction o ccurring within these non -permitted hours would cause a significant noise impact without City approval. That is, should extended construction hours (7:00 a.m. to 8:00 a.m. on weekdays and 7:00 a.m. to 9:00 a.m. on Saturdays ) be granted during the earthwork shoring/excavation, concrete pours (mat foundation and deck pours) and tower crane erection/disassembly phases of construction by the City of Culver City via their approval process, a determination of construction noise impacts occurring during those approved extended hours would be subject to the construction-related noise criteria below, as applicable. • NC-2: Project construction activities would not incorporate noise reduction techniques consistent with the City’s General Plan Policy 2.A of the Noise Element.
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City of Culver City 4.8-21 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
• NC-3: Project construction activities would result in noise levels 5 dBA L eq greater than measured ambient noise levels (see Table 4.8-4) at noise-sensitive receptors.
Operation:
• NC-4: For Project-related traffic noise, the Project causes the ambient noise levels measured at the property line of affected uses to increase by 3 dBA CNEL to or within the “normally unacceptable” or “clearly unacceptable” categories; or the Project causes the ambient noise levels measured at the property line of affected uses to increase by 5 dBA CNEL or more within the “normally acceptable” or “conditionally acceptable” categories. • NC-5: For Project-related operational on-site (i.e., non-roadway) noise sources such as outdoor building mechanical/electrical equipment or parking facilities increase the ambient noise level (Leq) at noise sensitive uses by 5 dBA Leq.
Groundborne Vibration and Groundborne Noise:
• NC-6: Potential Building Damage – Project construction activities cause groundborne vibration levels to exceed 0.2 inch-per-second PPV at the nearest residential buildings or 0.5 in/sec PPV at the nearest commercial buildings.
• NC-7: Potential Human Annoyance – Project construction activities cause groundborne vibration levels to exceed 75 VdB at nearby residential uses for occasional events.
Methodology
The methodology for evaluating construction and operational noise and vibration is discussed below and the calculation assumptions and results are also provided in Appendix G of this Draft EIR.
On-Site Construction Noise
On-site construction noise impacts were evaluated by determining the noise levels generated by the different types of construction activity anticipated, calculating the construction-related noise level at nearby sensitive receptor locations, and comparing these construction -related noise levels to existing ambient noise levels (i.e., noise levels without construction noise) at those r eceptors. The Project would include off -hours construction occurring between 7:00 a.m. and 8:00 a.m. on weekdays and 7:00 a.m. to 9:00 a.m. on Saturdays) , therefore the analysis includes a comparison to both morning and daytime ambient noise levels. The ty pes of construction equipment used, construction phasing, and construction schedule were provided by the Project’s construction representative. As indicated by the construction equipment list, no high-impact pile driving or vibratory pile equipment would be used for Project construction. Instead, shoring piles will be drilled to minimize noise and vibration.
Over the course of a construction day, the highest noise levels would be generated when multiple pieces of construction equipment are being operated concurrently. The Project’s estimated construction noise levels were calculated for a scenario in which all pieces of construction equipment would operate simultaneously with the loudest type of equipment located at the construction area nearest to the affected receptors to present a conservative impact analysis. The
4. Environmental Impacts Analysis
4.8. Noise
City of Culver City 4.8-22 5700 Hannum Avenue Mixed-Use Residential and Commercial Project SCH No. 2023080709 April 2024
remaining equipment was assumed to be located at the center of the Project Site. The following steps were undertaken to assess construction-period noise impacts.
1. Ambient noise levels at surrounding sensitive receptor locations were estimated based on field measurement data (see Table 4.8-4);
2. Typical noise levels for each type of construction equipment were obtained from the Federal Highway Administration Roadway Construction Noise Model (RCNM);
3. Distances between construction site locations (noise sources) and surrounding sensitive receptors were measured using Project architectural drawings and site plans and Google Earth;
4. The construction noise levels were then calculated for each construction phase using the FHWA RCNM, conservatively, in terms of hourly L eq, for sensitive receptor locations based on the standard point source noise-distance attenuation factor of 6.0 dBA for each doubling of distance, assuming that all of the equipment for each construction phase would be in use concurrently and that the loude st equipment would be located at the edge of the Project Site closest to the sensitive receptor locations and;
5. Construction noise levels were then compared to the construction noise significance thresholds identified above.
Off-Site Roadway Noise (Construction and Operation)
Roadway noise impacts have been evaluated using the Caltrans Technical Noise Supplement (TeNS) method based on the roadway traffic volume da ta provided in the Transportation Study43 prepared for the Project and included in Appendix I of this Draft EIR. This method allows for the definition of roadway configurations, barrier information (if any), and receiver locations. Roadway noise attributable to Project development was calculated and compared to baseline noise levels that would occur under the “Without Project” condition.
Stationary Point-Source Noise (Operations)
Stationary point-source noise impacts were evaluated by identifying the noise levels generated by outdoor stationary noise sources, such as rooftop mechanical equipment , parking structure, and loading area activity, calculating the hourly L eq noise level from each noise source (incorporating individual usage factor for each equipment) at sensitive receptor property lines, and comparing such noise levels to existing ambient noise levels. More specifically, the following steps were undertaken to calculate outdoor stationary point-source noise impacts:
1. Ambient noise levels at surrounding sensitive receptor locations were estimated based on field measurement data (see Table 4.8-4);
2. Typical noise levels generated by each type of stationary point-source noise generator including mechanical equipment, loading area, and parking structure operations were obtained from measured noise levels for similar equipment/activities, noise levels published in environmental noise assessment documents for land use development projects or scientific journals, or noise levels from equipment manufacturer specifications;